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.

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.




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 https://www.i5rosequarter.org/library/, 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.

    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).  https://www.fhwa.dot.gov/programadmin/pt2006q1.cfm
    • 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.

    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. https://doi.org/10.18128/D010.V10.0.

    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. https://doi.org/10.3334/ORNLDAAC/1735

    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 fuel economy through 2019. Average fleet economy was about 22.2 miles per gallon in 2019, far short of the targets set in the Metro modeling.

    2. Average vehicle age is 50 percent older than assumed modeling.  According to the Bureau of Transportation Statistics, the average age of an automobile in the United States is now 11.9 years, up from 10 years in 2004.  The Metro Climate Smart Plan assumed that the average age of a vehicle would decline by about 25 percent, from 10 years to 8 years; instead, the average age of a vehicle has increased by almost 20 percent, from 10 years to almost 12.  The average vehicle today is now 50 percent older than assumed in the Metro climate plan.

    3. Trucks and SUVs are displacing passenger cars, not the other way around.  A critical assumption in the Climate Smart Plan and the RTP is that consumers would buy more and more passenger cars, and fewer trucks and sport utility vehicles.  In fact, the opposite has happened:  since 2015—when sales of cars and SUVs/Trucks were roughly equal—it’s now the case that truck/SUV sales account for roughly 75 percent of all new vehicle sales.

    4. Vehicle electrification is occurring very slowly
    .  Many like to assume that electric vehicles will quickly and easily reduce carbon emissions.  Yet electrification is happening too slowly and on far too small a scale to materially affect transportation greenhouse gas emissions. ODOT’s October 2019 revenue forecast predicts the size and composition of Oregon’s light duty vehicle fleet through 2029.  They forecast that in 2029 Oregon will have about 3.9 million light duty vehicles, but only about 120,000 of them (total) will be electric vehicles.  That’s just 3 percent of the fleet; 97 percent will still be internal combustion engines.  The slow adoption of electric vehicles, as depicted in ODOT’s official revenue forecasts, means the agency believes that its efforts to promote EVs won’t have a significant effect on the state’s greenhouse gas emissions any time in the next decade, at least.

    5. State forecasts of future vehicle emissions have been proven wrong.  A critical part of any transportation greenhouse gas emission strategy is assumptions about the improvements in the cleanliness of future vehicles.

    Metro’s climate planning is based, in part, on rules adopted by the State Land Conservation and Development Commission (LCDC) directing metropolitan planning organizations around the state to work toward complying with the state’s adopted greenhouse gas emission goals.

    In 2017, LCDC produced a report detailing its analysis of how these planning organizations were to plan for reducing transportation-related greenhouse gas emissions.  As directed by the Legislature, the planning process was to give local planners guidelines on the proportion of reduction in greenhouse gasses that could be expected from changes in vehicle efficiency and electrification.

    LCDC based its rules on emission reduction assumptions taken from the Oregon Department of Transportation’s 2012 State Transportation Strategy (STS).  LCDC constituted a technical committee and retained Brian Gregor (formerly of ODOT) to prepare a technical analysis, drawing on the STS to estimate how much reduction in greenhouse gasses could be expected from improving technology and changing vehicle mix.  Gregor’s analysis predicted that vehicles would become dramatically cleaner over the next several decades, with a reduction in greenhouse gasses per mile traveled of more than 80 percent by 2050.  Gregor’s analysis concluded that LCDC should assume that emissions per vehicle mile would decline by 67 percent by 2035, the terminal year for local land use plans.  Importantly, LCDC wrote Gregor’s assumptions about future vehicle emissions into its administrative rules (OAR 660-044-0020).

    Gregor’s analysis assumed that average vehicle emissions would decline to about 90 grams per mile by 2050.  Gregor reached these conclusions by assuming that fuel efficiency and zero emission vehicle regulations would steadily improve new vehicle emissions, and that over time, these would change overall fleet emissions. The report assumed that average vehicle age would be 11 years, and that  average fleet vehicle economy in any year would be equal to the average new car fuel economy for vehicles sold 11 years earlier.  Gregor’s calculations imply a base level of emissions of about 520 grams per mile in 2005.  New cars would be assumed to achieve 100 grams per mile in 2035, and the fleet as a whole would achieve 100 grams per mile in 2046, and about 90 grams per mile by 2050. Gregor summarized his assumptions in this chart:

    As Gregor writes:

    Average vehicle emissions rates would need to decline by a little over 4% per year from the 2010 estimated average in order to achieve the recommended level in 2050.

    It is now 2021, and we have roughly a decade of data on the actual rate of improvement in new vehicle emission rates.  According to the Environmental Protection Agency, average emissions for new light vehicles have fallen from about 450 grams per mile in 2005 to about 348 grams per mile in 2021.  By Gregor’s approach, at that rate of improvement, average fleet efficiency in 2032 (eleven years from now) will be about 348 grams per mile.  In the past decade (2010 through 2021), the number of grams per mile has declined at about a 1.1 percent annual rate.  This is roughly only one-fourth the rate of improvement assumed in Gregor’s calculation and LCDCs target rules.

    The following chart shows the difference between Gregor’s estimate of the path of vehicle emissions (blue), and the actual improvement in emissions between 2010 and 2021 (green).  The red dashed line shows the trend in vehicle emissions based on the 2010 to 2021 growth rate of -1.1 percent per year extended through 2050.

    At current rates of improvement, per mile emissions are likely to be almost three times higher in 2050 than forecast in Gregor’s model, i.e. almost 300 grams per mile, rather than less than 100 grams per mile.

    Achieving a reduction in greenhouse gas emissions is driven by the combination of cleaner vehicles and less driving.  If vehicles become cleaner at a slower rate, then bigger decreases in driving (VMT/capita) are needed to achieve state goals. Gregor creates an equation showing how these factors determine the expected reduction in emissions.

    Gregor estimates that we need to reduce per capita emissions to 28 percent of base levels (i.e a 72 percent reduction).  He assumes that cleaner vehicles will do the lion’s share of this work.  His assumed 66 percent reduction in the rate of emissions per mile, means miles per capita need to be reduced about 20 percent.

    The much lower rate of improvement in cleaning up vehicle emissions that we’ve actually experienced means that proportionately more of the task of reducing greenhouse gasses will need to be met, per Gregor’s own methodology, by reducing vehicle miles of travel. At the current rate of improvement of vehicle emission reduction, in 2035, the average vehicle will still emit about 336 grams per mile, just a 25 percent reduction from base levels.  In order to meet the state’s target of reducing per capita emissions to 28 percent of base levels by 2035, that means per capita vehicle miles of travel need to fall by 66 percent.  (The following table uses Gregor’s Equation 2 to compute the needed “target” level of VMT reductions consistent with various rates of improvement in vehicle emissions).

    As show in the final line of the table, even if the annual rate of improvement doubles from its current rate to 2 percent per year from now through 2035, we would have to reduce vehicle miles traveled per capita by more than 50 percent.

    In effect, the dramatic shortfall between Gregor’s 2016 report, and the actual 1.1 percent improvement in GHG/mile is the combined effect of the factors described in this section (a heavier, truck and SUV oriented fleet, slow improvements in fuel efficiency, slower vehicle turnover and slow electric vehicle adoption.

    LCDC and ODOT have failed to re-examine their policies in light of forecast errors

    It is difficult and uncertain to make reliable and accurate projections about the future.  That is why analysts typically couch their predictions in terms of the assumptions made to produce them, and why policies and reports relying on such forecasts frequently promise to revise their estimates as more and better information becomes available.

    It’s important to note that Gregor’s predictions are based only partially on current law or policy, and rely heavily on assumptions that federal and state governments will devise, adopt, implement and enforce a whole series of new and more stringent policies to reduce vehicle emissions.  Gregor’s report made it clear that assumptions about improving vehicle economy were based on optimistic speculation about future federal and state policy.

    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 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 LCDC report relying on Gregor’s estimates implicitly acknowledges the need to update these forecasts as better information becomes available.  The LCDC goals were developed over several years from 2011 through 2016; The final rules were revised from earlier drafts explicitly because of the availability of additional information on vehicles and vehicle emission rates.  LCDC elected to tie its estimates of vehicle emission rates to those in ODOT’s STS for consistency with state efforts, and so that as the STS was updated, so too would be expectations about local targets.

    If the STS is adjusted to account for changing assumptions to vehicles, fuels, and technology, the targets can be similarly adjusted to compensate for the updated assumptions.  (page 9).  [Emphasis added].

    However, while the responsible state agencies (ODOT and LCDC) acknowledged the need to change targets as new information became available when targets and the STS were first prepared a decade ago (in 2011 and 2012), they’ve done little since to respond to new information.  ODOT prepared its first STS Monitoring Report in 2018 and found that progress on fleet, fuels and vehicle technology was much less than what it had forecast in the STS in 2012, and as a result that the state was way behind in meeting emissions goals.  Since that finding ODOT has done nothing to either revise its estimates of future vehicle emissions rates to reflect this new information or, more importantly, identify actions needed to get the state back on track.  Instead, ODOTs Monitoring Report obliquely concludes that unspecified state policy-makers will need to decide what to do next.     

    LCDC’s decision to tie its targets to the STS—a decision which at least promotes consistency—means that ODOT’s failure to update the STS means LCDC policy remains based on outdated, inaccurate estimates until ODOT chooses to update the forecasts in the STS—something not on ODOTs schedule, despite Governor Brown’s Executive Order which directs the agency to do everything in its power to implement the STS.  LCDC has also failed to follow its own administrative rules which require it to re-appraise the validity of the emissions assumptions on which the rules were predicated:


    Review and Evaluation of Greenhouse Gas Reduction Targets

    (1) The commission shall by June 1, 2021, and at four year intervals thereafter, conduct a review of the greenhouse gas emissions reduction targets in OAR 660-044-0020 and 660-044-0025.

    (2) The review by the commission shall evaluate whether revisions to the targets established in this division are warranted considering the following factors: . . . 

    (e) Additional studies or analysis conducted by the Oregon Department of Transportation, the Department of Environmental Quality, the Oregon Department of Energy or other agencies regarding greenhouse gas emissions from light vehicle travel, including but not limited to changes to vehicle technologies, fuels and the vehicle fleet; [Emphasis added].

    ODOT’s own STS monitoring report concedes that vehicle technologies, fuels and the composition of the vehicle fleet are not changing as anticipated in the STS, making the assumptions underlying LCDC’s rules invalid.  LCDC (and ODOT) have both ignored data from “other agencies”—in this case, the US Department of Energy, sponsor and publisher of the DARTE transportation greenhouse gas database—showing that Oregon greenhouse gas emissions have increased, rather than decreasing, as called for in both agency’s plans, and state statute.


    Why the proposed $5 billion I-5 bridge is a climate disaster

    The plan to spend $5 billion widening the I-5 Bridge Over the Columbia River would produce 100,000 additional metric tons of greenhouse gases per year, according to the induced travel calculator

    Metro’s 2020 transportation package would have cut greenhouse gases by 5,200 tons per year– 20 times less than the additional greenhouse gases created by freeway widening.

    Widening freeways induces additional travel. It’s an established scientific fact:  widening urban freeways prompts more miles of travel and consequently, more greenhouse gas emissions.  The effect is so well-documented that its referred to as the “fundamental law of road congestion.”

    Based on a synthesis of the latest award-winning peer-reviewed scientific research and work by scholars at the University of California, Davis‘s National Transportation Center, the Natural Resources Defense Council developed the induced travel calculator that computes the additional amount of greenhouse gases produced by an additional lane-mile of freeway capacity in each of the nation’s metro areas.

    The proposed Columbia River Crossing, now re-branded as the “I-5 bridge replacement project”, contemplates a 12-lane wide, 5 mile long freeway between Portland and Vancouver, effectively doubling the size of the existing I-5 freeway and adding 30 lane miles of freeway (3 lanes in each of 2 directions for 5 miles).  Freeway advocates have claimed that the bridge might only be 10 lanes, but as public records requests revealed, the bridge structure is designed to carry twelve lanes, and in many places the proposed roadway is 14 lanes wide.

    The Induced Travel Calculator shows that this increase in roadway capacity in Portland would produce an addition 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 gases of about 100,000 tons (at roughly 20 pounds of CO2e per gallon of gas).

    How big is that amount?  Well, to put in perspective, let’s compare it to the expected greenhouse gas reductions from other possible transportation investments.  In 2020, Metro advances a multi-billion dollar transportation spending project including light rail, bus lanes, pedestrian and safety improvements and other projects.  Metro estimated that this package of investments would reduce greenhouse gases by about 5,200 metric tons per year.

    State, regional and local government officials all recognize that we’re in the midst of a climate crisis.  It should be apparent to any casual observer that widening freeways takes us in the opposite direction of our stated commitments to reduce greenhouse gases.  In fact, the best scientific estimates of the emissions from added freeway capacity suggests that widening I-5 would generate 20 times more greenhouse gas emissions than would have been saved by the multi-billion dollar package of projects proposed by Metro last year.  Given the cost and difficulty of reducing greenhouse gas emissions, the last thing we should be doing is making the problem worse.

    Drive-thrus are ruining cities and helping kill the planet

    Your 12 ounce latte comes with a pound of carbon emissions, just from the drive-thru.

    How convenience for cars makes cities less livable for everyone, and contributes to climate change.

    Last week, twitter user Maris Zivarts posted this telling image of 20 car queue wrapping around the block of a Starbucks, all lined up to go through the store’s drive-thru.  It shows how the store’s driveway and parking lot taking up vastly more space than the store itself, and how the backup from the drive-thru window spills out onto adjacent streets, creating congestion and a safety hazard for others.

    As Zivarts observes, 20 people showing up at a coffee shop on foot, by bike or transit is no problem.  The same 20 headed for the drive-thru window is a disaster.  It’s clearly a blight on the neighborhood as well.

    And more than that, it’s bad for the environment.  Those cars idling while they wait in line are burning gasoline and creating pollution, including greenhouse gases.  How much, you might ask?  Well, we’ve studied queueing and service at coffee shops before (to create our Cappuccino Congestion Index), so we have a pretty good handle on this.  We would estimate that the average wait would an average of and ten minutes to handle all the cars in a queue like this.  (This assumes that the store can produce an order about every 30 seconds).

    The US Department of Energy tells us that a typical large US car burns about a third of a gallon per hour at idle.  A gallon of gas produces about 20 pounds of carbon when burned.  So that means that in ten minutes of idling would produce about a pound of carbon (10/60 * 20 * .33 = 1.1).  So, in addition to their twelve-ounce latte, each customer is producing another 16 ounces or so of carbon to be added to the global total, just from the time spent idling in their car, waiting to be served their coffee.   And, of course, this doesn’t count any of the emissions from driving to and from the coffee shop to get served, which by the same math works out to about another pound per mile.

    Oregon’s economic success: The triumph of the city

    After decades of lagging the nation, Oregon’s income now exceeds the national average.

    While some seem to think its a mystery:  It’s not.  It all about a flourishing Portland economy, especially in the central city of the region

    This success has been powered by an influx of talent, especially well-educated young adults drawn to close-in urban neighborhoods

    Income growth in Multnomah County accounts for essentially all of the net improvement in Oregon incomes relative to the nation over the past decade or more

    Rising incomes, especially in the city, have markedly reduced racial and ethnic income gaps

    The secrets of economic success:  talent, quality of life, urban amenities, and knowledge industry clusters.  This urban-powered success should bury old-school myths about business climate.

    A new story in the Oregonian notes that the state’s median household income has surpassed the national average, something it treats as a kind of esoteric statistical mystery, one that has economists, in its words, “flummoxed.”  As someone who’s followed this metric for decades, and analyzed Oregon’s economic growth, it’s really no mystery at all.  Oregon’s recent surge in median income is the product of a strong Portland economy, one that’s been transformed and powered by its ability to attract talent.  It’s been a long time in the making.

    Median household income is a key indicator of economic progress.  Here’s a half century long picture of how Oregon’s income has tracked relative to the nation.  Nearly all that time, Oregon has lagged.  During the 1980s, Oregon was particularly hard hit.  Since then, Oregon’s changes have tracked national trends, but through about 2012, income was always somewhat below the national median.  But in the last couple of years, Oregon’s income growth has surged and now surpassed the national median.  (The following chart, courtesy of Oregon economist Josh Lehner,  is in inflation-adjusted dollars).

    Oregon’s strong trend is borne out by other indicators. Another data series, the Current Population Survey (CPS), which has a much smaller sample and somewhat different approach than the ACS suggests that Oregon’s median income is outpacing the national average by an even larger margin.  State labor economist Will Burchard wrote that the latest figures show that Oregon’s median household income reached $76,554 in 2019, which is higher than the U.S. median household income of $67,521.

    Portland powered the state’s economic gain

    The Oregonian article makes it sound like the state’s improving incomes are a kind of mystery. But there’s no mystery here.  The first bit of evidence comes from looking at where Oregon incomes surged over the past couple of decades.  Oregon’s economy is big and diverse, and different parts of the state have fared differently.  When we look closely at the county-level data it’s apparent that the income surge is centered in Portland, not just in the Portland area, but in the City of Portland (which is largely coterminous with Multnomah County).  Between 2010 and 2019 median household income (in current dollars) rose 39 percent in Multnomah County, compared to 29 percent in the remainder of the metropolitan area (the suburban counties of Clackamas, Columbia, Washington and Yamhill), and just 23 percent in the remainder of the state.

    This is an urban success story.  In a statistical sense, Multnomah County’s income growth explains nearly all of the degree to which Oregon incomes now outpace the nation.  Excluding the effect of increasing median incomes in Multnomah County, statewide incomes median incomes would have risen about 3 percentage points less—enough to keep statewide median income growth from exceeding the national average.

    In a way, this isn’t new news at all, even for the Oregonian.  State labor economist Christian Kaylor highlighted Portland’s exceptional growth a couple of years ago, as reported in . . . The Oregonian.

    Talent drove Portland’s growth:  The Young and Restless

    It’s become increasingly clear in the past two decades that a well-educated population, what economists call “human capital,” is a decisive factor in economic development. It’s no secret that cities that do a great job of educating their populations, and which attract well-educated people from elsewhere do better economically.  That’s more the case with each passing year.

    As we’ve documented at City Observatory for years, smart young people have been moving to cities, and Portland has been one of the leading destinations for well-educated 25- to 34-year-olds.  Since the 1990s, Portland has outpaced the nation in attracting these young adults, and their arrival numbers have continued to grow. As we documented in our 2004 report, and in subsequent follow up reports on the Young and Restless, Portland has been a national leader in attracting well-educated young adults and they’ve settled disproportionately in the city’s close-in neighborhoods.  And after two or three decades of steady influx of young talent, this group, as it has matured into its prime working age years, has transformed the economic performance of the city.  Again, Portland’s key role in powering the state strong economic performance puts the lie to the old Portlandia joke that Portland was a place that young people went to retire (we debunked that at the time:  Portland has above average rates of employment and entrepreneurship among young adults). This steady influx of well-educated workers measurably increased the city’s educational attainment, making it one of the best educated large cities in the country.  A better educated population fueled income growth, something that is now clearly bearing fruit in the economic statistics.

    When we look across Oregon, there’s more evidence for this talent/income nexus in the county level income statistics.  The Oregon counties that chalked up the big gains in median household income were the counties with the highest levels of educational attainment.  The following chart shows the fraction of the adult population with a four-year degree in each county and the percentage increase in median household income in that county over the past decade.  There’s a strong positive relationship between education and income growth.

    On this chart, each dot represents an Oregon county.  As the regression line shows, counties with higher levels of educational attainment had faster rates of median income growth over the last decade than counties with relatively low levels of education.  Keep in mind, there’s always been a strong relationship between education and income; better educated counties have always had higher incomes.  What this data shows is that those better educated counties are increasing income even faster:  they’re pulling away.  It’s a core fact of a knowledge-driven global economy.

    Oregon’s economic growth has promoted equity as well.

    Any time we take rising incomes as a measure of economic success, it’s worth asking whether prosperity is widely shared.  The Oregon numbers show a further remarkable success story.  During the past several years, there’s been a dramatic reduction in the economic gap between White residents and people of color in Oregon.  Economist Josh Lehner used data from the American Community Survey to show the trend in poverty rates for persons of color compared to white Oregonians.

    Despite the modest claim in the chart’s title “poverty gap remains large, but is narrowing,” this represents prodigious progress in just a few years.  In 2009, poverty rates for persons of color in Oregon were effectively double those for non-Hispanic white Oregonians.  After several years of sharp and steady declines, BIPOC poverty rates fell by ten percentage points, from over 25 percent to 15 percent, and so were now only about four or five percentage points higher than for whites.  And this is after four-decades win which there was no perceptible narrowing of these racial-ethnic differences.  It’s an indication of how tighter labor markets can play a key role in providing more opportunities for those who’ve long been marginalized.  These gains for people of color also strongly correlate with the robust growth of the Portland/Multnomah County economy.  Portland and Multnomah County are much more racially and ethnically diverse than the rest of the state, so a strong city economy translates into more local opportunity for people of color.

    What this tells us about how to succeed at economic development

    For someone who’s labored for decades in the vineyard of economic development, there’s one key indicator we pay attention to when summarizing a state or region’s economic success:  its level of income relative to the national average.  One of the best metrics is median family income, which effectively reveals how a typical household in the middle of the income distribution is faring relative to the nation.

    For most of the past six decades, by this measure, Oregon’s economic performance has lagged that of the nation.  Our friend and mentor, the late Ed Whitelaw trenchantly pointed out that just looking at money income ignored the substantial “second paycheck” Oregonians earned from the state’s abundant and increasingly valuable natural amenities.  To that second paycheck, Oregonians can add another factor ignored in most conventional statistical comparisons:  the very sizable green dividend that Oregonians earn, largely because the state’s more compact development patterns (thanks to land use planning) mean that residents drive fewer miles than people in other more sprawling states, saving them a bundle on the cost of cars and gasoline.  Portland’s income is about $1 billion per year higher because of these savings.

    Back in the 1980s, as the chief economic analyst for the Oregon Legislature, I documented the state’s lagging income levels in a series of detailed statistical reports: Losing Ground: The Growing Gap Between Oregon and National Income.   These reports showed that for a variety of reasons (the structural decline of the timber industry, the state’s disconnect from the Reagan era defense build-up, and other factors), that Oregon’s economy lagged the nation, and showed up in most prominently in a big decline in average incomes relative to the rest of the nation.  It was clear then that raising the state’s educational attainment, promoting innovation and building world-class knowledge industry clusters was the key to raising our income.  And over the past twenty years, led by the Portland economy, Oregon has transformed into a better educated, more innovative and more productive state, something that has been largely propelled and supported by investments in quality of life that have attracted and retained talent.

    That success flies in the face of old school myths about the importance of business climate to economic success.  Portland’s strong showing, in particular, belies the bad-mouthing the city got during the last recession and disproves some outdated economic development nostrums.  Take, for example, the cynical doom-saying by the Portland Business Alliance, the city’s chamber of commerce, which in 2010 grimly intoned that Multnomah County ranked 198th of 199  Western counties and metro areas in job growth, attributing the problem to a bad business climate and a failure to attract large corporations.  It fretted that a continuing long-term decline in Multnomah County’s economic health would drag down the region and the state:

    The Portland-metro region faces a crisis. If unstopped, the loss of jobs in Multnomah County and the stagnant-to-declining wages and incomes across the region will erode our quality of life, not just in Portland-metro, but across Oregon because of the region’s key role in the overall state economy.

    These worries were echoed by pundits claiming that Oregon  somehow had an anti-business attitude, was over-taxed and over-regulated, or somehow lacked enough roads or industrial sites to accommodate growth. Far from dragging the region or the state down, Multnomah County’s ability to attract talent propelled the state’s economic success. The region’s strong performance also over the past decade also debunks other myths, like the notion that ours is a freight-dependent economy.  Portland flourished as never before even though ocean container service disappeared and port activity withered in the middle of the decade.  As the record of the past decade shows, these myths and self-serving claims were exactly backwards.  Far from being dragged down by a stagnant economy in the region’s center, the metro area and the state were propelled by income growth in Portland and Multnomah County.  Without the center’s strong showing, statewide growth would have been no better than the national average.

    In the end, economic success in the 21st century is no mystery, nor is Portland’s recent surge.  Economic development is a long term proposition, not amenable to quick and easy fixes.  It’s fundamentally about having a well-educated populace and and environment conducive to innovation.  It’s about having the amenities (urban and natural) that knowledge workers find attractive.  It’s about building clusters of dynamic, innovative industries that draw on these resources, and enhance them further. That’s what Portland has done, and its success is powering the state’s impressive income gains.

    Technical notes

    The key metric we’re tracking here is median household income, the income of the household in the middle of the income distribution for a county, state or the nation.  Half of all households have income above the median, half have incomes below.  The median is a useful statistic for very simply describing the distribution of income.  But using it to compare different geographies (counties and states) over time is challenging.  Medians are influenced by composition effects.  In our case, because some higher income counties are adding households faster than lower income households over the past decade, the growth of the statewide median is greater than the average of the county medians.

    For simple comparative purposes, we’ve computed the household-weighted statewide median income (weighting each counties median income by the number of households in that county).  Because we use weights that are based on the number of households in the 2019 ACS, this metric ignores the shifting composition of the state’s population and focuses on the changes in incomes across counties.  We compute that the household-weighted median income for Oregon counties in 2010 and 2019 including and (counterfactually) excluding, Multnomah County. Without the growth in incomes recorded in Multnomah County, statewide median income growth would have been about 3 percentage points less than it actually was over the decade, which would have been enough to erase the gains that enabled statewide income to exceed the national average for the first time.




    Let’s stop whining about gas prices: Gasoline is cheap, too cheap.

    Gas prices are going up, and it’s annoying to have to pay more, but let’s take a closer look at how much we’re paying for gas.

    Even with a recent uptick, gas prices are still lower than they were a decade ago.

    Cheap gas is burning the planet, and undercuts all of our efforts to lower greenhouse gas emissions.

    After decades of disinflation or deflation, the US economy, in the wake of an dramatic effort to bounce back from the pandemic, is experiencing a surge of inflation.  The media love to point at rising prices at the pump.  Gas was going for around two bucks a gallon in the early days of the pandemic, and nationally has just broken through $3/gallon.

    Everyone likes to complain about gas prices, but gasoline in the US is cheap. It’s cheap in historical terms, as the chart below shows: In inflation-adjusted terms, gasoline is cheaper now than it was a decade ago, and is well below its historic peak of more than $5 per gallon (in 2021 dollars).  From 2011 through 2014, the price of gallon of gas (in today’s money) was regularly north of $4.

    The price of gasoline fell precipitously after 2014, leading to a dramatic reversal in all of the trends that were helping ameliorate the climate crisis.  Public transit ridership, which had been rising, fell.  The average American, who had been driving less each year after 2004, suddenly started driving more.  The share of new vehicles that were heavier, less fuel efficient light trucks went from less than half to almost 75 percent.  The big increase in driving after gas prices fell in 2014 is directly connected to a surge in transportation-related greenhouse gas emissions.  In Portland, for example, greenhouse gases per person increased by 1,000 pounds per year over the past few years.  Propelled by cheap gas, and combined with larger vehicles, there was a huge increase in crash fatalities and injuries.

    Gasoline is cheap in the US compared to other countries.  In Italy, France, Germany, Denmark, the Netherlands and the UK, gas prices are roughly $2 per liter, compared to less than $1 per liter in the US.  These higher fuel prices prompt people and businesses to make different decisions: people drive more efficient vehicles, drive fewer miles, and kill and maim fewer of their brothers and sisters in crashes.  Cheap gas is a principal reason for America’s excessive greenhouse gas emissions and epidemic of traffic violence.

    Higher priced gasoline prompts businesses and consumers to make choices and investment decisions that lower our fossil fuel emissions.  Higher gas prices make electric vehicles more competitive, and prompt people to buy more fuel-efficient vehicles.  Higher gas prices also discourage long commutes and make transit more attractive.  The evidence from places like Amsterdam and Copenhagen, where cycling works well for a large fraction of the population is that it isn’t just about bike lanes; high prices for gasoline and high taxes on fossil fuel vehicles provide strong incentives for more efficient travel.  It’s perfectly possible to have a prosperous productive economy and a high standard of living with gas prices that actually come close to asking users to pay something approaching the cost of their decisions.

    The Bipartisan Infrastructure Bill just doubles down on continuing subsidies to driving.  It’s got a huge bailout of the Highway Trust Fund (which has roughly $100 billion in general funds since 2000), and these a $118 billion general fund bailout as part of the bill, plus a huge tranche of new money that will keep drivers from facing the true cost of building and maintaining roads and bridges, not to mention paying for environmental and health damage.

    Not surprisingly, once conditioned to depend on cheap gasoline, people express dismay at the higher prices.  But getting gasoline prices to more accurately reflect the social, environmental and personal health damage associated with automobiles is essential.

    The real macroeconomic concern about inflation is that somehow we end up in an accelerating spiral. Insulating Americans from the true cost that their gasoline purchases impose on other Americans, the rest of the world and the environment isn’t saving anyone in the long run.  We’ll end up paying for cheap gasoline in higher costs of figuring out how to reduce greenhouse gases in even more expensive, less efficient ways, and in paying more to deal with the damage caused by climate change.

    How to solve traffic congestion: A miracle in Louisville?

    Louisville charges a cheap $1 to $2 toll for people driving across the Ohio River on I-65.  

    After doubling the size of the I-65 bridges from six lanes to 12, tolls slashed traffic by half, from about 130,000 cars per day to fewer than 65,000.

    Kentucky and Indiana wasted a billion dollars on highway capacity that people don’t use or value.

    If asked to pay for even a fraction of the cost of providing a road, half of all road users say, “No thanks, I’ll go somewhere else” or not take the trip at all.

    The fact that highway engineers aren’t celebrating and copying tolling as a proven means to reduce congestion shows they actually don’t give a damn about congestion, but simply want more money to build things.

    Picture this.  A major interstate freeway that connects the downtown of one of the nation’s 50 largest metro areas to its largest suburbs.  It’s a little after 5 pm on a typical weekday.  And on this 12-lane freeway there are roughly two dozen cars sprinkled across acres of concrete.

    I-65 in Southern Indiana (Trimarc)


    I-65 crossing the Ohio River at Louisville (Trimarc)

    These pictures were taken by traffic cameras pointed in opposite directions on the I-65 bridges across the Ohio River at Louisville Kentucky on Wednesday, November 3 at about 5:30 pm.  Traffic engineers have a term for this amount of traffic:  They call it “Level of Service A”—meaning that there’s so little traffic on a roadway that drivers can go pretty much as fast as they want.  Highway engineers grade traffic on a scale from LOS A (free flowing almost empty) to LOS F (bumper to bumper stop and go).  Most of the time, they’re happy to have roads manage LOS “D”.

    Somebody finally figured out how to reduce traffic congestion!  Usually, as we know, simply widening highways, to as many as 23 lanes as is the case with Houston’s Katy Freeway, simply generates more traffic and even longer delays and travel times.  And, with no sense of irony, highway boosters even tout the Katy Freeway as a “success story,”  despite the fact it made traffic congestion worse. In contrast, Louisville’s I-65  is an extraordinarily rare case where traffic congestion went away after a state highway department did something.

    You’d think that the Kentucky Transportation Cabinet and the Indiana Department of Transportation would be getting a special award, and holding seminars at AASHTO to explain how to eliminate traffic congestion.  The fact that they aren’t tells you all you need to know about the real priorities of state highway departments–they really only care about building things, not about whether congestion goes away or not.

    So how did they do it?  Let’s go back a few years.  In 2010, I-65 consisted of a single six-lane bridge over the Ohio River, which carried about 120,000 vehicles per day.  The two states decided this was getting too crowded (and predicted worsening delay due to ever expanding traffic volumes) and so spent about $1 billion building a second six lane bridge (the Lincoln) next to the existing Kennedy bridge.  After in opened in 2017, the two states implemented a toll to pay part of the cost of construction.  Tolls started at $2 for single crossings (if you had a transponder), but regular commuters were given a discounted toll: regular commuters pay just a bit over $1 for each crossing.  Today the toll for one-way crossings if you have a transponder (and 450,000 area vehicles do), is $2.21.  But if you cross the bridge 40 times a month (back and forth daily for 20 work days), your toll for each trip is reduced by half to $1.10.

    And after the tolls went into effect, traffic on I-65 fell by half.  Here’s the average daily traffic count on I-65, according to data tabulated by the Indiana Department of Transportation.  In the years just prior to the tolling, traffic was in the 135,000 to 140,000 vehicles per day level.  But as soon as tolling went into effect, traffic dropped to barely 60,000 vehicles per day (with a very slight further decline due to Covid-19 in 2020).


    The two states spent a billion dollars doubling the size of I-65, only to have half as many people use the bridge.  That money was wasted.  Nothing more clearly illustrates the utter folly of highway expansions.  As we’ve pointed out, highway engineers size roadways based on the assumption that the users will pay nothing for each trip.  Just as with Ben and Jerry’s “Free Ice Cream Day,” when you charge a zero price for your product, people will line up around the block.  But ask people to pay, and you’ll get fewer takers.

    The fact that Louisville residents would rather drive miles out of their way or sit in traffic for an extra 10 or 15 minutes to travel on a “free” road, rather than spend a dollar or two for a faster, more direct trip tells you the very low value that highway users attach to these extremely expensive roadways.  In fact, they’ll only drive on them if somebody else pays for the cost the roadway.   This is also powerful evidence of what economists call induced demand:  people only taking trips because the roadway exists and someone else is paying for it.

    The Louisville traffic experiment shows us that there’s one surefire fix for traffic congestion:  road pricing.  Even a very modest toll (one that asks road users to pay only a third or so, at most of the costs of the roads they’re using) will cause traffic congestion to disappear.  This traffic experiment shows the folly and waste of building additional capacity.  Kentucky and Indiana spent over $1 billion for a bridge to carry as many as 250,000 vehicles per day, and today barely a quarter of that number are using it.

    If state DOTs really cared about congestion, they’d be implementing congestion pricing.  A small toll, probably less than a dollar per crossing, would be sufficient to get regular free-flow conditions on the I-65 bridge—without having to spend a billion dollars.  But the truth is, state DOTs don’t care about congestion, except as a talking point to get money to build giant projects. The next time you hear someone lamenting traffic congestion, ask them why they aren’t trying the one method that’s been shown to work.




    Louisville’s financial disaster: Deep in debt for road capacity that will never be used

    Louisville’s I-65 bridges:  A huge under-used roadway and hundreds of millions in debt for their kids—who will also have to cope with a climate crisis.

    Their financial plan kicked the can down the road, saddling future generations with the cost of paying for unneeded roads.

    The two states mortgaged future federal grant money and borrowed against toll revenues, which are falling dramatically short of projections.

    Louisville’s Ohio River Bridges are a monument to the epic policy, financial and generational failure that is the US highway system.  Ohio and Indiana spent more than a billion dollars on doubling an interstate highway bridge, that thanks to very modest tolls, is utilized at less one-fourth of its capacity.  Meanwhile, through a series of “creative” financial maneuvers, it passed the bill for the highway onto future generations, who, as it turns out will have to actually pay for the bridge at the same time the climate crisis hits in full force.  The almost empty freeway bridges show the folly of “asphalt socialism”—wasting vast amount of public resources on roads that their users don’t value enough to pay even a fraction of their cost.

    Earlier, we wrote about one aspect of the I-65 bridge project in Louisville.  It turns out that just by charging a $1 to $2 toll, Kentucky and Indiana were able to entirely eliminate traffic congestion on I-65.  Traffic plummeted from around 130,000 vehicles per day to about 60,000.  Now, even at the rush hour, I-65 is almost empty.


    I-65 crossing the Ohio River at Louisville


    And after the tolls went into effect, traffic on I-65 fell by half.  Here’s the average daily traffic count on I-65, according to data tabulated by the Indiana Department of Transportation.  In the years just prior to the tolling, traffic was in the 135,000 to 140,000 vehicles per day level.  But as soon as tolling went into effect, traffic dropped to barely 60,000 vehicles per day (with a very slight further decline due to Covid-19 in 2020).


    While there’s a hopeful lesson here—one that highway engineers are studiously avoiding—that road pricing can eliminate congestion, there’s a financial horror story that should be a warning to everyone thinking about highway expansion projects.  The two states spent over a billion dollars on doubling bridge capacity in downtown Louisville, and their financial plans show how through combination of cynicism, incompetence or saddled future generations with the cost of this boondoggle.

    Ostensibly, the justification for widening the bridges was the notion that traffic was already too congested and was growing rapidly.  The project’s environmental impact statement claimed that the I-65 bridges were “over capacity” in 2012, and predicted that traffic would grow from 120,000 vehicles per day to more than 180,000 by 2025, leading to hours and hours of traffic delay.

    The trouble with these forecasts is that they were both simple-minded and wrong, especially given the need to pay for this project—in part—by actually charging the users for a portion of its construction cost.  Like so many state highway department predictions, this one was flat out wrong—traffic was nearly flat-lining on I-65 before the project was built.

    State DOT traffic forecasts were wrong

    Surely, you must be thinking, the state DOTs knew that charging a toll would reduce traffic.  Before the project was completed, Kentucky and Indiana hired consultants—CDM Smith and Steer, Gleaves, Davie—to estimate future toll revenues from the project.  CDM Smith predicted that future traffic levels on newly expanded and tolled I-65 bridges would be 92,000 vehicles per day in 2020, growing to 102,600 in 2030..  That was a dramatic over-estimate.  Actual traffic levels in 2019 (i.e. the year prior to the pandemic) were just 62,000 vehicles per day.  Whereas CDM Smith predicted that tolling would produce about a 27 percent decline in traffic from pre-tolling levels, the imposition of tolls actually led to a 50 percent decline in traffic.  CDM Smith overestimated the amount of toll-paying traffic that would cross the I-65 bridge by 50 percent.  The direction and magnitude of that error is all too common in toll traffic forecasts, and has led to defaults and bankruptcies for other tolled projects.

    Creative Finance:  Sending the bills to future generations.

    Tolls are only paying for a small fraction of the costs of the project.  Both states borrowed substantial sums. Kentucky borrowed deeply to pay for its share of the project, using “Garvee” bonds—essentially mortgaging future federal grant money—to the tune of $300 million in principal repayment and $138 million in interest payments.  In addition, Kentucky’s tolls are pledged to pay of both Kentucky revenue bonds of $272 million and a Federal TIFIA loan of $452 million.  The debt service for these two borrowings is back-loaded, i.e. is very low in the first few years of the project, but then steadily escalates.

    This back-loading means the financial plan for the I-65 bridges project essentially sends the bill to the region’s future residents.  Essentially, Kentucky has borrowed most of the money to construction the project and arranged for a loan with a series of “balloon payments,” in later years.  Kentucky “back-loaded” the repayment of principal on both its own revenue bonds and its borrowings from the federal government’s TIFIA program.  It pays interest-only or just a token amount of the principal for these loans in the first few years, and then required payments steadily escalate in later years.  Debt-service obligations start at less than $10 million per year, and then balloon to more than $80 million annually in the early 2020s.

    In theory, the escalating repayment can be met by growing toll revenues, from some combination of toll rate increases and growing traffic.  Toll rates have increased steadily at 2.5 percent per year, but as the traffic counts show, volume has flat-lined.  The artificially low repayments in the first few years of the project create the illusion that toll revenues are sufficient to cover debt service payments, but as required payments steadily escalate over the next few years, the Kentucky will find it increasingly difficult to meet its repayment obligations.

    This looming mountain of debt service obligations has already prompted Kentucky to refinance part of its debt, essentially kicking the can further down the road for repayment of the cost of the I-65 bridges.  The refinancing plan essentially doubles down on earlier back-loading strategy, borrowing more money now to make these payments, and extending the period for repayment further.  Instead of paying off its “first tier revenue bonds” in 2045, they’re extending the term of the repayment by 8 years, to 2053.  And like the initial borrowing, these refunding bonds are mostly “interest-only” for the next 25 years, with nearly all of the principal being repaid after 2045.  As a result, the borrowers will pay almost as much in interest charges ($182 million over the life of the loan) as they pay in principal ($192 million).

    Traffic on I-65 will never get back to pre-tolling levels

    Whether toll revenues will be sufficient to repay these bonds hinges on whether you believe the latest forecast from Kentucky’s consultant, Steer & Company, prepared as part of the latest re-financing plan.  This new forecast now predicts  that total annual transactions (the number of vehicles using the project) will increase from about 30 million today to about 48 million by 2053.  What this means is that the I-65 bridges will effectively never recover to the level of traffic they had before the crossing was widened.  Currently, as noted above, the bridges are carrying about 60,000 vehicles per day.  The latest Steer forecast is that traffic will increase from that level by about 60 percent over the next three decades (48 million = 1.6 x 30 million).  This means that in 2053, the bridges will be carrying about 96,000 vehicles (which, ironically, is about the same level that the other toll consultants, CDM Smith predicted for 2020 in the projections that were originally used to justify project financing).  On the following chart, the red line is the FEIS traffic forecast for I-65, the black line is the actual level of traffic according to INDOT, and the blue line is the growth in traffic forecast by Steer & Company for the refinancing plan).


    Comparing these new refinancing estimates with the rosy projections used to justify the project in the first place show the profound gap between highway boosters and reality.  The project was sold based on an environmental impact statement forecast that in the “no action” scenario (with just the single six-lane Kennedy Bridge), traffic on I-65 across the Ohio River would grow to 178,600 vehicles per day, exceeding its “capacity” by 142 percent.  This estimate implies that the capacity of the 6 lane Kennedy Bridge was 125,000 vehicles per day.  (As traffic expert Norm Marshall has shown these “over-capacity” estimates amount to forecasting the impossible, but neatly serve the interests of highway advocates).

    Doubling the size of the I-65 crossing was needed, according to the project’s supplemental EIS in order to assure that the project could carry about 185,000 vehicles per day when completed:

    Specifically, the combination of new bridges in the Downtown and Far East corridors would result in the Kennedy Bridge operating at 74 percent of capacity in 2025.

    With a capacity of 250,000 vehicles per day (double the 6-lane Kennedy Bridge), the 74 percent of capacity implies a forecast level of travel of 185,000 vehicles per day in 2025.  Now, based on the impact of tolling, it’s doubtful that the bridges will ever carry more than a third of their designed capacity, and the much lower level of traffic on I-65 predicted for the 2050s shows that the project was a colossal blunder, wasting a billion dollars.  It’s a blunder that future Louisville area residents will be paying for—for decades to come.




    The opposite of planning: Why Metro should stop I-5 Bridge con

    Portland’s Metro regional government would be committing planning malpractice and enabling lasting fiscal and environmental damage if it goes along with state highway department freeway widening plans

    • The proposed $5 billion, 5-mile long, 12-lane freeway I-5 bridge project is being advanced based on outdated traffic projections using 2005 data.
    • ODOT is pushing freeway plans piecemeal, with no acknowledgement that they are creating new bottlenecks.
    • Freeway plans fail to address climate change and don’t acknowledge that new capacity will produce additional travel and increased greenhouse gases
    • I-5 bridge plans are inconsistent with adopted state, regional and city commitments to use road pricing to manage demand, which would obviate the need for expensive capacity
    • ODOT and WSDOT have not produced a viable financing plan for the project, which would be the region’s most expensive, and which has a $3.4 billion financial hole.

    In theory, Portland has a smart approach to regional planning.  It has a directly elected regional government, with strong planning authority over transportation and land use.  That government claims to care deeply about the climate crisis, and regularly touts the sophistication of its transportation modeling team.  And it says it’s looking at how the whole system works to make Portland a greener more just place.

    But when it comes to the single largest transportation investment in the region, a proposed $5 billion 5-mile long, 12-lane wide freeway project across the Columbia River, it’s simply abdicating its responsibility and betraying its stated principles.

    Next month, the Metro government is being asked to approve $36 million in additional funds for further planning of this massive freeway project.  It should say no.

    Supersize Me: The planned $5 billion widening of I-5 (Courtesy:  Bike Portland)


    This approval is one more brick in the wall of an even larger freeway building plan.  The Oregon Department of Transportation is pushing an entire series of freeway widening efforts, including the $1.2 billion Rose Quarter project, $5 billion for the mis-named “I5 Bridge Program” and billions more for widening I-205 and I-5 at the Boone Bridge in Wilsonville.

    In theory, a regional planning agency would be guided by current, accurate data and scientifically based models.  It would insist on knowing how each project fitted into a larger, long-term vision of how roads and transportation system would work.  It would insist on knowing what a project will cost, how it will be paid for, and who will pay for it.  And if it has committed itself to pricing roadways, it should know how pricing will affect demand before it commits billions on capacity that may not be needed or valued.  And if it is serious about its oft-repeated commitments to tackling climate change, it should insist that its investments actually result in fewer vehicle miles traveled, and less greenhouse gases.

    In practice, Portland Metro has done none of these essential things as it has considered the I-5 Bridge.

    No forecasts. Most fundamentally and technocratically, ODOT has not prepared, and Metro has not reviewed or analyzed current traffic forecasts that show the actual and projected demand for the I-5 bridge. The foundation of any road project is estimates of the future level of traffic the roadway is expected to carry.  Just last week, the staff working on the bridge project admitted that after more than two years of work to revive the failed CRC, they have no new traffic forecasts, and won’t have any for at least another year.  That hasn’t stopped them from claiming that they know just how big the project should be (they say “ten lanes”) and from claiming that other alternatives won’t meet the project’s purpose and need.  (As we’ve noted before, the two DOTs may claim it’s a “ten lane” project, but they’re planning on building a structure that would easily accomodate a dozen freeway lanes).

    The last traffic projections prepared for the I-5 bridge as part of the project’s environmental impact statement date back more than a decade, and are based on data from 2005.

    Ruling out alternatives and deciding on the size and design of a highway project before preparing and carefully vetting traffic forecasts is the opposite of planning.

    No comprehensive look:  building a badder bottleneck for billions.  As noted earlier, the I-5 bridge project is just one of a series of Portland-area freeway widenings.  Metro should be asking what the region, its environment, and its transportation system would look like with and without all these projects.  Instead, it is considering them only piecemeal.

    In effect, this approach amounts to approving the creation of new bottlenecks on the freeway system that will undoubtedly trigger efforts to widen freeways yet again in the future.  The I-5 bridge project would widen I-5 from six to as many as twelve lanes from Vancouver to Victory Boulevard (the project claims its just ten lanes, but in the past it has lied about the actual physical width of the project it plans to build). ODOT is also planning to widen I-5 at the Rose Quarter to as many as ten lanes.  Once these two I-5 projects are complete, a new bottleneck will be formed between them in the three-mile long six-lane wide section of I-5 between the Fremont Bridge and Victory Boulevard, with 12 lanes feeding into six at the north, and 14 lanes (I-5 plus I-405) feeding into this stretch of freeway from the south.  ODOT will then no doubt call for the construction of further “auxiliary” lanes) to carry traffic between exits on this newly bottlenecked segment of I-5.  In essence ODOT is building very large funnels at either end of this six-lane stretch of I-5 North, which will predictably lead to further traffic congestion, more pollution, and additional demands to waste billions of dollars widening roads to accommodate this traffic.

    As Metro staff noted in their comments on the I-5 Rose Quarter project, the Oregon Department of Transportation routinely lies about the fact that it is expanding freeway capacity.  It wrote of ODOT’s claim that it was not expanding I-5:

    This statement is not objectively true and is potentially misleading; auxiliary lanes clearly add capacity.

    Piecemeal reviews that approve segments on an ad hoc basis, and don’t consider the long-term effects of encouraging even more car traffic are the opposite of planning.

    Not following through on fighting climate change.  The original CRC was conceived with no notion of the seriousness of the climate challenge.  The proponents of the new I5 bridge have steadfastly opposed incorporating climate considerations in the project’s purpose and need statement.  It’s clear from their choice of alternatives (every one includes at least ten lanes of freeway), and claims that the inclusion of sidewalks, bike paths and transit as somehow make the project “climate friendly,” that nothing has changed with this new iterations of the project.  Never mind that the authoritative Induced Travel calculator based on research from the University of California Davis, shows that expanding I-5 to 10  or 12 lanes for five miles would add 155 to 233 million miles of driving and 800,000 to 2.5 million tons of greenhouse gases.  Freeway widening would worsen the climate crisis.

    Of course, these calculations don’t include the effects of congestion pricing.  Tolling I-5, which will be needed to pay for this project, would likely reduce and divert traffic (as we explain below), and ODOT’s own consultants show that tolling would reduce I-5 traffic by enough to entirely eliminate the need for widening I-5 at all.  If the project manages somehow not to be tolled (as many in Clark County want) it would tend to produce vastly more traffic and pollution, as estimated by this calculator.

    At $5 billion, the proposed I-5 bridge project is the largest single spending item in the Regional Transportation Plan.  If Metro isn’t going to undertake a serious appraisal of the greenhouse gas impacts of building or not building this freeway then it doesn’t really have a climate strategy.

    Metro is officially on record as supporting efforts to address climate change.  Metro has said it wants to reduce greenhouse gases by 20 percent by 2035.  But so far, its efforts have yielded no decline in emissions.  And greenhouse gas emissions from transportation  in metro Portland have actually increased by 1,000 pounds per person in the past five years.  Metro has so far done nothing, and this and other freeway widening projects will make pollution worse.

    At best, the I-5 bridge advocates pay lip service to climate issues, completely ignoring the effects of added road capacity on likely travel volumes and greenhouse gases, and instead making vague and unquantified claims that pedestrian and bike facilities on the bridge, plus transit improvements will somehow ameliorate the climate damage done by doubling freeway capacity.

    Approving funding for a climate polluting freeway widening project, and failing to insist on developing a more climate friendly alternative way of spending $5 billion is the opposite of planning, and a betrayal of Metro’s stated climate commitments.

    A failure to plan for road-pricing.  The State Legislature, ODOT, the City of Portland and Metro have all said that road pricing will be a key component of the region’s future transportation system.  Pricing can help better manage roadways, reduce peak hour traffic, lower the need for additional capacity, and provide funding for maintenance and equitable alternatives.  Metro should not approve a $5 billion freeway project without a clear idea of how the project integrates with a system of road pricing—and yet ODOT and WSDOT have done essentially nothing to integrate these two concepts.

    ODOT faces a profound dilemma with regard to road pricing.  Its financial analysis counts on at least $1.4 billion in revenue from tolling the I-5 bridge.  But the project is being sized and designed as if it needs to handle 180,000 vehicles per day, based on traffic projections—outdated, using 2005 data, and built using a model that ODOT concedes can’t address the effect of tolling.

    But imposing tolls will profoundly reduce traffic growth.  ODOT’s own consultants, in work completed after the CRC FEIS, have said that the proposed tolls on the I-5 bridges would reduce traffic levels on the bridge from their current level of approximately 130,000 trips per day to only 85,000.  (And this is a firm that routinely over-estimates traffic on toll roads).  Road pricing could dramatically reduce the need for expensive infrastructure.  Yet ODOT has not incorporated the traffic-reducing effects of tolling into its design or alternatives analysis.  They are treating it purely as a financial afterthought:  a way to pay for a over-sized roadway after they’ve borrowed billions of dollars to build it.  That’s exactly what Louisville did with a remarkably similar project (widening I-65 from 6 to 12 lanes across the Ohio River); there $1 tolls caused traffic to fall by almost half.

    Louisville’s I-65 bridges at rush hour: $1 tolls eliminated tens of thousands of daily trips

    If Metro were to demand that road pricing be implemented before squandering billions on this project, it would likely find that the region had more than adequate transportation capacity across the Columbia River. A region that says it is going to implement road pricing doesn’t commit to a multi-billion dollar freeway project based on outdated projections, and subsidize expensive freeway capacity that won’t be needed in a world with pricing. Going deeply into debt for a megaproject and failing to consider how paying for it will reduce traffic is the opposite of planning.

    No financial viability.  At $5 billion or more, this will be the most expensive transportation project in this region for the next couple of decades.In theory, the project should be part of the region’s “financially constrained” regional transportation plan, but the budget documents prepared by the state DOT staffs show that they don’t know the actual cost of the project, and that there is a massive, $3.4 billion hole in the project’s budget.  Moving ahead with no clear idea how the project would be paid for is opposite of planning.

    The original CRC effort foundered a decade ago because there was no stomach for its excessive costs in either Oregon or Washington.  Congressman Peter DeFazio famously declared the 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.

    Ten years ago, the two state DOT’s squandered nearly $200 million on planning without first securing the needed funds for the project, and they are repeating this exact failed strategy today.  Now, in their efforts to revive the project, after two years of work, the project has not developed a definitive financial plan, and its estimates of Oregon’s needed contribution have inexplicably jumped by more than $150 million in a month.  ODOT and WSDOT are spending millions—$200 million is planned for staff and consultants before this project breaks ground—with no clear idea of how this will be paid for.

    This amendment adds $71 million to the preliminary engineering (PE) phase of the IBR Program. With this change, the total available budget will change to $80 million ($45M from Oregon and $35M from Washington). The estimated PE cost to complete NEPA for the IBR program is approximately $135 million based on a completion of a supplemental environmental impact statement (SEIS) in mid-2024. Following NEPA completion, the IBR program will develop a program delivery plan and progress with right-of-way acquisitions and final design to prepare for the start construction in late 2025. The estimated PE cost for progressing final design to start the first phase of construction is estimated at approximately $70 million. In summary, the total estimate of PE to begin the first phase of construction is estimated to be approximately $205 million. This estimate is contingent on the scope of the IBR solution, as agreed to by program partners, that will be evaluated through the SEIS along with the scope of the program’s first construction phase. Right-of-way costs and construction costs are not included in this budget estimate.

    [Chris Ford, Memo to Metro TPAC, “I-5:Columbia River (Interstate) Bridge: Requested Amendment to the 2021-24 Metropolitan Transportation Improvement Program.” Oregon Department of Transportation. September 24, 2021, aka ODOT/Ford Memo. Page 6. Emphasis added.)

    The prospect for Build Back Better and a national infrastructure funding package is no reason to move ahead with a misguided, environmentally destructive bridge project.  Oregon and Washington will get their share of these monies whether they build this project, or whether they choose to use these funds more wisely.  A regional government that cared about the future would ask “what is the smartest possible use of $5 billion” rather than approving this project.

    Cannibalizing maintenance to pay for megaprojects.  This particular project is a particularly egregious example of how state DOT’s beg for money by complaining that they don’t have enough money to fix potholes, but then use any additional revenue they can find to build massive new projects that simply increase the maintenance burden.  This project is no exception, ODOT is literally asking Metro to approve the reallocation of funds that would otherwise be used for maintenance to pay for planning the megaproject.

    ODOT is reducing money for road maintenance and repair to hire consultants for this megaproject.  ODOT’s own memo makes this clear.

    This project change requires adjustment to the fiscally constrained RTP. Funds from the fiscally constrained Fix-It buckets in the RTP will be reduced to allow for the $36M ODOT funds to be advanced on this project. Memo with details was sent to Metro 9/17/21 by Chris Ford. We find the analysis is still applicable with the addition of WDOT funds since RTP focuses on Oregon revenue only.

    [ODOT/Ford Memo. page 12, Emphasis added.]

    Diverting money from maintenance funds to pay for a megaproject is the opposite of planning.

    This is a pivotal moment for Metro.  As former Metro President David Bragdon (who guided the agency through the original Columbia River Crossing) wrote in retrospect:

    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.

    That history is important, because if you’re not honest about the patterns of the past, you are doomed to repeat them. Unfortunately, I understand that’s exactly what’s going on with the rebranded CRC: the same agencies, and even some of the same personalities who failed so spectacularly less than a decade ago – wasting nearly $200 million and building absolutely nothing – have inexplicably been rewarded for their failure by being given license to try the very same task, using the very same techniques of bamboozlement.

    Metro has a choice: It can repeat the mistakes of the past and bow to the wishes of an entrenched highway building bureaucracy, or it can do its job, and live up to its professed values.  It can plan.  It can insist on accurate travel projections, it can demand a definitive finance plan, it can require that freeway construction be addressed comprehensively, rather than piecemeal, it can require that the vision for capacity be integrated with congestion pricing, and it can require a full financial plan before squandering more on planning this speculative project.  And above all, it can insist that the region’s next multi-billion dollar transportation project reduce greenhouse gases, rather than increase them.  Anything less would be the opposite of planning.

    Oregon, Washington advance I-5 bridge based on outdated traffic projections

    The Oregon and Washington Departments of Transportation are advancing their $5 billion freeway widening plan based on outdated 15-year-old traffic projections. No new projections have been prepared since the 2007 estimates used in the project’s Draft Environmental Impact Statement,

    The two state DOTs are essentially “flying blind” assuming that out-dated traffic projections provide a reasonable basis for sizing and designing and new bridge, and rejecting other alternatives.

    The two agencies have spent two years and tens of millions of dollars but not done the most basic preliminary work to accurately predict future traffic levels.

    The Oregon DOT has specifically violated Governor Kate Brown’s pledge that new traffic analyses would be done prior to determining the “best solution” for the I-5 bridge project.

    The two agencies have no plans to publish new traffic studies until mid-to-late 2022—months after determining a final design and asking for other local sponsors to approve.

    The justification for spending upwards of $5 billion on a massive expansion of the I-5 freeway between Vancouver and Portland—a project misleadingly branded as a mere “bridge replacement”—is the notion that there will be a huge increase in traffic between the two cities.  That notion is based on traffic forecasts prepared by the Oregon and Washington Departments of Transportation.  As with all transportation projects, estimates of how much demand there will be are key to deciding whether projects are needed and justified, for determining how they’ll be designed and what their worth, and critically, assessing their environmental impacts.

    Traffic Projections for the I-5 Bridge are based on 15 year old data

    When it comes to the “I-5 Bridge Replacement Project,” which has been proceeding for more than two years, there are no new traffic projections.  The latest traffic numbers the Oregon and Washington Departments of Transportation are from the project’s Final Environmental Impact Statement, published in 2011.  They predict that without the project, traffic on the I-5 bridge will increase to 184,000 vehicles per day, and produce high levels of congestion.

    Columbia River Crossing Final Environmental Impact Statement , 2011, Chapter 3, page 3-30.


    These numbers are the same as were presented in the project’s Draft Environmental Impact Statement, published in 2008.  In fact, the traffic analysis for the project was completed in 2007, and is based on traffic data gathered in 2005.


    Columbia River Crossing Draft Environmental Impact Statement , 2008, Traffic Technical Report, page 47

    How, it is reasonable to ask, is it possible to plan for a $5 billion project without bothering to update the most fundamental data used to design, justify, and evaluate the environmental impacts of the project?

    Traffic Projections are Central to Project Design and Environmental Impact

    The basis for any major transportation investment is some sort of careful statistical analysis to project future travel volumes.  How many people might travel in a region or a corridor, and what are the various options for accommodating their travel?  The statistical models used to generate these data, should, in theory, inform the design of particular alternatives and shape the choices.  In particular, traffic forecasts are essential to evaluating the environmental effects of alternatives:  which alternative will have lower levels of pollution?

    We have many concerns about the quality and biases built into the models used by state Departments of Transportation, but without a doubt, these statistical estimates are in theory, the intellectual foundation for any claims about the need for a project.  Without traffic estimates, highway engineers are simply predicating key project decisions on their personal opinions rather than demonstrated facts.  In this case, the engineers guiding the I-5 bridge project are engaged in nothing more than faith-based project planning.

    For the past two years, the Oregon and Washington Departments of Transportation have been trying to revive the corpse of the Columbia River Crossing, a multi-billion dollar boondoggle that died in 2014.  In the process, they’ve told a series of lies, beginning with the false claim that unless they move forward with the moribund project, that they’d have to repay $140 million in federal money spent on planning the original project.  (That’s not true!).

    In September, the staff of the misnamed “Interstate Bridge Replacement Program” debuted their final and definitive list of project alternatives.  Every one of them is centered on a something labeled as a ten lane bridge, with typical illustrations like this:

    If the past is any guide, the agency will draw pictures of a ten-lane bridge, but then size it to accomodate 12 or 14 lanes of traffic—exactly what they did with the failed Columbia River Crossing.  In reality the project is likely to look like these renderings of the Columbia River Crossing—12- or 14- lane, five-mile long freeway.

    In the process, the staff has ruled out a range of other alternatives, like improving transit, instituting pricing, improving local connections, and constructing a supplemental bridge, rather than a replacement.  The staff published a series of memos in August, 2021, claiming, based on technical work done by the original CRC process more than a decade ago,  that these alternatives “failed to meet the project’s purpose and need,” the first item of which is “growing travel demand and congestion.” Whether any of these alternatives can meet “growing travel demand” and result in lower congestion depends critically on the assumptions one makes about future levels of traffic.  Similarly, the as yet un-resolved question of how wide the bridge needs to be also hinges on these same traffic forecasts.

    For two years, ODOT has disobeyed Governor Brown’s order to prepare new forecasts first

    The need for updated forecasts was recognized when the project was revived in 2019.  At the time, Governor Kate Brown promised that a first order of business would be revised forecasts to shape the project.  On November 18, 2019, Brown said:

    “I think what else is key is that we’re going to be doing a traffic analysis ahead of time to help us determine what’s the best solution for the I-5 Bridge Replacement Project.”

    Clearly, Governor Brown envisioned that we would do a traffic study first—”ahead of time”—and allow the data to shape decision.  But that’s not what has happened.  Let’s turn the microphone over to Clark County Today, which specifically asked the managers of the bridge project the status of their traffic projections, which were originally promised  in 2019.

    It is now almost two years later. Has the IBRP team conducted a new traffic analysis to determine what’s the best solution for the I-5 Bridge replacement project? Clark County Today asked for the details of any traffic analysis.

    “The Interstate Bridge Replacement (IBR) program is currently collecting new traffic data and conducting preliminary traffic modeling that will be used to inform the evaluation of preliminary design options that will be considered to identify the IBR solution early next year,” said Frank Green, IBR assistant program administrator. “More in-depth traffic modeling is expected to be completed in mid to late 2022 as a critical component of the federal environmental review process.”

    The IBRP team has no plans to release forecasts until after making design decisions

    That timetable was confirmed at the December meeting of the project’s Executive Steering Committee.  The project’s schedule calls for developing a resolution defining a “locally preferred alternative” by April 2022, and securing endorsements of that solution by June 2022.


    Meanwhile, ODOT and WSDOT have no plans to complete serious traffic modeling—which would address the impact of tolling on traffic levels—for two or three more years.  In its November presentation on its tolling plans, the agencies made it clear that they are putting off serious “investment grade” forecasts—like the ones made for the CRC, which showed traffic on I-5 would never recover to pre-construction levels, until 2025.

    What this means in practice, is that the only traffic projections that the project has were the ones prepared for its original environmental analysis.  These were published originally in 2008, and based on 2005 base year data.  As a practical matter, ODOT and WSDOT are planning this bridge based on data that is now more than 15 years out of date.

    Pushing for a decision before updating traffic forecasts is engineering malpractice, and violated NEPA

    When the project managers say that they need to build a bridge that is at least 10 lanes wide, it’s based on these outdated projections, rather than current, accurate information.  This isn’t so much fact-based engineering as it is faith-based speculation.  They’ve decided the bridge needs a minimum of ten travel lanes, without first doing a traffic forecast. The I-5 Bridge Project’s Manager has made it clear for nearly a year—well in advance of any technical analyses or any new traffic information—that they’ve already decided what they’re going to do.  Clark County Today summarized a January, 2021 presentation by Greg Johnson:

    During discussions at Monday’s EAG meeting, Administrator Johnson made the following statement.
    “One of the things that I also tell folks, if you’re here and you think we’re going to talk about a third bridge, or we’re going to talk about not doing the Interstate Bridge, you’re in the wrong meeting.  The whether we’re gonna do this has been decided. “

    John Ley, “Revelations surface from the two ‘advisory’ group meetings on the Interstate Bridge,” Clark County Today, January 28, 2021.

    Saying that the project must be ten lanes wide, or claiming that other alternatives don’t adequately meet the project’s stated purpose and need are, in the absence of traffic forecasts, simply arbitrary and capricious.  The fact that project managers have repeatedly made definitive statements that no other options will be considered, and that the bridge will be ten lanes wide before even undertaking traffic analysis, shows that they have no intention of allowing the data to drive their decisions, and are signalling that they will cook the modeling to justify this pre-made decision about the project’s size and scope.

    Concealing or lying about traffic models is nothing new for ODOT. When it released its environmental assessment for the I-5 Rose Quarter freeway widening project, it entirely omitted any data on “average daily traffic”—the most basic yardstick of travel volumes, and also purposely concealed its modeling assumption that its base year, 2015 traffic volumes were based on the entirely fictional assumption that the I-5 Columbia River Crossing had already been built. As we’ve said, this is the opposite of planning.



    Here’s what’s wrong with Oregon DOT’s Rose Quarter pollution claims

    10 reasons not to believe phony DOT claims that widening highways reduces pollution

    We know that transportation is the largest source of greenhouse gas emissions in the US, and that our car dependent transportation system is the reason Americans drive so much more and consequently produce far more greenhouse gases per capita than residents of other wealthy countries.  Scientists have shown that building more and wider roads stimulates more driving, longer trips, and more decentralized land use patterns, reinforcing car dependence.

    With this entire vicious cycle well-documented, it’s hard to imagine anyone arguing that a widened urban freeway would  be good for the environment, but for state DOTs and their paid apologists, it’s a frequent claim.  They’ve created trumped up projections that claim traffic and pollution will be greater if we don’t build freeways.  These are false claims, and today we take a close look at how this plays out in one egregious, if typical, project.

    For years, we’ve been following the Oregon Department of Transportation’s proposed I-5 Rose Quarter freeway widening project.  The project would widen a mile-and-half long stretch of Interstate 5 in downtown Portland at that has recently ballooned to $1.2 billion.

    A key part of the agency’s argument is that this freeway widening project—exactly unlike every other one that has ever been undertaken—will have essentially no impact on air pollution or greenhouse gases.  They make the fanciful claim in their Environmental Assessment that the not widening the freeway (the “no-build” option) will somehow produce more pollution than the eight- or ten-lane freeway their plans shown they’re really intending to build.  In this commentary we sketch ODOT’s claims, and present a 10-point rebuttal.

    A long list of false environmental claims from Oregon DOT

    Recently, a Portlander interested in the project contacted us, asking us to comment on ODOT’s Environmental Assessment, which makes these claims:

    • Traffic operations would improve on I-5 in both the AM and PM time periods, . . .
    •  Conditions for pedestrians and bicyclists would improve from increased travel route options, improved ramp terminal intersections, physical separation from motorized users, and reduced complexity of intersections.
    • Overall, the Regional Travel Demand Model results did not indicate trip increases on I-5 much beyond the Project limits (i.e., no induced demand). The 5 to 14 percent trip increase on I-5 within the Project Area is expected for an auxiliary lane project intended to improve flow between entrance ramps and exit ramps and is indicative of primarily local through-traffic.
    • While consideration of greenhouse gas emissions and the effects of climate change has not been a NEPA requirement for EAs and EISs since the Council on Environmental Quality (CEQ) withdrew its previous guidance on April 5, 2017, ODOT included an analysis of climate change in the Project EA due to the high level of agency and stakeholder interest in these issues. As reported in Section 3.5 of the EA, the 2045 operational greenhouse gas emission total for the Build Alternative is projected to decrease by approximately 22 percent compared to the 2017 emission total due to federal, state, and local efforts to develop more stringent fuel economy standards and vehicle inspection and maintenance programs and the transition to cleaner low carbon fuels for motor vehicles. These trends are expected to continue over the life of the Build Alternative. The Build Alternative would contribute to this reduction due to higher speeds, less stop-and-go traffic, and less idling on I-5. Therefore, no mitigation is proposed.

    Ten reasons not to believe Oregon DOT’s false claims

    There is so much that is false and misleading about these claims about traffic, air pollution and greenhouse gases that it’s difficult to know where to begin.  We’ve written about all these phony claims at City Observatory.  Here are ten reasons why everyone should ignore ODOT’s environmental analysis of this project.

    1. Traffic projections assume that a five-mile long, 12-lane wide freeway was built just north of this project in 2015.  Hidden in the Rose Quarter’s traffic forecasting is an assumption that a massive, multi-billion dollar Columbia River Crossing was built as part of the “no-build”–and finished five years ago. The project is still in limbo in 2021.  This inflates traffic and increases congestion in the Rose Quarter in the “no-build,” and makes the “build” look better than it is.

    2. ODOT concealed plans that show it is widening the I-5 roadway enough to accomodate 8 or 10 lanes of traffic.  Two years after ODOT published the environmental assessment we uncovered true plans for a 160-foot roadway. But its traffic modeling assumes that the freeway is expanded only from four to six lanes.   Modeling an 8-  or 10-lane road would show much more traffic and pollution.

    Secret ODOT documents showed plans for 160 foot roadway, enough for a 10-lane freeway.

    3. ODOT’s Rose Quarter Forecasts forecasts are completely inconsistent with the forecasts they prepared for the CRC and as part of ODOT’s own road pricing work.  Those forecasts show much lower traffic on I-5 in the RQ in the “no build” scenario.  By inflating the base case, and ignoring induced demand, the Rose Quarter forecasts cook the GHG and pollution estimates and hide the negative impacts of the project.  (For details, see the section labeled “Two sets of books”, at the end of this commentary).

    4. ODOT frequently claims that “pollution will be lower in the future”—but this is entirely due to assumptions about a cleaner vehicle fleet (more electric vehicles, tougher mileage standards for remaining internal combustion cars).

    “. . . operational greenhouse gas emission total for the Build Alternative is projected to decrease by approximately 22 percent compared to the 2017 emission total .  . .”

    This is a classic red herring:  You get these emission reductions whether you build this project or not. It’s simply irrelevant to deciding which options to choose. And, for what it’s worth, neither electric vehicle adoption or higher fuel economy standards accomplishing as much as ODOT hoped; in fact greenhouse gas emissions from driving are up in Portland by 1,000 pounds per person

    5. In response to these criticisms, ODOT routinely claims that its air quality analysis was validated by a  “peer review panel”.  The panel was a whitewash:  it wasn’t provided with any of the critiques of traffic models and air quality analysis, held no public meetings, and explicitly chose to ignore road pricing, which they admitted could greatly affect project outcomes.  Former ODOT Director Grace Crunican, who ran the review, testified that the group didn’t look at the traffic projections to see if they were reasonable or accurate, they just took them at face value. The phony traffic numbers generate phony air quality estimates.

    6. There is a strong scientific consensus on induced demand, with multiple studies in the US, Europe and Japan.  Wider roads means more travel.  ODOT and other highway agencies simply ignore the science.

    When pressed, professional staff ODOT and PBOT admitthis project will do nothing to reduce daily “recurring” congestion at the Rose Quarter—invalidating claims that it will produce less idling.

    7. At City Observatory, we’ve developed a version of the induced travel calculator created by the University of California Davis to estimate greenhouse gas emissions from the Rose Quarter project.  Its verdict:  Widening the roadway will increase emissions by adding 17.4 to 34.8 million miles of vehicle travel and 7.8 to 15.5 thousand tons of greenhouse gases per year.

    8. Highway engineers love to pretend that greenhouse gases are caused primarily by cars having to idle in traffic, and they we can fight global warming by getting cars moving faster. That’s a myth:  Improving traffic flow generates more total miles of travel which overwhelms any savings from less idling.  Also:  Cars generate more GHG per mile at speeds over 50 MPH than below (something ODOT never mentions).  Wider, faster freeways mean both more vehicle miles traveled and more greenhouse gases generated per mile traveled.  This is validated scientifically by a paper published by two scholars at Portland State University.

    9. Like most state DOT’s Oregon DOT uses an outdated and flawed traffic modeling approach that fails to accurately incorporate the effects of induced demand.  These static, four-step models consistently over-estimate traffic levels and congestion for no-build scenarios, and under-estimate or completely ignored the added travel induced by creating more capacity.

    10. Globally, the only strategy that’s convincingly been shown to lower congestion is road pricing, which the Oregon Legislature approved for this stretch of I-5 in 2017.  Oregon DOT failed to examine road pricing as an alternative in its 2019 Environmental Assessment.  ODOT’s own consultants say pricing I-5 would obviate any need to add lanes at the Rose Quarter.

    Governor Brown ordered ODOT to look at road pricing as part of its environmental review of the project in late 2019; but the agency has simply ignored her instruction.

    ODOT is keeping two separate sets of books for its I-5 traffic estimates.

    There’s no question that the traffic estimates created to sell the Rose Quarter project were rigged to make the “No Build” look worse.  At the same time it generated the Rose Quarter forecasts, ODOT hired another firm to estimate future traffic on this same stretch of roadway in 2027.  It came up with dramatically lower levels of I-5 traffic in the “no-build” world.

    In May 2018, at the same time it was preparing I-5 forecasts for the Rose Quarter project, ODOT also contracted for modeling of I-5 traffic for the legislatively adopted congestion pricing plan. These are contained in a report from ODOT: https://www.oregon.gov/ODOT/Value%20Pricing%20PAC/VP_TM3-Final-InitialConceptEvaluatio n.pdf

    These data include baseline estimates of traffic on Interstate 5 in the Portland metropolitan area for the year 2027. The study has baseline estimates, that project future traffic conditions in the absence of congestion pricing. This study uses an I-5 cordon line North of the project area corresponds to N. Skidmore Street, which is just two blocks from the I-5 cordon line used for the Rose Quarter projections. The following table compares the projected 2027 volumes in the congestion pricing study at this cordon line with the VISUM Rose Quarter 2015 volumes. This shows that the volumes used in the VISUM model for 2015 are 21 to 37 percent higher than the expected volumes in 2027, according to the congestion pricing baseline model.

    I-5 North Volumes from two ODOT models
    Northbound Southbound Total Difference
    Time Period RQ VISUM Model (2015)
    AM Peak 8AM-9AM 4,370 4,631 9,001 37%
    PM Peak 5PM-6PM 4,424 4,855 9,279 21%
    Conges on Pricing Study (2027)
    AM Peak 8AM-9AM 3,255 3,337 6,592
    PM Peak 5PM-6PM 3,803 3,860 7,663
    RQ VISUM Model, “Mainline North of Going, 2015 No Build”
    Conges on Pricing Study, “Interstate Br.-Skidmore” Baseline Traffic Performance

    This analysis suggests that the traffic numbers, particularly north of the Rose Quarter project area are much higher than would be expected in another arguably reasonable forecast of traffic conditions. Given the expectation of growing traffic levels in the ODOT Rose Quarter modelling, one would expect that 2027 I-5 traffic levels would be considerably higher, not lower than 2015 levels. The fact that two models, prepared for the same agency, in the same month, produce two such different pictures of traffic levels suggests that the model results are highly sensitive to the assumptions and input values used by the modelers. These key values and assumptions have generally not been provided to the public for review, making it impossible for independent, third parties to understand, replicate, and analyze the summary results presented in the Environmental Assessment.

    Freeway-widening grifters: Woke-washing, fraud and incompetence

    The Oregon Department of Transportation’s glossy mailer to sell its $1.25 billion I-5 Rose Quarter Freeway widening project is a cynical, error-ridden marketing ploy.

    ODOT doesn’t show or tell about its wider freeway and more traffic, but instead tries to sell the project based on buildings it won’t contribute any money for building.

    ODOT sent an expensive mailer to thousands of Portland households studded with nearly two-dozen typographical errors.

    The key part of salesmanship, whether you’re selling condominium time-shares or breakfast cereal, is to emphasize the really attractive things that aren’t part of what the customer is paying for, whether it’s models cavorting on a glistening white-sand beach or the fresh bananas and blueberries atop a pile of bland corn-flakes.  The grifters at the Oregon Department of Transportation have settled on just this strategy for peddling their now $1.25 billion Rose Quarter freeway widening project.  In their latest marketing material:  It’s not about cars or lanes at all, it’s about covers and community centers and housing built by Black artisans.  Never mind that these “features”—like the models and the blueberries—aren’t actually part of the ODOT project at all.

    Woke-washing:  Fictional buildings

    As we’ve documented at City Observatory, the Oregon Department of Transportation is implicated in the destruction of Portland’s historically Black Albina neighborhood.  It slashed through the area with three major highway projects in the 1950s, 1960s and 1970s, leading to a two-thirds decline in neighborhood population.  Today, its trying to sell its massive 10-lane wide freeway widening project—which would increase traffic and pollution—as a way to remediate the damage to the neighborhood.

    Earlier this month, ODOT sent a glossy 4-page newsletter to thousands of Portland households.  Its key feature is illustrations portraying new, but entirely fictitious, buildings lining the streets of Albina.  Previously, they’ve shown proposed buildings to be constructed on or adjacent to the freeway as part of the project’s environmental assessment.  Earlier this year, they paid consultants to illustrate hundreds of entirely conjectural apartments on or next to the widened freeway.  Now their new brochure sets a new bar for illusion, showing a fictitious streetscape of N. Vancouver Avenue, with three imaginary buildings.  In the lower right hand side of the frame, 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.

    This freeway widening project is part of a complete breakfast (some features sold separately).

    If this were a commercial publication, it would have to include some kind of disclaimer.  ODOT went out of its way to emphasize the “highway cover” aspects of the project, without mentioning that the project’s real purpose is to widen the freeway. The brochure is doesn’t show a single car, nor does it reveal that the project is designed to expand the freeway to as much as ten lanes wide.

    Fraud:  There’s no money to build these buildings

    It would, of course, be nice to have more housing in Albina, and to have a career development center, and to advance the redevelopment plans of the Albina Vision Trust.  But in reality, none of these features is actually part of ODOT’s I-5 Rose Quarter Freeway widening project.

    The fundamental problem with all these imaginary buildings, including new housing, and the career development center:  There’s no funding for any of them as part of the Rose Quarter freeway widening project.  And, as we’ve shown at City Observatory, the cost of new buildings shown would run to hundreds of millions of dollars.  Despite the fact that it demolished hundreds of homes to build its highways through Albina, ODOT has never provided a dime to rebuild any of them, and is saying it won’t as part of this project either.

    At best, the project claims that it might provide the sites on which these mythical structures could be built, but even that claim is misleading.  The Oregon Transportation Commission is now seeking to stick city and county governments with the added costs of freeway covers wide and strong enough to support this development.  So while apartments and a career development center are being prominently displayed as the centerpiece of this project, ODOT isn’t paying for any of them, or even the sites on which they’ll be built.  They expect others to do so.  The fact that the agency pretends to care about social justice, but won’t contribute to repairing the damage its three highways caused Albina, including replacing the housing it destroyed, shows its commitment is a sham.

    Incompetence:  A document shot-through with typographical errors

    The full-color glossy four-page brochure, titled “Newsletter: I-5 Rose Quarter Improvement Project, Volume 1, Issue 2, September 2021” was delivered via bulk mail to thousands of households in North and Northeast Portland.  But while ODOT took great pains to downplay the actual nature of the project (a ten-lane freeway), and to incorporate images of African-Americans and fictitious buildings, they apparently didn’t have a budget for proof-reading or care enough to do a press check of their elaborate newsletter.

    As publishers ourselves, we know that the occasional typo is the bane of one’s existence, and that a few always seem to sneak through.  No one is perfect.  But in this ODOT newsletter we counted 23 typographical errors. Here we’ve circled in red errors on pages 2-3 of the brochure.

    There were errors on every page of the brochure.  One page of the report is titled:  “Our Values in Action.”  Apparently neither accuracy nor attention to detail are among the project’s values.  For years, the agency has been misleading the public about the project, concealing basic facts like the width of the freeway it is planning to build and repeatedly including illustrations of fictional buildings that aren’t part of the project (see below).

    There’s a lot of missing substance in this ODOT newsletter.  It reveals nothing about the cost of the project, which has ballooned to $1.25 billion.  It conceals the fact that the real purpose of the project is to widen the I-5 freeway to 10 lanes, which will result in more traffic and pollution. It ignores news reports that have utterly disproven its false safety claims about the project.  It says nothing about the active community opposition to the project, which has produced thousands of citizen objections.  It doesn’t reveal that the project is being challenged in court for violating federal environmental laws and state planning requirements.  It fails to acknowledge that the project will increase greenhouse gases–a fact that has produced regular bi-weekly protests at ODOT’s Portland headquarters.

    What this document really shows is that ODOT has no intention of telling the truth about the Rose Quarter freeway widening project.  This brochure, like the ODOT effort that produced it, is cynical, misleading and incompetent.  This is hardly an effort that should be rewarded with $1.25 billion in public funds.

    ODOT’s deceptive history

    Here are illustrations from the project’s 2019 Environmental Assessment showing wireframe buildings as part of the freeway-widening concept.  (Again:  There’s no funding for such buildings as part of the project).

    Likewise, 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.



    Talkin’ ’bout my gentrification

    Jerusalem Demsas of Vox has a thoughtful synthesis of what we know about gentrification.  

    If we’re concerned about poverty and inequality, gentrification is far from the biggest problem we face.

    Gentrification is surprisingly rare, and while it brings inequality into sharp focus, there’s precious little evidence of widespread harms.  The bright spotlight shining on a relative handful of gentrified neighborhoods hides in the shadows the real and far more pervasive problem of concentrated poverty.

    And, as we’ve written at City Observatory, the myopia of gentrification scholarship means that few studies every consider the counterfactual case of asking what happens to people who live in poor neighborhoods that don’t rebound.  

    The most common anti-gentrification tactics—blocking new market rate housing—actually make housing affordability and displacement worse.

    Writing at Vox, Jerusalem Demsas has become quickly established as a keen observer of urban issues.  This past week, Demsas waded into the gnarliest and most contentious urban debate, gentrification.  This balanced essay is worth a read.  Here’s our take.

    Gentrification doesn’t create inequality:  It just makes it more visible.

    America’s cities are segregated by race and class and essence of segregation is keeping these worlds separate and apart from one another, and by doing so, make inequality less visible.  What gentrification does, in effect, as Demsas convincingly argues, is to force us to see inequality:

    Segregating neighborhoods does not get rid of these sentiments or the harms they cause: it simply hides them. In a wealthy, white enclave like the Upper East Side, there aren’t somehow fewer people who assume any Black person on their street is begging for money than there are in gentrifying neighborhoods. In fact, there are likely more. Gentrifying neighborhoods pull back the veil and allow for these worlds to collide, displaying the vast differences in income, access to education, and government protection and investment.  . . . Taken all together, it becomes clear why we focus on gentrification while the unseen culprits (segregated enclaves) are able to avoid controversy: Gentrification is the most visual manifestation of inequality in urban life.

    Concentrated poverty, not gentrification is the big urban challenge

    Much of the gentrification literature is fueled by anecdotes and narrowly drawn case studies that relate the dissatisfaction that long-time residents of gentrifying neighborhoods feel as a result of neighborhood change.  And there’s little question that change imposes social and psychic costs for long-time residents.  This kind of ethnographic research isn’t so much wrong as it is incomplete.  As we’ve pointed out at City Observatory, this kind of research is biased because is is missing the counterfactuals:  What do long-time residents of non-gentrifying poor neighborhood say about how their neighborhoods have changed?  And what would a neighborhood look like if it didn’t attract new residents.

    We and others have assembled comprehensive data on neighborhood change in US cities.  It shows that gentrification is extraordinarily rare (over 4 decades, perhaps 10 percent of poor neighborhoods experienced gentrification, defined as having a poverty rate fall from twice the US average to anything less than the national average).  Statistically, the far more striking fact is the persistence and growth of concentrated poverty.  Poor neighborhoods that don’t gentrify steadily lose population (down an average of 40 percent over 40 years), and the number of high poverty neighborhoods in major US metro’s has tripled.  Americans in poverty today are more likely to live in neighborhoods of concentrated poverty.  Research shows that all of the negative effects of poverty are amplified by having lots of poor neighbors.  As Demsas concludes:

    City by city, the message is clear: Segregation and concentrated poverty are the true blights of urban life, despite our fascination with gentrification.

    There’s precious little evidence of the supposed harms of gentrification even in those relatively few neighborhoods that are changing. Careful economic studies show that gentrification generally benefits long-time residents.

    Supposed cures for gentrification often make the problems worse

    Demsas concludes by musing about the “ethical” ways we might use to promote greater integration, and ends up suggesting more housing, greater tenant protections, and less restrictive zoning in predominantly white and middle income neighborhoods.  Making it easier to build more housing in high demand locations makes a lot of sense, but that advice runs distinctly counter to most anti-gentrification efforts, which are squarely focused on blocking new market rate housing.

    The painful irony of many anti-gentrification tactics is they simply serve to make housing affordability and displacement worse. Advocates regularly oppose up-zoning and new developments, or as in Atlanta, impose development moratoria to “save” the neighborhood.  Attempting to slow or stop  neighborhood change by blocking the construction of new market-rate housing—which many associate with gentrification—only makes housing supplies tighter, and drives up rents.  As Demsas notes, this flies in the face of a spate of recent studies that show that construction of new market rate housing actually helps hold down rents, and by setting off a chain of household moves, opens up more housing opportunities for lower and moderate income households.

    Two of the big persistent problems in the American metropolis are segregation and racial wealth disparities.  And despite the pain of change, gentrifying neighborhoods are the places where these two interrelated problems are being ameliorated.  Our 2018 study America’s Most Diverse, Mixed Income Neighborhoods, showed that many places identified as “gentrifying” are the most racially and economically mixed places in the nation.  And contrary to common assumption, once neighborhoods become more racially and ethnically diverse, they tend to stay that way.

    As Andre Perry and his colleagues at Brookings Institution have documented, there are persistent disparities in the value of homes in predominantly Black and predominantly white neighborhoods.  These disparities are a major contributor to the racial wealth gap. And these disparities are largest in metro areas with high levels of racial segregation.  It’s a seeming paradox, but rising home prices in gentrifying neighborhoods are actually diminishing this underlying home value disparity.  As bad as a it may be to have to pay higher property taxes because your home has appreciated (and your wealth has increased) it’s far worse to see your wealth stagnate or decline because slumping home values in a segregated neighborhood.

    Climate efforts must be cost effective

    Portland’s $60 million a year clean energy fund needs climate accountability

    Any grant writer can spin a yarn that creates the illusion that a given project will have some sort of climate benefits, but if you’re actually investing real money, you should insist on a payback in the coin of the climate realm:  a measurable and significant reduction in greenhouse gas emissions.  That standard isn’t being met, mostly because even the most basic questions aren’t being asked of projects submitted for funding by Portland’s Clean Energy Fund.

    Former Portland City Commissioner Steve Novick, and long-time Chair of the Oregon Global Warming Council, Angus Duncan are demanding that Portland’s $60 million per year clean energy fund have at least minimal performance standards when it comes to reducing greenhouse gases.  A bit of background:  using the city’s initiative process, activists forwarded a ballot measure to create a gross receipts tax on larger businesses, with the proceeds dedicated to clean energy investments.  The voters approved the measure by a wide margin, and the Portland Clean Energy Fund (PCEF) now is making grants to community groups for projects to promote greater energy efficiency, and, at least in theory, reduce greenhouse gases.  But in practice there are real concerns that the dispensation of grants is advancing either climate or equity considerations. As Novick and Duncan wrote in their Op-Ed:

    Already, the fund has issued grants for projects that have nothing to do with climate or equity, including $100,000 for a rooftop garden on a yoga studio. For the program’s long-term success, we should ensure that the fund supports proposals tied to specific outcomes and cost-effectiveness goals. Unfortunately, the fund’s proposed scoring criteria do not provide any such benchmarks. Indeed, they are not really focused on outcomes at all.

    The underlying problem is that PCEF doesn’t have clear standards for defining what constitutes either equity, or cost-effective greenhouse gas reductions.  According to Novick and Duncan, the application process is a kind of affinity-demonstrating beauty contest, with applicants chosen chiefly for the meritorious origins of the sponsoring organization rather than the characteristics of the project.

    For example, applicants for large-scale grants of up to $10 million can earn no more than 8 points out of 100 for reducing greenhouse gas emissions. Think about that: “Clean Energy Fund” applicants could, apparently, get 92 points out of 100 without reducing greenhouse gas emissions at all. Meanwhile, applicants can only lose 5 points if their proposal will not “realistically result in intended outcomes.” So, you could get 95 out of 100 points even if your project has no realistic chance of succeeding. Applicants get a large number of points for “characteristics of the organization” categories, which may be important, but not more than actual results. The selection committee could simply require that organizational applicants meet certain criteria for diversity, etc., rather than allowing applicants to make up for a lack of substance by accumulating “organizational” points.

    The idea of setting up a public sector fund to advance the twin goals of promoting equity and reducing greenhouse gases has considerable merit, but if it’s going to make any difference in either area, it needs to insist on measurable results and clear accountability.  The current PCEF regulations do very little to achieve this fundamental need.  Portland’s voters, historically disadvantaged communities, and the environment all deserve better.

    A net zero blind spot

    Stanford claims its campus will be 100 percent solar powered . . . provided you ignore cars.

    A flashy news release caught our eye this week.  Stanford University is reporting that its campus will be 100 percent powered by solar energy very soon.

    In the echo chamber that is social media, that claim got a lot of attention and repetition, and predictably morphed into an even more sweeping accomplishment.  Climate Solutions tweeted that Stanford would be the first major university to achieve 100 percent clean energy.

    To be clear, Stanford’s press release didn’t make that claim, but any time you tout “hashtag 100 percent” anything, people tend to focus on the “100” and not on the universe to which that is applied.  When you read the fine print, it’s clear that the “100 percent” claim applies only the the campus buildings, not to how students, faculty, staff and visitor actually get to and from the campus to for education, research and entertainment.

    Buildings get a lot of attention; you have to use energy to heat, light, and cool them, and run computers and other equipment, but as with the rest of America, the far bigger source of energy use and carbon emissions is not the buildings themselves, but the energy and pollution generated by traveling to and from them.  In California, cars account for 5 times as much greenhouse gas production (28 percent) as all commercial buildings (5.5 percent).

    In the case of Stanford University, The “100 percent  solar” claims definitely doesn’t include the campus’s nearly 20,000 parking spaces, most of which are used by internal combustion fueled cars.   About 58 percent of those working on campus arrive by private car. And that produces vastly more carbon emissions that just building operations.

    To its credit, in recent years, the university has been taking steps to build more on-campus housing, and to meet the travel demand from expansion without increasing the total number of car trips, but it’s still the case that cars and travel are the university’s leading source of greenhouse gas emissions.  So far the university’s own sustainability plan has counted mostly building-related emissions, and avoided counting what it classifies as “Scope 3” emissions associated with university travel.  They’re planning to address those emissions in the future.

    While it’s technically true that the building energy may come from solar, it’s important to recognize that the buildings have no utility unless people travel to and from them on a regular basis.  The parking lots, and the cars they service are an integral–and in fact dominant–part of the university’s carbon footprint.  It’s all well and good to celebrate greater use of solar power, but before anyone makes “100 percent” or zero net carbon about any particular institution, they would do well to consider all their emissions, not just one component.


    BIB: The bad infrastructure bill

    Four lamentations about a bad infrastructure bill

    From the standpoint of the climate crisis, the infrastructure bill that passed the Senate is, at a minimum, a tremendous blown opportunity.  Transportation, especially private cars, are the leading source of greenhouse gas emissions in the US.  We have an auto-dependent, climate-destroying transportation system because we’ve massively subsidized driving and sprawl, and penalized or prohibited dense walkable urban development.  The Senate bill just repeats the epic blunder of throwing more money at road building, and even worse this time, drivers are excused from paying the costs of the bill—a triumph for asphalt socialism.

    You’ve probably seen “BIB,” Michelin’s famous cartoon mascot for its tires (and tourist guides).  Coincidentally—and perhaps appropriately—BIB is the nickname of the Senate-passed bi-partisan infrastructure bill. and the animated stack of tires is an fitting mascot for the legislation.  It’s all about driving and jovially oblivious to the deep systemic problems in our approach to transportation finance.

    Michelin’s BIB is the true mascot of the Bi-Partisan Infrastructure Bill; Two thumbs up for more subsidies to auto dependence, climate destruction and asphalt socialism.

    Others, including Transportation for America, NACTO, Streetsblog, the Eno Foundation and Politico have written about the details behind the bill.  You should definitely read their analyses.  But allow us to pull out just four themes—lamentations, if you will—that explain why this triumph of bipartisanship is a disaster for safety, climate, and fiscal responsibility.

    1. $200 billion for more deadly, climate killing highways.  The centerpiece of the bill is more money for roads and bridges, which in practice means wider roadways and more capacity.  The Senate Bill writes a $200 billion check for state highway builders, which is likely to fund wider roads and bridges that will generate more traffic, more pollution, more climate-destroying greenhouse gases, and more sprawl.  The National Association of City Transportation officials observes:

    . . . the infrastructure bill passed today by the Senate keeps our nation on an unsafe and unsustainable path. It continues to prioritize building the infrastructure that most contributes to the U.S.’s worst-in-class safety record and extraordinarily high climate emissions: new highways. With transportation as the largest source of U.S. climate emissions, and 80% of those coming from driving, the Senate’s bill goes in the wrong direction, giving a whopping $200 billion in virtually unrestricted funding to this unsustainable mode.

    Ironically the Senate passed the bill the same week the International Panel on Climate Change released its latest and most dire warning about the damage done by these greenhouse gas emissions.  The Senate Bill not only does nothing, but promises to squander vastly more resources to make the problem worse.

    2. No accountability for climate, safety or good repair.  It’s a considerable exaggeration to say we have a federal “transportation policy.”  In effect, while it mouths a national interest in a safe, well-maintained and sustainable transportation system, the Senate bill just continues a system in which the federal government writes huge checks to state highway builders and . . . looks the other way.  There are no requirements with any teeth that hold states accountable for the most basic of outcomes, and the Senate bill continues this system, as Beth Osborne of Transportation for America explains.

    . . . the Senate also supercharged the highway program with a historic amount while failing to provide any new accountability for making progress on repair, safety, equity, climate, or jobs access outcomes.

    3. Inequitable asphalt socialism, and the cynical joke of “user pays”.  The great myth of road finance in the US is that we have a “user pays” system.  Truth is that’s never been the case, as road users have forever been subsidized, and shifted the social, environmental and health costs of the road system off onto others.  The Senate had no stomach for asking road users to pay a higher gas tax to support roads, so instead, they’ve turned the  highway “trust fund” into the trust-fund baby of the BIB, getting a huge infusion of general fund money, which will simply be added onto the national debt, with the costs ultimately being repaid, with interest, from income taxes.

    An analysis by the ENO Foundation shows that the Senate bill transfers $118 billion to the highway trust fund from the general fund, bringing the total amount of the bailout of highway funds to more than $272 billion since 2008.

    We know that despite Congress dumping more than $200 billion of general fund revenue into the highway portion of the fund, that car apologists will continue to make the false argument that we have a “user pays” system, and that spending money on any non-auto form of transportation is somehow stealing from drivers.  This bill completely disconnects use of the transportation system from the obligation to pay for its costs:  what we call asphalt socialism.

    4. We could have done better.  House Transportation and Infrastructure Chair Peter DeFazio managed to engineer passage of a decent stab at transportation reform in the House, only to see it “gutted and stuffed” by the Senate.

    The bill that passed the House earlier this year contained provisions that at least gently nudged expenditure priorities in favor of “fix-it first” policies that would put repairs ahead of expansion, would require at least an effort to consider how highway construction leads to greenhouse gas emissions, and would have held states accountable for actually improving safety (rather than just talking about it).  All that language was purged from the Senate BIB.

    Politico‘s Tanya Snyder offers a succinct insider explanation of the politics of the bill from an anonymous former congressional staffer:

    “It’s not that it was bipartisan; it was a least common denominator approach,” said the former aide, who worked on the transportation bills that Congress enacted in 2012 and 2015, both of which were hailed as triumphs of bipartisanship. Larger ambitions, he said, “fail to get addressed because of the insistence on staying in the very, very narrow area of bipartisan agreement and we recreate the status quo.”

    So what the BIB really does is recycle and perpetuate a badly broken transportation finance system that promises to make our climate, community, health and transportation problems worse, not better.


    America’s berry best cities

    Why Boston and Portland are the berry-best metros, and why it matters

    Summer is the height of berry season in most of the US, and nothing beats a fresh, locally grown blackberry, blueberry or raspberry.  Today we’re ranking large metro areas in the US based on how many berries they grow (which we’re proxying using USDA data for farm acreage devoted to commercially raising berries of one sort or another).  While you can find at least some local berries almost everywhere, a few places really have an abundance of summer fruit.

    The overall leader is the Boston metro area, which is located at the Southern end of the nation’s cranberry-bog belt, and which has more than 12,000 acres devoted to raising berries in the counties that make up the metro area.  Second is Portland, at the head of the Willamette Valley, with 11,500 acres of berry farms, which produces a wide array of berries.  Other top metros include Tampa (a big producer of early season fruit) and Grand Rapids (a big blueberry producer).  Almost every metro area has at least a few commercial farms, but they’re rare in many dry places, like Austin, Denver, Las Vegas and Phoenix.  Of the 53 US metro areas with more than a million population, here are the top 25 metro areas, ranked by acres of berries grown:

    Berry acreage by metro area (USDA Food Atlas)

    Also near the top of the list, Philadelphia has a wealth of local berry farms.  In the west, they call it “U-pick”; in Philly it’s called “PYO–pick your own” and the Inquirer has lists of farms within thirty miles of center city where you can harvest your own blueberries or strawberries.

    The economic importance of local, perishable things

    While it might seem like ranking cities based on the presence of summer fruit is a bit esoteric, bear with us.  There’s a really good reason for thinking this is important.  A while back, for example, Paul Krugman waxed poetic about fruit and economic theory.  Krugman was just back from Europe, and thirsting for summer fruits coming into season. That led him to reflect on a fundamental flaw in economic logic, the notion that more choice is always better. The short, uncertain season for his mangoes and figs, makes them all the more valuable, not less so. He observes:

     . . . seasonal fruits — things that aren’t available all year round, at least in version you’d want to eat – have arrived. Mangoes! Fresh figs!  What makes them so great now is precisely the fact that you can’t get them most of the year. . . .The textbooks (mine included) tell you that more choice is always better. But a lot of things gain value precisely because they aren’t an option most of the time. I’d probably get tired of fresh figs and mangoes if I could get them all year round. But still, if you imagine that being rich enough to have anything you want, any time you want it, would make you happy, you’re almost surely wrong.

    We’ve written about other things—ranking cities by the numbers of locally owned restaurants, for example.  As the urbanist Jane Jacobs observed its these distinctive local experiences that make places special.  Every city has its own unique strengths—the big challenge is to understand, appreciate and build on them.  That’s what makes a great city.

    Selling Oregon into highway bondage

    Borrowing billions to widen roads endangers the climate and finances

    It’s doubly wrong to burden future generations with the environmental costs of wider roads, and then also send them the bill

    Bond financing of new capacity puts expansion ahead of repair and endangers the financial soundness of the transportation system

    Oregon Governor Kate Brown has just signed legislation that passed the Oregon Legislature,  HB 3055, which authorizes the Oregon Department of Transportation to issue revenue bonds to finance potentially billions of dollars of highway widening projects in the Portland metropolitan area.

    The Oregon DOT plan: Borrow billions to build more roads to make environmental catastrophe even worse.

    Oregon DOT is planning to widen freeways in Portland, including the Rose Quarter I-5 project, which we’ve now proven is designed to be wide enough to accomodate ten lanes.  It’s excessive width is the reason this project costs $800 million, and will cost even more if promised covers are constructed.  The department is working on a multi-billion dollar list of other freeway expansion projections, including a revived Columbia River Crossing, a widening I-205, a new Boone Bridge and widening Highway 217.  As we know from the fundamental law of road congestion, each additional lane mile of urban highways has the effect of generating more travel, more traffic and more pollution; these projects will certainly and measurably increase greenhouse gas emissions.

    HB 3055 allows ODOT to adopt a “borrow, spend and build, then only later toll” approach to construction which is guaranteed to produce oversized facilities, that require increased traffic to avoid being a financial burden.  ODOT’s own consultants on tolling have said that modest tolls could avoid the need to build any additional capacity on key Portland freeways, including the Rose Quarter.

    ODOT  is planning to embark upon a speculative financing scheme authorized by HB 3055 to issue potentially billions of dollars of bonds to widen highways throughout the Portland area.  In theory, the bonds would be repaid by tolls, but ODOT has exactly zero experience in forecasting toll revenues. Forecasting toll revenue is a notoriously difficult business, and many toll roads and bridges have been forced into bankruptcy or bailouts because toll revenues didn’t match over-optimistic projections.

    That’s a problem, because HB 3055 allows ODOT to pledge, without limitation, all of its future revenues from state taxes and federal grants, to the repayment of bonds issued to pay the cost of toll funded highway expansion projects. If toll revenues are insufficient, ODOT would be required to take money from every other available source, including state and federal funds for road maintenance around the state, and use it to satisfy bond obligations.

    Coupled with the fact that its major projects of the past two decades have all ended up costing double or more what they were projected, bond financing freeway widening exposes the state to financial risk.  And when toll revenues aren’t enough to cover construction costs, ODOT is pledging every dollar available to it to bondholders, putting them in line ahead of every other project in the state, including maintaining our existing roads.

    What’s worse:  this Faustian bond bargain commits Oregon to filling newly widened roads with traffic in order to generate the money to pay bond holders.  Borrowing creates the perverse financial incentive to maintain and increase traffic (and attendant climate pollution) in order to be able to pay off bonds and is directly contrary to the state’s adopted legal goal of reducing greenhouse gas emissions. This approach is doubly evil:  it widens roads and generates traffic that will make climate change worse, and sticks future generations with the bill for paying for these roads, whether they’re used or not.

    This plan to bond for huge highway expansions in the Portland area takes the state in exactly the wrong direction, in contradiction to our stated values:   it would worsen our state’s carbon footprint, make us financially beholden to financial markets to generate traffic to repay bonds, and send the bill for this destructive and unneeded capacity to future generations of Oregonians, while undercutting the financial stability of the state transportation system.

    Oregon DOT’s Real Climate Plan: Keep on polluting

    The Oregon DOT’s “Climate Action Plan” claims that the agency wants to decrease greenhouse gases, but its financial plans show otherwise

    The agency’s revenue projections show it is planning for gasoline consumption not to decline at all, meaning that carbon emissions don’t decline

    ODOT’s fuel tax projections imply that cars and trucks will continue to produce about 19 million tons of greenhouse gases through then end of this decade, an amount 60 percent larger than consistent with achieving the Governor’s greenhouse gas reduction goals.

    ODOT has used these fuel consumption projections to convince private investors to buy bonds to be repaid from future gas tax revenues; the financial projections, not the climate PR, represents the agency’s real position.


    The Oregon Department of Transportation is telling anyone who’ll listen about their supposed deep concern about climate change, and all the actions they’re taking to reduce greenhouse gas emissions.  It’s a splashy PR campaign, with a newly minted “climate office” and a “fig leaf” logo.

    But that’s not the real story.  The real story is told, not in the agency’s PR documents, but in its financial plans and projections.  It’s told in the byzantine “official statement” it provides to bond markets.  That real story is that the agency is planning on Oregon’s transportation system continuing to emit just as much greenhouse gases for the next decade as it does today.  Its financial plans hinge on Oregonians buying, and burning enough gasoline and diesel into the 2030s to produce nearly 20 million tons of CO2 a year—roughly 20 percent more than was emitted in 1990, and nowhere near the state’s official target of cutting greenhouse gas emissions by 80 percent by 2050 (and far below interim targets established by Governor Brown).

    Oregon Governor Kate Brown’s  climate emergency order calls for reducing greenhouse gas emissions by 45 percent from 1990 levels by 2035; ODOT is counting on fuel consumption that will produce greenhouse gas levels of 19.4 million tons in 2030; nearly 20 percent higher than in 1990, and 70 percent higher than the amount needed to be on track to meet the Governor’s stated goal.

    This department’s revenue forecast belies claims that any of the actions it’s hoping for, including electric vehicle adoption or more efficient internal combustion vehicles will do anything in the next decade to reduce Oregon’s transportation greenhouse gas emissions.

    ODOT predicts we’ll continue buying and burning 1.7 billion gallons of taxable motor fuel every year, through 2030.  This coupled with other transportation fuels, in turn, will produce 19.4 million tons of greenhouse gases annually through 2029.

    Here’s ODOT’s latest (April, 2021) forecast of quarterly taxable motor vehicle fuel sales.  (This doesn’t include sales of diesel fuel for large, over the road trucks which pay the state’s weight-mile tax).  As you can see, these quarterly figures show long term consumption of motor fuels stabilizing at a bit more than 440 million gallons per quarter (about 1,760 million gallons annually) through the remainder of the decade.

    Source:  Oregon Department of Transportation Revenue Forecast, April, 2021.

    Burning gasoline and diesel fuel translates directly into more greenhouse gas emissions. It’s very straightforward to estimate the greenhouse gas emissions that result from burning a gallon of gasoline.  Each gallon of gas, when burnt, produces 8.87 kilograms (almost 20 pounds) of CO2.  That means burning 1.75 billion gallons of gasoline will result in about 15.6 million metric tons of carbon dioxide (1,750,000,000 * 8.87).  Burning diesel fuels accounts for most of the rest of the 19.3 million in emissions (see further discussion of diesel fuel consumption, below).

    The continued burning of all this fossil fuel is completely inconsistent with Oregon’s stated climate goals. As illustrated by the green line in our first chart, Governor Brown’s Executive Order 20-04 implies a much more rapid and dramatic decline in greenhouse gases, and therefore, fossil fuel consumption. This same point has been made by the Oregon Global Warming Commission, which has sketched out the path to meeting the state’s 2050 goal of reducing greenhouse gases to no more than 20 percent of 1990 levels.  (See the yellow dashed lines).

    It’s worth noting, as we’ve pointed out before at City Observatory, that the most effective means of reducing gasoline consumption (and greenhouse gases) was higher fuel prices.  Fuel prices which rose steadily from 2004 through 2008, and which remained high until 2014, had the effect of reducing Oregon’s total gas consumption by almost 10 percent.  When gasoline prices plunged by almost 40 percent in 2014, following the collapse of global oil prices, Oregon’s gasoline consumption surged from about 400 million to about 470 million gallons per quarter (seasonally adjusted).  This was the principal reason that the state saw big increases in greenhouse gas emissions from transportation over this time period.

    Although it doesn’t explicitly say so, presumably these official ODOT forecast reflect the net effects of improving vehicle efficiency, increasing numbers of electric vehicles, and ODOT’s much vaunted “operational improvements” (i.e. electronic sign boards along highways).    What ODOT’s official revenue forecasts are telling us is that the agency fully expects us to be generating just as much greenhouse gases from driving in 2030 as we are today; indeed, the agency is counting on it, to pay its bills.

    If the agency seriously believed in its climate strategy, then it would be planning for and predicting a steady decline in gasoline consumption, as we adopted more efficient vehicles, electrified and “made every mile count.”  But as its financial projections make clear, the agency has no faith that any of these measures will make any substantive difference to gasoline consumption (and therefore, greenhouse gas emissions).

    Diesel Emissions

    And gasoline-based CO2 emissions are just part of the puzzle.  The ODOT taxable motor fuels forecast exclude diesel fuel burned by vehicle subject to Oregon’s weight-mile tax, which is applied to heavy over-the-road trucks. The Oregon Department of Environmental Quality reports that these sources represent about 23 percent of transportation greenhouse gas emissions:

    In addition to the health effects, combustion of diesel fuel is a significant source of greenhouse gas emissions. Transportation accounts for approximately 40 percent of all statewide greenhouse gas emissions in Oregon. This represents the largest source of emissions and a source that has seen increased emissions in recent years. While heavy-duty trucks and buses, which typically are fueled by diesel, only account for four percent of vehicles on the road nationally, they are responsible for nearly 25 percent of total transportation sector greenhouse gas emissions nationally, and 23 percent in Oregon. Emissions from trucks are one of the fastest growing sources of greenhouse gas emissions, and the number of truck miles traveled on the nation’s roads is projected to continue to grow significantly in the coming decades.

    In its 2018 inventory, DEQ estimates that burning distillate fuels (of which diesel is the bulk), account for about 7 million tons of greenhouse gases per year; equal to about 50 percent of the amount generated by burning gasoline in cars.

    ODOT also has a prediction for these weight-mile taxes, which suggests that they, too will not decrease materially between now and 2030.  That means that greenhouse gas emissions from diesel trucks will also not materially decline.  ODOT predicts that weight-mile transactions will stabilize at 2019 levels through 2025 and then increase thereafter (Figure 18).  In short, ODOT is saying that diesel truck emissions will likely remain at or above their current levels indefinitely.

    And, no EVs will not save the day; By 2030, only 3 percent of Oregon vehicles will be electric, according to ODOT

    The favorite dodge of highway apologists is to argue that electric vehicles will obviate the need to reduce driving at all.  Never mind that the production and operation of electric vehicles isn’t zero carbon, best estimates are that life-cycle emissions from building EVs and their batteries and charging them will produce about 30 to 50 percent of the emissions of greenhouse gases as cars.

    But ODOT doesn’t expect electric vehicles to be more than a token part of the fleet in the next decade. The agency’s October 2019 revenue forecast predicts the size and composition of Oregon’s light duty vehicle fleet through 2029.  They forecast that in 2029 Oregon will have about 3.9 million light duty vehicles, but only about 120,000 of them (total) will be electric vehicles.  That’s just 3 percent of the fleet; 97 percent will still be internal combustion engines.  The slow adoption of electric vehicles, as depicted in ODOT’s official revenue forecasts, means the agency believes that its efforts to promote EVs won’t have a significant effect on the state’s greenhouse gas emissions any time in the next decade, at least.

    There’s a naive and wrong-headed argument going around among highway apologists, arguing that they don’t need to worry about climate change because vehicle electrification will somehow solve the problem.  These data show that won’t happen fast enough, and in all likelihood won’t happen at all, as we continue to burn 1.7 billion gallons of taxable motor fuel a year in Oregon.

    Financial projections show ODOT’s real priorities:  More greenhouse gas pollution

    As Upton Sinclair observed, “It is difficult to get a man to understand something, when his salary depends on his not understanding it.”  What ODOT is saying, implicitly, is that their salaries depend on continued massive production of greenhouse gases.

    In simple financial terms, ODOT is counting on—is planning on—Oregonians not doing anything to significantly reduce their consumption of fossil fuels between now and 2030.  Its plans to pay for building new highways are based on the assumption that we reduce total fuel consumption by no more than a few percent in the next decade–at exactly the time when scientists (and our adopted climate plans) tell us we need to be making the most progress toward preventing climate catastrophe.

    There’s a striking contrast between the precise and hard-nosed projections of ODOT’s revenue forecast (they’re counting on us buying and burning 1.7 million gallons of taxable motor fuel every year through 2030), and the vague, PR-infused, fuzziness of Oregon DOT’s Climate Action Plan.  Part of this plan is an “Every Mile Counts” initiative, which, despite its name, doesn’t actually include any counts of vehicle miles traveled, any hard plans for reducing VMT, or any specific goals for 2030.  Instead, it’s just a vague exhortation to maybe, if you’d like, drive a bit less.  But there’s no serious plan to make that happen.

    If you read the fine print of the agency’s climate plan, it’s also clear that their real priority is getting more money and building more roads.  The climate plan contains no stated goal for reducing greenhouse gas emissions from transportation (or VMT), but does specify as goals, assuring the agency has plenty of revenue and can keep building roads.

    The agency’s real plan is reflected in its revenue forecast.  ODOT is planning to spend billions widening highways, and is counting on us to buy just as much fossil fuel through the next decade as we’re buying now.

    If you want to know what ODOT really cares about, and the future it’s really planning for, don’t be taken in by the gauzy and performative claims to care about climate, look at the agency’s financial plans.  Money talks, and at ODOT it’s effectively saying, “we’re going to do nothing to significantly reduce greenhouse gases in Oregon, and we’re going to keep spending money to widen roads and encourage people drive more.”

    Disobeying the Governor’s climate order

    Oregon DOT’s financial plans show that the agency has no intention of even trying to comply with Governor Kate Brown’s Climate Emergency Order.

    In 2020, the Governor ordered state agencies, including ODOT, to develop plans to reduce emissions to 45 percent below 1990 levels by 2035.  According to DEQ, Oregon’s 1990  greenhouse gas emissions from transportation fuel consumption were 16.1 million tons.  That implies that by 2035, the state’s total emissions from transportation fuels should be no higher than roughly (.55 * 16.1) 8.9 million tons.  The pathway or glide slope required to reach that level of emissions requires roughly a 4.9 percent annual decrease in from 2018 through 2029.  This glide slope implies that in 2029, emissions would need to be just under 12 million tons to be on track to meet the 2035 goal.

    ODOT’s forecast makes it clear that through 2029, emissions from light duty cars and trucks (not to mention all other sources of transportation emissions, such as railroads, ships and aircraft) will be 60 percent greater than that amount—19.3 million tons.

    Section 4(c)(2) of the executive order makes it clear that the 45 percent reduction applies separately to transportation fuels (e.g. gasoline and diesel fuel); the Department of Environmental Quality is directed to come up with rules that will achieve these reductions separately for transportation fuels.  Agencies like ODOT can’t claim that they’ll be able to pollute more because other sectors of the economy will somehow make even larger reductions in greenhouse gas emissions.

    In effect, ODOT is keeping two sets of books:  Except that one set of books, doesn’t actually have any hard information, just vague and unverifiable claims about values and a lot of noble intent.  The real books—the ones with dollars and cents—and millions and millions of tons of greenhouse gases locked-in—are hidden in plain sight.  And the agency’s climate plans make no mention of how inconsistent the agency’s real financial plan is with its purported climate goals.  It’s a fraud and deception, pure and simple.

    Appendix:  Transportation Fuels and Greenhouse Gases in Oregon

    As noted, Oregon DOT forecasts taxable motor fuels sold and weight-mile transactions (a proxy for total weight mile truck volume) through 2029.  Motor fuels, when burned, produce greenhouse gases.

    We’ve estimated average transportation emissions from gasoline and diesel in Oregon based on the historic relationship between the ODOT taxable motor fuels volume estimate and the DEQ annual transportation sector greenhouse gas estimate for on road gasoline and diesel fuel consumption.  On average,between 2004 and 2019, the consumption of 1,000 gallons of taxable motor fuel (as estimated by ODOT) was associated with an estimated 11.07 metric tons of transportation fuel carbon dioxide (as estimated by DEQ).  We apply this relationship to ODOT’s 2021-2029 projections to estimate greenhouse gases associated with transportation fuel consumption.

    These figures likely underestimate CO2 emissions, inasmuch as ODOT projects weight-mile activity and associated diesel heavy truck emissions to increase faster than taxable motor fuels activity through 2029.  In addition, it’s worth noting that the DEQ sector estimates are considerably lower than those used in the evaluation of Oregon’s Clean Fuels Program (CFP).  The CFP requires that gasoline and diesel fuel in Oregon be blended with ethanol and biodiesel to reduce the total carbon content of fuels burnt.  The methodology used to calculate emissions under the CFP is a “well-to-wheels” metric, that counts all of the carbon emissions associated with production, refining and transport, as well as combustion, as opposed to the EPA factor which is a “tank to wheels” metric, counting just the carbon from combustion.  The CFP well-to-wheels emission factor is about 12.3 kilos of carbon per gallon of conventional gasoline, compared to the EPA “tank-to-wheels” emission factor of 8.78 kilos of carbon per gallon of conventional gasoline.  If the “well-to-wheels” approach is actually correct, this may mean that current estimates used by DEQ in its sector inventory substantially understate the relative contribution of transportation fuels to Oregon’s greenhouse gas emissions.

    ODOT’s forecast only explicitly included taxable motor fuel sales, i.e. gasoline and diesel fuel used to power cars and light and medium sized trucks.  Sales of diesel fuel to larger over the road trucks is exempt from this tax, as these trucks pay the weight-mile tax instead.

    The Oregon Office of Economic Analysis computes the carbon intensity of gasoline and diesel sold in Oregon under the Clean Fuels program.  It estimates that the total net effect of the program has been (which blends 10 percent ethanol with conventional gasoline, and a similar amount of biodiesel with conventional diesel), is to reduce greenhouse gas emissions from fuel consumption by an aggregate of about 5 percent, based on a “well-to-wheels” analysis.  The potential for increasing biofuels is limited; nearly 90 percent of gas-powered vehicles on the road today can only burn a maximum of ten percent ethanol.  Increasing ethanol production would have serious negative environmental impacts.

    ODOT forecasts that taxable motor fuel sales in 2029 will be 1,751 million gallons.  That’s slightly more than the average fuel consumption for the years 2004 through 2019 (about 1,723 million gallons per year).  DEQ estimates that total transportation emissions from motor gasoline and distillate fuel (chiefly diesel) were about 19.6 million tons in 2019, about 22 percent above their 1990 level of 16.1 million tons.  The following chart shows estimated carbon emissions from motor gasoline and diesel fuel in Oregon, grown at the rate of increase of taxable motor fuel sales, for the period 2021 through 2029, per the ODOT Forecast.

    Editor’s Note:  Thanks to Daniel Porter of ODOT and Michael Kennedy of OEA for sharing in spreadsheet form the data contained in their estimates.  This commentary revised on December 13 to correct a the percentage by which estimated 2029 emissions will exceed the amount needed to achieve the reductions called for in Governor Brown’s Executive Order.

    Welcome to Portland Secretary Pete! Now about the Rose Quarter Freeway

    Transportation Secretary Pete Buttigieg is visiting Oregon to learn more about local transportation issues. The local advocacy group No More Freeways has sent him an open letter to provide some background for his visit.

    Here’s what Transportation Secretary Pete Buttigieg needs to know about Oregon DOT’s proposed $800 million neighborhood-wrecking, climate-destroying I-5 Rose Quarter Freeway widening project.

    Under Buttigieg’s leadership, USDOT has set a new direction for US transportation policy.  He’s explicitly acknowledged the role that federally directed and supported freeway building played in destroying urban neighborhoods, especially neighborhoods of color.  And he’s called for measures to explicitly offset the damage done and restore those places.  The new administration is taking a decidedly different direction, telling TXDOT to call a timeout on its plans to widen I-45 through Houston, over concerns about civil rights.

    This letter from No More Freeways tells how Portland’s freeway fight intersects with the key agenda items of the Biden Administration:  promoting equity and taking climate change seriously.


    Burn, baby, burn: ODOT’s climate strategy

    The Oregon Department of Transportation is in complete denial about climate change

    Oregon DOT has drafted a so-called “Climate Action Plan” that is merely perfunctory and performative busywork.

    The devastation of climate change is now blindingly manifest.  Last month, temperatures in Oregon’s capital Salem, hit 117 degrees.  The state is locked in drought, and already facing more wildfires, on top of last year’s devastating fire season.  Cities across the nation are swathed in the smoke from Western wildfires—largest among them Oregon’s Bootleg fire—and are daily witnessing orange-tinged sunsets.

    Earth Observatory, July 2021.

    All this is plainly due to climate change, and in Oregon, transportation is the leading source of greenhouse gases.

    If there were every a time to change direction on climate, this would be it.  But plainly, the Oregon Department of Transportation is locked on cruise control, moving ahead with plans inspired by the dreams of the 1950s rather than the increasingly grim reality of the the 2050s.

    ODOT’s climate denialism

    While the Oregon Department of Transportation mouths the words of climate awareness, the substance of its plans make it clear that it is engaged in cynical climate denialism.  Its State Transportation Strategy (STS)—which claims to address state greenhouse gas reduction goals, never acknowledges that Oregon is failing to reduce greenhouse gases as mandated by law because of increased driving.

    In Oregon, transportation, and specifically driving, is the largest single source of greenhouse gas emissions, contributing 40 percent of statewide greenhouse gases.  And while we’ve made some progress cleaning electricity generation and reducing industrial emissions, transportation greenhouse gases are increasing, up 1,000 pounds per person annually in the Portland metropolitan area over just the last five years

    To date, Oregon’s and ODOT’s plans to reduce transportation greenhouse gases have amounted to less than nothing.  According to DEQ statistics, driving related greenhouse gases are were 25 percent above 1990 levels in 2018.  Given the state’s objective of reducing greenhouse gas emissions 10 percent below 1990 levels by 2020 (and 80 percent below 1990 levels by 2050), we’re headed in exactly the wrong direction.

    In the face of this epic failure to make progress, and in the wake of the most extreme weather ever recorded, ODOT is proposing to actually make the problem worse by spending billions widened Portland area freeways, and going deeply into debt to do so, as we discussed earlier.

    As the Oregon Environmental Council and 20 other local environmental organizations wrote to the Oregon Transportation Commission:

    Transportation-related emissions make up nearly 40% of Oregon’s total greenhouse gas emissions and continue to steadily increase. The investments that ODOT has made to address climate, while valuable, are profoundly insufficient given the scale and urgency with which we must reduce emissions to avert the worst of the grim and chaotic future we are already experiencing.

    ODOT’s “climate action plan”:  Cynical, meaningless and wrong

    In theory, the Oregon Department of Transportation is going to combat climate change through  is a five-year climate action plan, which is supposed to represent the agency’s response to a call from Governor Brown to take climate more seriously.  It’s a sketchy and vague grab-bag of piecemeal and largely performative actions, packaged along with some deceptive claims about transportation’s contribution to climate change.  And its policies make it clear that the agency is principally concerned with continuing to build more roads, and get ever larger budgets.

    A fig leaf for business as usual

    Appropriately, the plan’s signature  graphic element is a single leaf—a fig-leaf as it were— superimposed over an outline of the map of Oregon. Never has an info-graphic been more appropriate:  this document is fig-leaf covering what would be, upon any closer inspection, an obscene document.


    ODOT’s climate plan has no measurable goals and no accountability

    ODOT is a staffed by engineers, so you might think they’d have some actual quantitative measures of the problem they face, and the impact of the steps they’re proposing.  his a remarkable plan which contains no statement of the problem in terms of quantities of greenhouse gases emitted, no goal for their reduction (to 25 percent of 1990 levels by 2050, as mandated by law), and no evidence that individually or collectively the measures described in the plan will have any quantitative effect on greenhouse gas emissions whatsoever.  It’s merely a perfunctory checklist of actions, which once taken, will absolve ODOT of any further responsibility to worry about climate issues.  There’s simply no accountability for any reduction in greenhouse gases.

    The lack of accountability is apparent in the framing of the document; there’s no acknowledgement that transportation greenhouse gas emissions have gotten worse since the development of ODOT’s first climate fig-leaf, it’s “Sustainable  Transportation Strategy” eight years ago.

    Reducing GHG’s isn’t a priority:  Getting more money for ODOT is

    Climate may be in the title, but the substance of the plan is really about ODOT’s 1950s era highway-building values.  It’s clear from the get-go that this strategy actually isn’t interested in reducing greenhouse gases.  The document states clearly it has three main priorities (pages 7-8):  promoting equity, building the transportation system, and assuring ODOT has enough money.  Reducing greenhouse gases didn’t even make the list.

    It’s worth noting that with equity, as with climate, there are no measurable objectives.  It’s just lip service from an agency that has repeatedly pushed city destroying highways through minority neighborhoods, and which plans to atone for this damage by making the highways even wider.

    Pricing is a source of revenue, not a means to manage demand or reduce climate pollution

    Potentially, pricing could have a major impact on greenhouse gas emissions.  Fuel consumption and greenhouse gas emissions actually did decrease through 2014 when gas prices were high. But ODOT has no plans to using pricing to achieve climate objectives. The plan mentions pricing, but only to pay for more roads; there’s no commitment to use pricing to reduce greenhouse gases, vehicle miles of travel or traffic congestion.  The only stated policy concern is generating enough revenue to fund ODOT construction projects,

    “Pricing:  Price the transportation system appropriately to recover the full costs to maintain and operate the system.”

    The plan contains no provisions to reflect price of environmental damage back to system users—ODOT wants to get paid to build more roads, but resists having it or highway users pay for the damage their emissions cause.  As we’ve noted, ODOT backed off from pricing based in part on its consultations with avowed climate change deniers it appointed to its “stakeholder” group.

    Falsely claims making traffic move faster will reduce emissions

    The strategy repeats a false claim that Oregon DOT can reduce emissions by making traffic move faster.  One of the plan’s action items is “System efficiency” which it defines as

    “. . . improve the efficiency of the existing system to reduce congestion and vehicle emissions.”

    What this really means, in practice, is that ODOT spends more money on elaborate computers, variable advisory speed signs and signboards that show estimated travel times on some highways.  None of these so called “intelligent transportation systems” have been demonstrated to measurably reduce either congestion or greenhouse gases.  Moreover, to the extent they do lower congestion, they induce additional travel demand, and the scientific literature has shown that increased travel more than wipes out any emission reductions from improved traffic flow.  This is precisely the false set of claims that ODOT conceded it made to the Legislature in 2015 when it lied about estimates of emission reductions from these “system efficiency projects.”

    It’s “climate lens” is really an eye-patch, turning a blind eye to induced demand

    The climate plan says a “climate lens” will be applied to the State Transportation Improvement Program (TIP) projects, but is silent on the application of any such standard to megaprojects like  the I-5 Rose Quarter project, the revived Columbia River Crossing or any of the billions in other proposed Portland area freeway widening projects.  The induced demand calculator developed by the University of California Davis from the best available science shows these kinds of freeway widening projects will produce hundreds of thousands of tons of additional greenhouse gas emissions.

    The so-called “climate lens” is simply a glib PR talking point that has no impact or meaning. If you were at all serious about climate, a real climate test would have the agency put on hold all additions to state highway capacity.

    The climate plan reiterates a discredited claim that greenhouse gases can be reduced by widening roads and making traffic move faster, something that’s been shown scientifically to induce more driving and pollution.

    Technocratic climate denialism

    Future generations, enduring the brunt of increasingly intolerable summers and extreme weather, seeing Oregon’s forests and natural beauty decimated by climate change will look back to the decisions ODOT is making now and ask how it could simply ignore this problem, ignore the demonstrated science about its causes, and then commit literally billions of dollars to make it worse, dollars that future generations will be forced to repay.

    This may seem like a simple, routine technical matter.  It’s not.  Its an irrevocable commitment to burn our state, to cower in ignorance in the face of an existential challenge, and an effort to cling to an outdated ideology that created this problem.


    It’s back, and it’s even dumber than ever: The Urban Mobility Report

    There was an unprecedented decline in traffic congestion in the US last year.  According to the Urban Mobility Report, there’s essentially nothing we can learn from this experience

    The Texas Transportation Institute has always been apologists and propagandists for the highway lobby

    TTI reports fail the basic scientific test of responding to repeated detailed critiques of methodology, measures and findings

    Every year (or so), the Texas Transportation Institute generates something called the “Urban Mobility Report,” which is a dire lamentation on the supposed costs that urban traffic congestion imposes on Americans.

    This past week, they’ve issued their latest report, covering 2020.  As everyone knows, the Covid-19 pandemic produced an instant and abrupt change in US travel patterns.  And that’s noted in the latest UMR.  Their measure of congestion—which, as we’ll explain in a minute, is deeply flawed and biased—actually showed a epic decline in congestion costs in 2020.  So far, so good. But wait.

    Now, for scientists and the intellectually curious, you would think that actually experiencing a dramatic decline in traffic congestion would be, if not a cause for celebration, at least an opportunity to better understand the dynamics of the problem they’re purportedly concerned with solving.

    Here’s the big, salient fact about traffic in 2020:  Travel declined by about 15-20 percent, but congestion—as measured by TTI—fell by about half. Here’s the data on quarterly travel volumes in 2020 compared to the previous year.  In the second half of the year, travel was down about 15-20 percent.

    While travel went down a bit, traffic congestion went down a lot.  Even in the second half of the year, as travel had rebounded, traffic congestion, measured here by TTI’s own estimate of hours of delay, was down 40 to 50 percent from 2019 levels.

    As we’ve stressed at City Observatory, this non-linearity (a small decline in travel produces a big decline in congestion) is the most important insight we can have about how to deal with traffic.  In Portland, during the height of the pandemic-fueled travel reductions, the city’s major freeways carried more cars at the rush hour, at higher speeds, because traffic levels were kept below the tipping point that causes cascading delays.

    Traffic congestion is a demand problem:  too much demand at certain times, specifically peak hours.  If we can reduce demand, or shift travel to off-peak times, we can dramatically reduce congestion.  We have traffic congestion because we don’t price roads; we don’t systematically reflect back to users the costs their travel decisions impose on others.

    The only effective solutions to traffic congestion involve congestion pricing, but “pricing” is one word you won’t find anywhere in the 2021 Urban Mobility Report.  The word “toll” appears exactly once.

    TTI has never grasped the fundamental economics of traffic congestion.  They’ve always pretended that the transportation system can be run as if every day was free ice cream day at Ben and Jerry’s.  If you don’t charge users for your product, you get lines around the block and you’re always running short of money.

    The real lesson of the pandemic, if we recognize it, is that measures to alter travel demand, especially ones that incorporate real time pricing, can re-shape demand in ways that reduce congestion.  In fact, evidence from the pandemic shows that avoiding over-loading roads at peak hours can maintain consistent high travel speeds and higher levels of vehicle throughout.

    However, if you read the TTI report, you’ll never learn any of that. Instead, what you’ll hear is that when the pandemic abates, the world of transportation will trend back toward increased traffic and congestion, and well, we’ll just have to build more capacity to accommodate it.

    Add capacity in critical corridors — We just need “more” in some places. Increases in freight and person movement often require new or expanded facilities. Important corridors or growing regions can benefit from more street and highway lanes, new or expanded public transportation facilities, and larger bus and rail fleets.

    That’s TTI doing what it has always done:  providing a rationalization for ever more highways in the name of trying—counterproductively, as it turns out—to reduce congestion.

    Flawed, biased and unscientific

    Though it has been produced for decades, the Texas Transportation Institute’s Urban Mobility Report is essentially propaganda for road-building, not a critical analysis of transportation policy.  It is designed to generate heat, not shed light.  We and others have repeatedly refuted and debunked the methodology, metrics, and findings in this and prior TTI reports.  Some of the highlights:

    • Its core measure of delay, the “travel time index” ignores the distance of trips across metro areas, and incorrectly penalizes cities with compact development and shorter trips, while rewarding sprawling metros with very long commutes.
    • Claims that congestion imposes net costs on travelers is based on the false assumption that enough highway capacity could be constructed so that peak hour travel was never slower than off-peak hour travel.
    • The first three decades of the report’s congestion estimates are based on a flawed and unscientific extrapolation of speed-volume tables, and are inconsistent with other measures of actual travel time.  The report presents as a single time series estimates made using wildly varying methodologies.
    • As Victoria Transportation Policy Institute’s Todd Litman has shown, the report’s authors have repeatedly failed to respond to thorough and well-researched critiques of their methodology.

    Our experiences with a very changed transportation system during the Covid-19 pandemic could have been (and could still be) a powerful learning moment as to how to build more just, sustainable and efficient cities.  We observed that reducing transportation demand can greatly improve the function of the transportation system, reducing congestion and travel times, and improving air quality.  Greater emphasis on walking, biking, and repurposing public space for people instead of car movement and car storage can make our cities better places to live, rather than merely easier to drive through.  Alas, these are lessons that will never be learned by anyone who places any credence in the Urban Mobility Report.

    Lower interest rates = More expensive homes

    The decline in interest rates in 2020 is a huge factor in explaining the recent surge in home prices.

    Population growth, a key driver of housing demand, actually slowed dramatically in the past year.

    The current surge in home prices may be a short-term phenomenon.

    We’re constantly being told that the housing market is hot, and that the US is facing a housing shortage. There’s no denying that home prices have risen sharply in the past year.  The broad-based S&P Core-Logic Case-Shiller index records that the average home price has jumped 14.6 percent in the past year, the fastest increase in three decades (a period that includes the housing bubble of the mid-aughts.

    Case Shiller Home Price Index (via Calculated Risk)


    Since most buyers finance their homes with long-term mortgages (plus equity from a current home, if they own one), mortgage interest rates have a profound effect on how much people can afford to pay for housing.  When mortgage rates go down, a family can afford to borrow a larger amount of money for any given level of monthly payments they can afford.  Since the Covid-19 recession, interest rates, including mortgage interest rates have fallen sharply.

    Here’s the typical rate on a 30-year fixed residential mortgage.  For the past two years, mortgage rates have been declining, and since the start of the Covid-19 recession, have plummeted to the lowest levels seen in decades.

    On January 2, 2020, the average mortgage rate was about 3.7 percent.  Just a year later, on January 7 of 2021, the interest rate stood a full percentage point (100 basis points in financial speak) lower, at just about 2.7 percent.  That change makes a big difference to how much homes people can afford based on their income.

    For example, if you were financing a $300,000 mortgage in 2020 at 3.7 percent, your monthly payments would be about 1,380.  Here’s a mortgage calculator.

    But a year later, in 2021, if you could still afford a $1,380 monthly payment, at the new lower 2.7 percent interest rate, you would now be able to swing a $340,000 mortgage.

    That $40,000 increase works out to a 13.3 percent increase in the amount you could borrow, roughly in the same ballpark as the increase in home prices over the past year.  (Our simple calculation here overlooks some important details, such as needing a larger down payment for a bigger mortgage, but between government stimulus payments and big reductions in household outlays for travel, entertainment, services caused by Covid restrictions, many households saw big gains in savings during the pandemic).

    It’s not population growth

    Historically, one of the biggest and most easily predictable drivers of housing markets is population growth.  But thanks to direct and indirect effects of the pandemic, national population growth has fallen dramatically.  Economist Tom Lawler estimates 2020 population growth fell to 0.22 percent from a 21st Century average of about 0.72 percent.  That decline is due both to an increased death rate and subdued international in-migration.

    Housing markets are big and complex, and there are many reasons why prices have risen so sharply in the past year.  But clearly one of the big factors has been the declining cost of borrowing.  Going forward the impetus to home price inflation from the recent decline in interest rates should wane (assuming mortgage interest rates don’t continue to decline at the same pace in the next year or so).  If the decline in mortgage rates is largely over, stable or increasing mortgage interest rates should actually help dampen future home price increases.

    But as we all learned in the housing bubble, home price movements can become disconnected from fundamentals, and be driven by expectations of future increases.  One of the troubles with housing is that homeowners are in many respects speculators, and most buyers are purchasing a new home based in part on the growth in value of a previous home.  The current dramatic spike in home prices seems to be propelled by some short term factors, most notably the decline in interest rates.  We’ll all want to watch closely to see what happens in the months ahead.


    The Bum’s Rush

    The $800 million project transitions from “nothing has been decided” to “nothing can be changed”

    There’s a kind of calculated phase-shift in the way transportation department’s talk about major projects.  For a long, long time, they’ll respond to any challenges or questions by claiming that “nothing has been decided” or that a project is still being designed, that its in its infancy, and that objections will be dealt with . . . at some point in the indefinite future.

    But then, a magic moment occurs, with no notice or observable event, and they’ll suddenly proclaim that it’s too late to raise and questions or consider any changes.

    That’s exactly what’s happened with the Oregon Department of Transportation’s $800 million I-5 Rose Quarter project in the past few weeks.

    You’ve got concerns?  Not to worry, nothing’s been decided

    As recently as last fall, ODOT’s Director of Urban Mobility, Brendan Finn was telling OPB’s Think Out Loud host Dave Miller, the project is only 15 percent designed, and that there was lots of opportunity for the community to shape the project:

    Well, the project is still pretty much in its infancy, it’s only being at 15 percent design.  I don’t clearly remember the exact verbiage as far as that.  The House Bill that was passed that created the Rose Quarter project, HB 2017, did have certain parameters in it that were expected from the Legislature, and that was one of them.  That said, there is almost an amazing opportunity here to connect neighborhoods and to provide not only multi-modal options, but  community connections.  And for us, making this move right now is signaling to the community . . . especially . . . those who have left the process, that we are willing to do things differently, we are ready to change, we are ready to be deliberative about our commitment to our shared values around restorative justice.

    And very publicly at that time, ODOT convened an “Historic Albina Advisory Board “(after blowing up two other efforts at community engagement) and spent several million dollars hiring a team of consultants to conduct an independent highway cover assessment.  ODOT hired a multi-million dollar team of consultants to undertake an independent analysis of the freeway covers, undertaking both a technical analysis, and seeking public opinion.  This work developed a series of alternatives that vary considerably from the proposal being designed by ODOT—devoting more space to housing  and better reconnecting the urban street grid, and moving freeway on and off ramps away from the center of project.

    According to ZGF: Oregon DOT’s plan for the Rose Quarter produced irregular parcels that would be “challenging to develop” and create a complex, unintuitive street system.

    This process is proceeding according to the timeline ODOT announced when it appointed this new board last year.  In May, consultants presented their analysis and recommendations to the Historic Albina Advisory Board and the project’s steering committee.  Their alternatives, included two that rate much higher technically, and in community support, and which would significantly re-design the project.

    Sorry, time’s up: Too late to make any changes

    Now, ODOT says, it’s simply too late to think about doing anything different than what the agency first planned.

    The community has been pushing for buildable covers for years, and now ODOT says, that any consideration of covers will create unacceptable further delays.  Last week, in response to support by Oregon’s two Senators and local Congressman for buildable covers, ODOT said it was basically too late to think about doing that, according to the Portland Mercury:

    A spokesperson for ODOT told the Mercury that while getting the cost of the caps fully funded by federal dollars would be “a dream,” there are still other obstacles to consider when building more substantial freeway caps. In order to build caps capable of supporting five-story buildings, the caps would need larger support pillars on either side of the freeway to ensure that there is enough structural strength to support the buildings.

    “That could mean further acquisitions of land in the area, potentially displacing businesses,” said April deLeon, an ODOT spokesperson.

    According to deLeon, changing the design of the caps now could also add time delays. The Federal Highway Administration would need to approve the new cap design, but would be under no timeline to do so. That time delay could make the project more expensive due to the cost of inflation.

    It’s also worth noting that ODOT’s own consultants have said that buildable covers would be much more economical, if only ODOT would narrow the overly wide project to just the two additional lanes it says it needs, and built shoulders comparable to other urban freeway projects.  According to ODOT, it will build stronger covers only if it gets to condemn other people’s land, not if it has to give up any of the monstrously oversized roadway it intends to built (and then to re-stripe into a ten-lane freeway).

    ODOT’s reflexive claim that its too late, and too costly to even consider buildable caps shows that their claims of interest in “restorative justice” are just a sham.  What the really want to do is build a wider freeway, and they’ll engage in whatever performative theatre they think is needed to convince people they care

    Kudos to OPB’s Dave Miller for asking hard questions last fall:  But what the media generally fails to do is follow the thread and insist on accountability.  At what point did the project go from “infancy” to unchangeable?  Who made that decision?  Deus ex machina is a great literary device, but it’s no way to run a government.

    More proof of ODOT’s Rose Quarter Freeway coverup

    Newly revealed documents show its roadway is vastly wider than needed for traffic, and also makes “buildable” freeway covers prohibitively expensive

    If you really want just two additional lanes, you can do so much more cheaply and with less environmental destruction

    The reality is ODOT is planning a 10 lane freeway at the Rose Quarter, and is lying about the covers and the project’s real cost and environmental impact

    For years, the Oregon Department of Transportation has been lying about the freeway widening project it plans for a mile long stretch of I-5 at Portland’s Rose Quarter.  While it’s advertised as just adding a couple of so-called “auxiliary” lanes, we and others have uncovered multiple documents showing that they’re actually planning a 150-foot to 160-foot roadway, wide enough for a ten lane freeway.

    The latest confirmation of ODOT’s big lie comes from a report prepared by one of the agency’s own consultants, ARUP Associates  ARUP pointed out the obvious:  If you really want to just add two lanes to the existing 82 foot wide pavement, you certainly don’t need two double the size of the roadway.  In an article published by Willamette Week, ARUP says:

    “The most significant driver of project cost (initial construction cost as well as ongoing maintenance and life-cycle costs), right-of-way impacts, and development potential on and adjacent to the covers is the cross-section width,” the draft report states, laying out various technical approaches used in other states.”We believe these options can be considered to reduce the tunnel width so as to minimize construction cost and impact to the adjacent properties.”

    The ARUP report shows the Rose Quarter project could be much smaller, cheaper, and less environmentally destructive.  ARUP recommends interior shoulders of 3 to 8 feet (instead of 12); exterior shoulders of 10 feet (instead of 12), and lanes of 11 or 12 feet (instead of only 12).

    ODOT claims that part of the reason for such a wide right of way is to accommodate “full” shoulders.  But ARUP’s report puts the lie to that claim.  It notes that nowhere in expensive urban freeway rebuilding projects does anyone build 12-foot inside shoulders.  Willamette Week reports:

    . . . no comparable highway project in any other city includes the 12-foot inner shoulder lanes that ODOT has included in this project. (According the report, Presidio Parkway in San Francisco has 4 feet, the I-93 Central Artery in Boston has zero feet, and the Alaskan Way tunnel in Seattle has 2 feet.)

    Not only that, even for this project, ODOT doesn’t think 12-foot shoulders are necessary.  On the project’s viaduct section, at the Southern end of the project, ODOT is proposing to add a freeway lane (including re-striping freeway lanes to 11 feet in width), and shoulders of 3 to 9 feet.  ODOT’s own analysis shows these narrower shoulders and lanes have a trivial impact on safety compared to a wider and more expensive project.

    As we’ve maintained for several years, the real reason ODOT is planning a massive roadway with oversized shoulders is because it plans to simply re-stripe the road for additional lanes as soon as the project is built, something that could be accomplished in an afternoon with a few gallons of highway paint.  It’s a blatant attempt to evade any environmental analysis of the traffic, noise, air pollution, and greenhouse gas emissions that would be associated with building a 10 lane freeway, and is violation of the National Environmental Policy Act.

    Blowing up the covers

    ODOT has attempted to woke-wash this project by claiming that the construction of a highway cover (really slightly enlarged overpasses) will help repair the damage the original construction of Interstate 5 did to the Albina neighborhood in the 1960s and 1970s.  While they’ve claimed that the covers might be used for a variety of purposes, their own consultants have concluded that the current project design creates a human- and pedestrian hostile environment that’s inimical to neighborhood restoration.

    The new ARUP documents make it clear that the vastly oversized roadway also makes covers much more expensive, and and in particular, makes constructing covers that could support multi-story buildings prohibitively expensive.  According to Willamette Week, project documents now show the covers construction could cost $500 million, and would cost an additional $200 million if build strong enough to support an 5-story building.

    The draft Constructability and Cost Analysis Report for the Rose Quarter Independent Cover Assessment, dated June 2, estimates covering the highway would cost more than $500 million. Covers that could support five-story buildings would cost roughly $200 million more, depending on which design ODOT proceeds with.

    The freeway covers have always been a transparent and disingenuous ploy to cloak this project as a vehicle of neighborhood restoration.  ODOT has not committed any funds to real reparations, in particular rebuilding any of the hundreds of houses iti demolished for highway construction in the 1950s, 1960s and 1970s  Other state highway departments have used highway funds to build housing to undo the damage of past freeway building projects, but not Oregon DOT.  If it actually cared about restoring the neighborhood, ODOT would be talking about the narrowest possible freeway, and providing more money for housing and restoring the neighborhood.  Or it could study removing the freeway entirely.  All of the glib talk about covering a vastly wider freeway, is really just a fig leaf for a deeply flawed project.

    How highways finally crushed Black Tulsa

    Tulsa’s Greenwood neighborhood survived the 1921 race massacre, only to be ultimately destroyed by a more unrelenting foe: Interstate highways

    Black Tulsans quickly rebuilt Greenwood in the 1920s, and it flourished for decades, but was ultimately done in by freeway construction and urban renewal

    Even now, Tulsa has money for more road widening, but apparently nothing for reparations.

    The past week has marked the Centennial of the Tulsa Race Massacre, when hundreds of Black residents of Tulsa’s Greenwood neighborhood were brutally killed and the neighborhood, Greenwood, was leveled.  Recent news stories have made more Americans aware of this tragic chapter of our history than unfolded in May 1921:  Greenwood’s residents were shot and beaten, their homes and businesses burned and their neighborhood bombed.

    What’s less known is that despite the best efforts of the violent racists, they didn’t kill Greenwood.  In fact, the neighborhood’s Black residents returned and rebuilt, in less than five years.  The rapid rebuilding, in spite of the obstacles put in its place by the City of Tulsa, and continued racial discrimination grew praise for the neighborhood’s  resilience.  In 1926, W.E.B. Dubois wrote “Black Tulsa is a happy city,“ saying:

    Five little years ago, fire and blood and robbery leveled it to the ground. Scars are there, but the city is impudent and noisy. It believes in itself. Thank God for the grit of Black Tulsa.”

    Rebuilt and thriving Greenwood in North Tulsa, 1930s.

    Greenwood’s heyday stretched into the 1950s, and even its moniker–The Black Wall Street–dates from this period, and not before the massacre.

    What finally killed Greenwood wasn’t an angry racist mob:  it was the federally funded Interstate highway system.  Coupled with urban renewal, highways built through North Tulsa’s Greenwood neighborhood in the late 1960’s did what the Klan and white racists couldn’t do:  demolish the and depopulate the place.  That’s the key conclusion of a newly published book by Carlos Moreno, which chronicles the neighborhood’s destruction, re-birth and ultimate demise at the hands of the highway builders.  NBC News interviewed Moreno, and reported:

    In his new book set to be released next week, “The Victory of Greenwood,” Moreno explores how the neighborhood had a second renaissance led by Black Tulsans after the massacre, rebuilding even bigger than before. It was not the bloodshed that eventually destroyed most of Greenwood, however; rather, it was this, he said, pointing to the spaghetti of interchanges to the south and the expressway that stretches north.

    Carlos Moreno & the freeway that finally crushed Greenwood (NBC News)

    In an essay at Next City, Moreno explains:

    What often gets erased from Greenwood’s history is its 45 years of prosperity after the massacre and the events that led to Greenwood’s second destruction: The Federal-Aid Highway Acts of 1965 and 1968. As early as 1957, Tulsa’s Comprehensive Plan included creating a ring road (locally dubbed the Inner-Dispersal Loop, or IDL); a tangle of four highways encircling the downtown area. The north (I-244) and east (U.S. 75) sections of the IDL were designed to replace the dense, diverse, mixed-use, mixed-income, pedestrian, and transit-oriented Greenwood and Kendall-Whittier neighborhoods.

    As in so many other US cities, the construction of freeways was used to demolish, divide and isolate communities of color.  President Biden acknowledged the federal government’s role in Greenwood’s decline in his proclamation of a Day of Remembrance:

    And in later decades, Federal investment, including Federal highway construction, tore down and cut off parts of the community. The attack on Black families and Black wealth in Greenwood persisted across generations.

    At a community conversation sponsored by Tulsa Urbanists, Moreno summarized his research on the role of the 1921 race massacre and later highway building and urban renewal efforts in destroying Greenwood:

    Greenwood looks the way it does today, not because of the massacre.  It came back. And there’s a video footage of that. But North Tulsa/Greenwood look the way it does today because of the federal highway project, and because of urban renewal . . .

    And Tulsa continues to widen highways even as it refuses to discuss reparations for the destruction of Greenwood.  Again, Moreno:

    Somehow it’s okay for Tulsa to pay $36 million to repair one mile of road between 81st and 91st on Yale in South Tulsa, like that’s okay. We have no problems doing that. We just passed a road widening bill and every single citizen of Tulsa is paying a part of that $36 million. But somehow reparations for Greenwood is a non starter . . .

    A hat tip to Next City for publishing Carlos Moreno’s synopsis of his book and Graham Lee Brewer of NBC News his reporting of how the highway’s wounds still trouble Greenwood to this day.

    It’s hard to imagine anything more hateful and horrific than the bloody attack on Greenwood in May, 1921.  In the past century, that kind of violent overt racism has given way to a more subtle, more pernicious and more devastating  kind of systemic or institutional racism, in the form of highway construction.

    State DOTs can and should build housing to mitigate highway impacts

    If OregonDOT is serious about “restorative justice” it should mitigate  highway damage by building housing

    Around the country, states are subsidizing affordable housing to mitigate the damage done by highway projects

    Mitigation is part of NEPA requirements and complying with federal Environmental Justice policy

    The construction of urban highways has devastating effects on nearby neighborhoods.  Not only has building highways directly led to housing demolitions to provide space for roadways, the surge of traffic typically undermines the desirability of nearby homes and neighborhoods, leading to the depreciation of home values, the decline of neighborhood economic health, and population out-migration.  That story has been told numerous times across the US; we’ve detailed how the Oregon Department of Transportation’s decisions to build three huge highway projects in the 1950s, 1960s and 1970s decimated Portland’s Albina neighborhood.  This predominantly Black neighborhood lost two-thirds of its population over the course of a little more than two decades. At the time, no one gave much thought to the loss of hundreds or thousands of housing units, or the effect on these neighborhoods.  But increasingly, state highway agencies are looking to mitigate the negative effect of current and past highway construction by subsidizing housing in affected neighborhoods.  Here are three examples from around the country.

    The Oregon Department of Transportation claims that it is interested in “restorative justice” for the Albina community, which has identified housing as one of the keys to building wealth and restoring the neighborhood.  And ODOT’s project illustrations show how hundreds of housing units might be built near the project–but these are just vaporaware, as ODOT hasn’t committed to spending a dime of its money to making that happen, to replacing the homes it demolished over the decades.  Based on the past and current experience of other states, there’s no reason that they can’t treat investments in housing as mitigation, just as ODOT routinely spends a portion of its highway budget on restoring wildlife habitat, creating new wetlands, or even replacing jail cells.  A real restorative justice commitment would make up for the damage done, as these examples show.

    Lexington Kentucky:  A community land trust funded from highway funds

    For decades, Kentucky’s highway department had been planning a freeway expansion through Davis Bottom, an historically African-American neighborhood.  The threat of freeway construction helped trigger the decline of the neighborhood.  When the road was finally built a little more than a decade ago, the state highway agency committed to restoring the damage done to the area by investing in housing.  As part of the Newtown Pike Extension project, the Kentucky Transportation Cabinet acquired 25 acres of land and provided funding to establish a community land trust for the construction of up to 100 homes.

    In 2008, the Federal Highway Administration gave the project an award for this project, saying:

    The Davistown project is the first CLT ever created with FHWA Highway Trust Funds. Eighty percent of the project, including the acquisition of CLT land and the redevelopment of the neighborhood, will be funded with these FHWA funds.

    The FHWA Environmental Justice guide highlights the Lexington CLT as as a “best practice.”

    Houston, Texas:  $27 million to build affordable housing to mitigate interstate freeway widening

    Houston’s I-45 “North Houston Highway Improvement Project” would, like the I-5 Rose Quarter project, widen a freeway through an urban neighborhood.  The Texas Department of Transportation, as part of the project’s environmental impact review process has dedicated $27 million to build or improve affordable housing in neighborhoods affected by the freeway.


    Reno Nevada, State DOT providing land and money to cities and counties for affordable housing

    Nevada DOT committed to using highway funds to pay for housing to mitigate effects of freeway expansion in Reno at the junction of I-80 and US 395.

    NDOT will provide funds or land already owned by NDOT to others (Cities of Reno or Sparks, Washoe County) to build affordable replacement housing for non-Reno Housing Authority displacements. Those displaced by this project who wish to remain in the area will be given priority access to the replacement housing. After those needs have been addressed, the affordable housing will then be made available to those who qualify for affordable housing but were not displaced by the project. Residents will be considered eligible for this replacement affordable housing if they meet Section 8 eligibility requirements or Reno Housing Authority’s Admission and Continued Occupancy Policy (Reno Housing Authority 2018).

    Federal Regulations encourage or require mitigating impacts.

    The key environmental law governing federal highway projects is the National Environmental Policy Act.  It requires that agencies identify the adverse environmental impacts of their decision, and then avoid, minimize or mitigate those impacts.  In particular, NEPA mitigation includes “restoring the affected environment” and “compensating for the impact by . . . providing substitute resources or environments.”  Using highway funds to replace housing demolished by a freeway is one key way in which the negative effects of a highway project on an urban community can be mitigated.

    CFR § 1508.20 Mitigation.

    Mitigation includes:

    (a) Avoiding the impact altogether by not taking a certain action or parts of an action.

    (b) Minimizing impacts by limiting the degree or magnitude of the action and its implementation.

    (c) Rectifying the impact by repairing, rehabilitating, or restoring the affected environment.

    (d) Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.

    (e) Compensating for the impact by replacing or providing substitute resources or environments.

    A federal executive order on Environmental Justice directs agencies to pay particular attention to the impacts, including the cumulative impacts of agency decisions on low and moderate income people and people of color.  THe Federal Highway Administration’s Environmental Justice Policy specifically identifies impacts on neighborhoods as “adverse effects” of federal highway projects, and calls for both mitigating these impacts, and considering alternatives that minimize adverse impacts on communities.

    1. Adverse Effects. The totality of significant individual or cumulative human health or environmental effects, including interrelated social and economic effects, which may include, but are not limited to: bodily impairment, infirmity, illness or death; air, noise, and water pollution and soil contamination; destruction or disruption of human-made or natural resources; destruction or diminution of aesthetic values; destruction or disruption of community cohesion or a community’s economic vitality; destruction or disruption of the availability of public and private facilities and services; vibration; adverse employment effects; displacement of persons, businesses, farms, or nonprofit organizations; increased traffic congestion, isolation, exclusion or separation of minority or low-income individuals within a given community or from the broader community; and the denial of, reduction in, or significant delay in the receipt of, benefits of FHWA programs, policies, or activities.

    FHWA Policy:  It is FHWA’s stated policy to mitigate these disproportionate effects by providing “offsetting benefits” to communities and neighborhoods, and also to consider alternatives that avoid or mitigate adverse impacts.

    What is FHWA’s policy concerning Environmental Justice?  The FHWA will administer its governing statutes so as to identify and avoid discrimination and disproportionately high and adverse effects on minority populations and low-income populations by:

    (2) proposing measures to avoid, minimize, and/or mitigate disproportionately high and adverse environmental or public health effects and interrelated social and economic effects, and providing offsetting benefits and opportunities to enhance communities, neighborhoods, and individuals affected by FHWA programs, policies, and activities, where permitted by law and consistent with EO 12898;

    (3) considering alternatives to proposed programs, policies, and activities where such alternatives would result in avoiding and/or minimizing disproportionately high and adverse human health or environmental impacts, where permitted by law and consistent with EO 12898

    Taken together, the NEPA requirements for mitigation, and the FHWA’s policy on environmental justice require FHWA projects—like the I-5 Rose Quarter Freeway Widening—to address the cumulative totality of the project’s effects on the neighborhood, including the disruption of community cohesion, the displacement of people and businesses and increased traffic congestion.  The current project adds, as we have shown, to a long history of federally supported highway projects in the Albina neighborhood that have had devastating cumulative effects, including particularly, the destruction of hundreds of housing units, which are essential to the economic well being of the neighborhood and its residents, who, historically have been lower income and people of color.  It is fully consistent with federal environmental policy and environmental justice requirements for ODOT to devote funds to rebuilding housing as a way to mitigate the damage it has done to the Albina neighborhood.




    For a grand bargain, think bigger and bolder

    Right diagnosis, weak medicine, wrong metaphor

    In a far ranging thought piece for James Fallows’ Our Towns Civic Foundation—”Learning from Eisenhower and Lincoln:  A Grand Bargain for Transportation,” Patrick Doherty and  Chris Leinberger invoke Abe Lincoln and Dwight Eisenhower as role models for a Biden Administration infrastructure policy.

    There’s a lot to like in this analysis, and its recommendations touch on many of the topics that are essential to crafting a solution to the problems we face.  That said, we’d offer a couple of contrasting views, and hopefully friendly amendments to the policy prescriptions, and different metaphor than the authors invoke.  This is a worthwhile conversation to have, and we’re grateful to the authors for inviting us to join.

    Their essay is founded on a trenchant and accurate diagnosis of the roots of America’s social, economic and environmental crises:  public policies that have fostered excessive reliance on private automobiles.  Our obsession with cars has caused us to remake our landscape in a way that has made us all more car dependent.

    Today, dense, walkable neighborhoods are in short supply and therefore command premium prices.  And they are either uneconomical or actually illegal because of our obsession with catering to cars.

    Doherty and Leinberger are spot on when they diagnose this problem:  Clearly, we need to build more walkable places; the challenge is figuring out how to reduce decades of auto-centric policies, and undo the damage they’ve inflicted on the landscape.  This essay goes in the right direction, but we would urge them to go considerably further.  To paraphrase the President, we need to build back bolder, and differently.

    The big challenge is equating “infrastructure” and “transportation.”   It’s unfortunate to conceptualize our core urban problems as a lack of transportation. As a metaphor, they’ve chosen Lincoln’s subsidies for transcontinental railroad construction and Eisenhower’s defense and interstate highways.  While these initiatives are suggestive of the scale of the change that’s needed, there’s a “hair of the dog” quality to this prescription.  Particularly in the case of the interstate highways, the fixation with transportation generally and cars specifically have led to massive subsidies to sprawl and dispersion.  America’s problem is not that we have too little transportation infrastructure, but that we have too much (particularly of the wrong kinds), and it has led to vast decentralization.  And in a world built for cars, it’s simply impossible to walk, and uneconomical to provide transit service.

    That’s why one core feature of the Doherty and Leinberger prescription—rejiggering the formula for the the distribution of federal transportation funds to favor transit—while very much a step in the right direction is simply too weak a prescription given the scale of the problem.  Better transit would be a palliative to some of the worst effects of this car dependent system, but given the enormity of the challenge simply isn’t enough.

    Let’s be clear about the magnitudes here:  The Biden American Jobs Plan (AJP) proposes $85 billion over eight years for public transit, about $10 billion per year.  (A further $80 billion would go to high speed rail; which is meritorious in its own right, but doesn’t make the bus come sooner).  In addition, except for recent pandemic aid, almost all federal transit funding goes to capital construction, and between fares and local taxes, cities are hard pressed to support the existing level of transit service, much less expand it.  Increasing transit mode share would also require a large and permanent increase in federal operating subsidies.

    A key problem with transportation is that we haven’t asked cars to pay their way:  We subsidize driving in many ways, and some features of the AJP continue this.  Instead of raising the gas tax, the AJP would use higher corporate taxes.  The bill also calls for a $174 billion  subsidy for vehicle electrification.  The US has a gas tax that is a fifth of the of other industrialized nations.  Enlarging the deep subsidies to car transportation undercuts all of the efforts to invest in transit and promote dense walkable places.  A more direct and radical solution to the problem of too much driving would be a healthy increase in the gas tax, or a national carbon tax, with the proceeds dedicated to building housing and communities (as well as subsidizing transit).  Higher gas prices that fully reflected the social and environmental cost of driving fossil fueled vehicles will also help propel the electrification of the vehicle fleet.

    It’s also worth noting that investments in transportation are no panacea for the problems of rural development.  The late University of Oregon economist Ed Whitelaw observed of the investments in schools and highways in Appalachia, that better schools gave kids the education and better highways enabled them to leave.  Even the legacy of the transcontinental railroads was the devastation of small scale farming in New England, which couldn’t compete against California.

    Beyond investing in transportation, we’ve got to invest in place, in the civic realm that brings us together, and in building more housing in those high demand places that already have walkable amenities (and which by and large have the best transit access).  In a sense, the better Lincoln analogy would have been to the Homestead Act, rather than to transcontinental railroads.

    As our friends Joe Kane, Adie Tomer and Jenny Schuetz at the Brookings Institution have written, this will require a very different approach to land use.

    That leaves the country with no choice: We must prioritize development in the kinds of neighborhoods that permanently reduce total driving and consume less energy. Such human-centered neighborhoods have the added benefit of helping us adapt to climate impacts, improve public health, and promote access to activities. Encouraging their development should be a central part of any national climate resilience strategy.

    We probably need to be even more blunt about the nature of our problem (Doherty and Leinberger never use the word “sprawl”) and much more explicit about our transportation goals (as Brookings suggests, we need to reduce VMT (vehicle miles traveled), which is an indicator Doherty and Leinberger don’t mention).

    Doherty and Leinberger acknowledge that land use needs to change, but the threat of losing federal infrastructure funding is unlikely to change the willingness of high income neighborhoods and suburbs to exclude higher density housing.   (Many of these are ones that already have the amenities and walkablity which are in short supply). Ironically, the federal government wields much more authority to ban local practices that affect access to television a and the Internet, than they do local practices that restrict housing affordability.   They also call for “prioritizing” affordable housing near transit, but absent a monumental increase in the paltry federal funding for affordable housing, this is not going to perceptibly change community form.

    All this suggests that Franklin Roosevelt is a better role model than Dwight Eisenhower.  Early on, Roosevelt focused on fixing the housing market, inventing federal mortgage insurance.  Equally important, Roosevelt’s Works Progress Administration and Civilian Conservation Corps made wide ranging investments in civic infrastructure–parks, public buildings, trails, and other assets for the public commons–that still provide value today.  In addition, throughout his administration, during the recovery from the Great Depression, and during the mobilization for World War II, the federal government poured massive resources into building public housing.

    As John Kenneth Galbraith observed, the US has long been a nation of private prosperity and public poverty.  Investing in a public realm and shared civic assets, especially those that anchor and enrich walkable community spaces, strengthens our communities.

    It may seem politically astute to invoke a pair of Republican presidents as role models, but given the depth and acrimony of the partisan divide, that’s likely to be fruitless in generating a bipartisan support for this measure.  Better to get the metaphor and the details right, than to implicitly reinforce the idea that more or different transportation spending will solve the problems that too much transportation spending created.

    If there is something to be gleaned from Eisenhower and Lincoln (in addition to FDR), it was that each of them proclaimed and implemented an entirely new and much larger federal responsibility for a key aspect of the nation’s development.  Arguably transportation was timely in 1860 and 1956, but the nation’s needs today are different.  Viewing our problems through the lens of transportation, and constructing a grand bargain that provides more (or somewhat re-jiggered) subsidies for transportation misses the opportunity to make the principal focus placemaking and fixing the shortage and high cost of housing in walkable locations.

    The real “I-5” project: $5 billion, 5 miles, $5 tolls

    The intentionally misleading re-brand of the failed Columbia River Crossing conceals the key fact that it is a 12-lane wide, 5 mile long freeway that just happens to cross a river, not a “bridge replacement.”

    It’s vastly oversized and over-priced, with current cost estimate ranging as high as nearly $5 billion (before cost-overruns), which will necessitate round trip tolls of at least $5 for everyone using the bridge.

    This part of the “I-5 bridge replacement” isn’t even the bridge, it’s the widened approach on Hayden Island. (Bike Portland)

    Almost a decade ago, plans for a gigantic freeway-widening between Portland and Vancouver collapsed in the face of budget concerns and deep community disagreements about the project.  For the past year, the Oregon and Washington transportation departments have been trying to breath life into the zombie project—with the help of $40 million in consultants. The project’s-PR led marketing effort has systematically concealed the fundamental facts of the project, while promoting meaningless, unquantified and unenforceable platitudes about promoting equity and responding to climate change.

    Like the original Columbia River Crossing (CRC) project, its an intellectually bankrupt sales pitch, not an honest conversation about alternatives.

    It’s been apparent for months now that ODOT and WSDOT are trying to pressure the two states into recycling the project’s current record of decision–now more than a decade old.  That “ROD” as it’s called, specifies a massive freeway expansion illustrated above.  While the agency is hinting at the possibility of “design” tweaks—it’s apparent that their plan is to simply recycle the failed CRC proposal.

    They’ve rebranded  it the “I-5 Bridge Replacement” but that’s an intentionally misleading title.  Sounds innocuous, right?  Who can be against merely “replacing” a bridge?

    The only part of that branding that’s right is the number 5.

    But they’ve left out the real meaning of the “5” in the title.  There are really three “5’s” that really define this project.  According to the project’s own documents: It’s five miles long, it’’ll cost $5 billion, and they’ll charge you $5 for a round trip.

    It’s not a bridge “replacement” — It’s a five-mile long, 12-lane wide freeway that just happens to cross a river.  It stretches five miles from Lombard to Mill Plain Boulevard.

    It’s 12 lanes over the Columbia River, and even wider on Hayden Island, as the above illustration shows.  Congressman Peter DeFazio has called the plan “gold-plated.” (Manning, Jeff. “Columbia River Crossing could be a casualty of the federal budget crunch”, The Oregonian, August 14, 2011).

    It’s going to cost upwards of $5 billion, a—and likely more because they routinely have massive cost overruns.

    According to their tolling financial estimates, which are part of the current finance plan, they’ll charge a minimum toll of $2.60 each way to cross the bridge, which works out to more than $5 per round trip. Peak tolls would be higher, and heavy trucks would pay four times as much as cars ($20 per round trip, minimum).

    It’s time for ODOT and WSDOT to be honest about what they’re really proposing, the 5-5-5 project: 5 miles of freeway, $5 billion, $5 tolls per round trip.

    Getting real about restorative justice in Albina

    Drawings don’t constitute restorative justice

    ODOT shows fancy drawings about what might be built, but isn’t talking about actually paying to build anything

    Just building the housing shown in its diagrams would require $160 million to $260 million

    Even that would replace only a fraction of the housing destroyed by ODOT highway building in Albina

    The Oregon Department of Transportation is going to great lengths to cloak its $800 million I-5 Rose Quarter Freeway widening project in the language of restorative justice.  Starting in the 1950s, ODOT built not just one or two, but three different highways through the historically Black Albina neighborhood, and is now back with plans to widen the largest of these, but is now pretending to care about restoring the neighborhood.  To that end, its appointed an “Historic Albina Advisory Board”—after disbanding another community advisory group which had asked too many uncomfortable questions.

    Housing is essential to restorative justice in Albina

    The real challenge to restorative justice in Albina is more housing.  The aerial photo here shows the Albina neighborhood as it existed in 1948; the red-lined areas are properties takes or demolished for the construction of Interstate Avenue in 1951, the I-5 Freeway in 1961 and the Fremont Bridge and aborted Prescott Freeway in the early 1970s.  Albina was torn apart by these ODOT highway projects and its housing stock decimated. Given that ODOT’s highway building triggered the destruction of thousands of homes in Albina (the neighborhood’s population declined by more than 60 percent, from 14,000 to less than 4,000, it’s hardly surprising that getting more housing built is a key priority.


    The ODOT consultants report that that one of the key strategies for building community wealth is to create affordable housing.

    ODOT’s making it look like there will be housing as part of its plans

    ODOT staff and consultants have presented the HAAB with surveys and focus group information on what restorative justice might look like.  An “Independent Cover Assessment” consulting group has even prepared drawings showing alternative development plans for the area near I-5.  The drawings feature examples from other cities of Black cultural and community facilities, and prominently include diagrams showing large new multifamily housing to be built on top of or near the freeway.  Here are two such diagrams, (the yellow colored buildings are residential apartments).  Concept 1 has four large residential buildings, Concept 5 has 5 large residential buildings.


    But who’s going to pay for that housing?  It’s going to cost $160-260 million and ODOT is offering . . nothing.

    It’s all well and good to talk about housing, but how, exactly, would it get built?  These colorful illustrations are really just misleading puffery and magical thinking unless there’s a realistic plan for paying for the project.  The availability of the land is the easy part.  The hard part is getting money for construction.  To get an idea of how much it would cost, we can look just a few blocks away to the newly completed Louisa Flowers Building.  It was just finished and has 204 studio, one bedroom and two bedroom apartments.  Its development and construction cost about $71 million, and Home Forward, the city of Portland’s housing agency paid $3 million for the site.  The project cost about $380 per square foot, with the overall cost per housing unit working out to about $350,000.

    The Louisa Flowers affordable housing building in Portland (Portland Tribune)

    The Independent Cover Assessment shows that the residential buildings (shown in yellow) in its two concepts would make up about half to 60 percent of the 900,000 to 1.1 million square feet of buildings to be build atop or adjacent to the freeway.  Those figures imply about 430,000 square feet or about 470 apartments in Scenario 1, to 680,000 square feet or roughly 740 apartments in Scenario 5.

    If you could build those apartments for the same cost as Louisa Flowers (you couldn’t, of course; costs have gone up), that means the yellow colored buildings shown in these renderings would cost between $160 million and $260 million to develop and construct.

    In short, unless you’ve got between $160 and $260 million (just for the housing part, mind you), those pictures are just a fantasy.

    If ODOT actually had a budget for the construction of that housing, in order to, you know, promote restorative justice, then it would be perfectly valid to include this as part of the project discussion.  But ODOT hasn’t committed a dime to actually paying to build this housing.

    And you could say, in theory, (and it would have to be theoretical, because ODOT has made no such commitment), that ODOT would be contributing the land for these buildings.  But as noted in the case of Louisa Flowers, the cost of the land is less than 5 percent of the cost of constructing the project.  If housing is key to restorative justice in Albina, and if ODOT is committed to restorative justice, it seems like it ought to come up with the other 95 percent as well, rather than expecting unnamed others to do the heavy lifting for it.

    Housing is essential to restorative justice in Albina.  Simply drawing pictures of housing isn’t justice, it’s cynical vaporware, an attempt to create the illusion that ODOT cares, when its only real interest is in building a vastly wider freeway.  The state highway department readily spent money to demolish housing in the 1950s, 1960s and 1970s, but apparently isn’t willing to spend any of its money to replace that housing today. And the irony is, if you really want to have restorative justice and more housing, you don’t need to build a wider freeway.  In fact, a wider road would make the area less desirable for housing. ODOT’s plan to widen the freeway—and further inundate this neighborhood with more car traffic—doesn’t so much heal the repeated wounds it has inflicted on Albina, as it does to make them even worse.


    The NIMBYs made $6 trillion last year

    In 2021, US residential values increased by $6.9 trillion, almost entirely due to price appreciation

    Those gains went disproportionately to older, white, higher income households

    Capital gains on housing in 2021 were ten times larger than the total income of the bottom 20 percent of the population.

    Little of this income will be taxed due to the exemption on capital gains for owner-occupied homes

    Gains to homeowners dwarf the profits made by developers, foreign investors, or Wall Street home buyers.

    Rising home prices are a transfer of wealth to older generations from younger ones.

    So much of our housing debate is a search for suitable villains on which to blame a lack of affordability.  Our problems must be due to rapacious developers, greedy landlords, absentee speculator owners, buying new housing and holding of the market, and private companies buying up and renting out single family homes.  These are the cartoon characters who get blamed for driving up prices.  But they aren’t the ones to blame, and they’re not the ones who are making a killing in the housing market.

    Housing affordability melodrama: Where’s Snidely? Sirsalem1, CC BY-SA 4.0 via Wikimedia Commons

    The real estate speculators reaping literally trillions of dollars of gains from our capitalist housing system are millions of homeowners, who, whether they acknowledge it or not, are the beneficiaries of “Not in my back yard” policies that have driven up the price of housing.  And this surge of homeowner wealth is a rotten development from the standpoint of addressing yawning disparities by race, income and generation, as the beneficiares of these gains are statistically higher income, whiter and older than the overall US population.

    Last year, according to calculations from Zillow, the value of existing residential real estate in the US grew by $6.9 trillion.  (New residential buildings—the construction and upgrading of homes and apartments—contributed about $800 billion).  The gain home values in 2021 was nearly triple the $2 trillion or or so increase in residential values Zillow reported in 2022.  In the post-pandemic era, we’re getting a bit inured to counting  “trillions.”  To put the amount of housing capital gains in perspective, the $6.9 trillion dollar one-year increase in home values is more than ten times the total pre-tax income of the bottom twenty percent of US households (about $600 billion in 2018, according to the Congressional Budget Office).

    Here’s another picture of how much housing wealth has been created.  The Federal Reserve tracks “homeowner’s equity”—the net amount of wealth that homeowners have after subtracting outstanding mortgage debt from home values.  After the collapse of the housing bubble, owner’s equity stood at about $10 trillion, and since then has ballooned to $26 trillion.


    To get an idea of exactly who reaped those gains, we took a look at data compiled by the Federal Reserve Board on the demographics of homeownership. The Fed’s triennial Survey of Consumer Finance provides estimates by age, race and income of homeownership rates and the average value of housing for the nation’s households.  Using these data, we computed the number of households by race and age of the household head (which the Fed Survey tactfully calls “the reference person”) and by the income of the household.  We’ve combined the value of owner-occupied residential property with other residential property owned by households (i.e. second homes, investment houses or apartments).  The Fed’s estimates (based on its household survey) are somewhat different from Zillow’s (derived from its database of homes), but both put total value of US residential real estate in the $30-$40 trillion range.  To a first approximation, these data on the age, race and income of homeowners are our best guide to who reaped the $6 trillion in residential capital gains this year.  That assumption masks some variability in housing price appreciation across markets and classes of homes, but this should be a good rough indicator of the demographics of the nation’s housing wealth winners.

    The gerontopoly of housing wealth

    As we’ve noted before at City Observatory, older Americans hold most US housing wealth, and have been chalking up a disproportionate share of gains as housing has appreciated.  The latest data from the Federal Reserve show that households headed by a person aged 55 and older own 56 percent of all residential housing wealth in the US. It’s a fair guess that these older homeowners reaped most of the gain in home values in the past year.

    As Ed Glaeser has pointed out, rising real housing costs are a straightforward transfer of wealth from younger generations (who must buy the now more expensive homes) to older generations (who own the housing, and will reap gains when it is sold).

    The long shadow of race

    For a long list of reasons—including discrimination in housing and labor markets, redlining, and segregation—households of color have been systematically denied the opportunities to accumulate housing wealth.  That pattern is still very much in evidence in the latest Fed data:  Non-Hispanic white households own almost 80 percent of all the housing wealth in the US, implying they also reaped 80 percent of the residential capital gains, or about $1.6 billion.

    Rising home prices effectively increase the wealth of white households relative to households of color.

    High income households own most housing 

    While homeownership is touted as a means of wealth accumulation, it has mostly worked out for high income households. While the ownership of real estate is not as skewed to high income households as is the ownership of financial assets like stocks or bonds, it is still the case that the highest income 20 percent of the population owns 59 percent of all the residential housing value in the US.

    These data suggest that about $1.2 trillion of the gain in home values went to the top 20 percent of the population, meaning that their residential capital gains exceeded by a factor of about two the total pre-tax income of the bottom 20 percent of the population.

    Housing appreciation is untaxed, which benefits older, white and wealthier households

    The skewed ownership of housing wealth means that the gains in wealth are highly concentrated in households that are older, whiter, and higher income than other Americans.  But unlike wage income, income from housing appreciation is mostly un-taxed. As a result, the capital gains exclusion for housing is regressive and inequitable.  The capital gains exclusion for owner-occupied real estate,is much more valuable to high income households because they are more likely to own homes, own more expensive homes, and generally face higher tax rates that low income households.

    In reality, the $2.2 trillion in capital gains that US residential property owners reaped in 2020 will be lightly taxed, to the extent they are taxed at all.  Federal law exempts from capital gains the first $500,000 in gains on the sale of owner occupied property (for married couples filing jointly).  That is to say that you would need $500,000 of appreciation to have any capital gains liability.  As a practical matter, few households pay capital gains taxes on residential real estate appreciation.  The tax-favored status of income from residential real-estate speculation is a quintessential feature of our system that attempts to promote wealth-building through home ownership.  While well intended, it systematically rewards older, whiter and wealthier households, and effectively denies opportunities to build wealth to the third of the population that is renters.  In many ways, it is the worst of all worlds, making housing more expensive for those least able to afford it, and providing most of the gains to those who are already most advantaged.

    There’s one final irony here:  policies to broaden access to homeownership now, by providing subsidies or other support for lower income, younger, and minority homebuyers don’t rectify these gaps, they likely make them worse.  Steps to amplify demand in a surging market tend to drive prices up further, which further enriches incumbent homeowners at the expense of first-time buyers.  If you could enable people to somehow buy houses at 1990 or 2010 prices, they could be assured of wealth gains, but the risk is that buying now offers no such expectation of long term gains. Promoting homeownership primarily helps those who are selling homes, not those who are buying them.

    The search for villains

    Rather than talk about the capital gains that flow to older, wealthier, whiter households, much of the housing debate is a melodrama, looking to cast suitably evil villains on which to blame the crisis.  It’s fashionable to finger Wall Street investors (who for the past decade or so have been buying up single family homes and renting them in many US markets), foreign buyers of luxury condominiums in New York, Miami, Seattle and other hot cities (who let the units sit vacant while speculating on higher values), and greedy developers, who make excessive profits by building new homes.  None of these supposed villains accounts for more than a trivial part of the problem; at most, they’re picking up crumbs, compared to the the trillion dollar gains logged by incumbent homeowners.

    A recent article in the New York Times suggests Wall Street backed investors now own as much as $60 billion in single family real estate.  That’s sounds ominous, but it’s less than 1 percent of the $35 trillion or so of residential investment in the US.  If all these investors earned a 10 percent capital gain in 2020, they would have collectively gotten about $6 billion or a couple of tenths of one percent of the $2.2 trillion in home values. It’s also fashionable to blame the construction of luxury condos in a few superstar cities—held vacant by rich, often foreign speculators.  The trouble is that such units are a tiny slice of the housing market, and there’s no evidence they affect overall housing costs.

    And then there are the developers.  Supposedly they make a killing from building new housing. When housing price are appreciating, especially as fast as they have in the past year, the profits that developers earn from building new housing are dwarfed by the capital gains reaped by existing homeowners.  Our friend Josh Lehner, an economist with the Oregon Office of Economic Analysis, has an insightful study estimating the profits earned by homeowners and developers in Oregon over the past decade.  Lehner estimates, that on average, developers reap a margin of about 14 percent on new housing construction.  By comparing that total (14 percent of the value of new housing built in any year), with the appreciation of the existing housing stock in that same year, Lehner is able to show how developers profits stack up against the capital gains enjoyed by incumbent homeowners.  It isn’t even close:

    Applied to Zillow’s estimates of national level new construction, Lehner’s 14 percent of building value estimate suggests that developers netted less than $40 billion nationally, an amount equal to about 2 percent of the gains that accrued to owners of existing homes.  It’s not the greedy developer that’s benefiting from rising home prices, it’s the NIMBYs next door who reap the gains.  As our colleague Daniel Kay Hertz has pointed out, we tend to conveniently forget that essentially all of the existing housing stock came into being, not by immaculate conception, but by the profit-motivated efforts of earlier generations of developers. If anything, because new development increases housing supply, it blunts housing price appreciation, so more development tends to increase affordability.

    Wall Street investors, speculating oligarchs, and greedy developers all make signature villains in the housing affordability melodrama, but they really conceal the identity of those who are actually reaping the gains of rising housing prices.  It also hides the principal policy that’s driven the appreciation of residential real estate:  the dominance of a range of “Not in my back yard” policies, including excessive single family zoning, apartment bans, high development fees, parking requirements and a host of other policies that have made it harder to build housing, especially in the places people most want to live.

    The experience of the past year illustrates the profoundly broken nature our current strategy of “wealth building through home ownership.”  The benefits of home price appreciation accrue disproportionately to those who already have wealth, and if anything, they tend to worsen the existing disparities of wealth among households.  As existing housing appreciates, it increases the wealth of the incumbent homeowners, who are disproportionately white, older and wealthier, and drives up housing costs for those who don’t now own homes.  And our tax system amplifies these inequities by allowing nearly all of this income to go untaxed.  The myth of homeownership as a universal wealth building strategy is the real villain here.

    A version of this commentary was originally published in 2021, and has been updated to reflect the latest data on home price appreciate estimated by Zillow.