The Interstate Bridge Replacement Project simply can’t tell the truth about current traffic levels or recent growth rates.

IBR reports inflate the current level of traffic on I-5 bridges by nearly 5,000 vehicles per day

IBR reports falsely claim that I-5 bridge traffic is growing twice as fast as ODOT’s own data show

IBR officials have exaggerated traffic levels and traffic growth rates to try to sell an over-sized, over-priced project.

It’s important to note that this is actual, recorded data, gathered by the Oregon Department of Transportation, and published on its traffic counting website.  If IBR officials can’t be trusted to accurately report current and historical data, and when they instead choose to inaccurately inflate traffic counts and claim traffic is growing twice as fast as their own data show, it raises serious concerns about whether they can be trusted to accurately project future traffic levels–a process that is inherently more difficult, and critically, largely shrouded from public view.

The Interstate Bridge Replacement (IBR) project, a massive $7.5 billion undertaking to replace the I-5 bridges over the Columbia River, is built on a foundation of questionable traffic projections. As we’ve seen time and again with megaprojects, errors in traffic modeling can lead to overstated needs, financial boondoggles, and understated environmental impacts. The IBR project seems to be following this well-worn path.

The importance of getting traffic numbers right

Traffic counts and modeling aren’t just a technical exercise—they’re the cornerstone of the entire project. Traffic levels define the need, justify the size, evaluate alternatives, and determine financing.  Understanding present and future traffic levels are also crucial for assessing environmental impacts. As the Federal Highway Administration notes, “travel and land use forecasting is integral to a wide array of corridor and NEPA impact assessments and analyses.” In other words, if the traffic forecasts are wrong, the entire environmental impact assessment is compromised.  Current traffic data and recent traffic growth trends need to be accurate in order to create accurate forecasts of future activity–and IBR officials have exaggerated traffic levels and traffic growth to sell their project.

IBR can’t even report current traffic count data accurately

One would think that counting cars on a bridge would be straightforward. Yet, the IBR project can’t seem to agree with itself—or with the highway department’s own  traffic recorders—on how many vehicles cross the I-5 bridge daily.

The IBR has variously claimed 142,400 or 143,400 vehicles per average weekday in 2019. Meanwhile, ODOT’s automatic traffic recorder reports 138,780 per day for the same year. That’s a discrepancy of up to 4,620 vehicles per day—not exactly a rounding error when you’re justifying a multi-billion dollar project.

Average weekday traffic for each month in 2019  is shown in second column of the right-hand panel of this table, downloaded from ODOT’s own traffic reporting website.  The average weekday traffic for the twelve months January through December 2019 is 138,780 vehicles per weekday.

This isn’t the first time ODOT and WSDOT have played fast and loose with traffic numbers. During the Columbia River Crossing project from 2008 to 2011, they overstated 2005 traffic levels —a fact they were forced to admit in federal court.

IBR exaggerates recent traffic growth

Not only does the IBR technical work get recent traffic levels wrong, it also grossly overstates the rate of growth in traffic across the I-5 bridge.  The study focuses on the four-years prior to the pandemic—2015 to 2019.  The IBR’s “Level 2” traffic study claims traffic on the I-5 bridge increased by 1.1 percent annually between 2015 and 2019. However, ODOT’s own official data shows the actual growth rate was only 0.55%—half of what the IBR claims. This isn’t just a minor discrepancy; it’s a fundamental misrepresentation of traffic trends that could significantly impact the project’s justification and design.

The inaccurate traffic count data leads the Stantec Level 2 study to overstate the recent rate of growth across the I-5 bridges.  The Level 2 study claims that between 2015 and 2019, traffic increased by 1.1 percent per year. 

The average weekday river crossings along the I-5 and I-205 Bridges since 2015 are presented in Figure 2-6. Between 2015 and 2019, the traffic on the I-5 Interstate Bridge increased at an annual rate of approximately 1.1% . . .
Stantec, Level 2 Report, page 2-9

According to the average weekday traffic data reported on the ODOT automatic data recorder website, the actual rate of increase was only half as much—0.5 percent.   We examined actual data reported on ODOT’s website (https://www.oregon.gov/odot/data/pages/traffic-counting.aspx) for the Automated Traffic Recorder for  the I-5 Interstate Bridge.  In 2015, average weekday traffic was 135,696 vehicles per day.  In 2019, average weekday traffic was 138,700 vehicles per day.  This represents an annual rate of increase of 0.55 percent per year, half the rate claimed in the Stantec Report.

The difference in growth rates is a crucial point that highlights potential issues with the IBR project’s traffic projections.  The failure to accurately report recent traffic growth has important implications and consequences:

1. • The IBR’s claimed growth rate is twice the actual rate based on official ODOT data.
   • This discrepancy is significant because growth rates are often used to project future traffic volumes, which in turn justify the need for and scale of transportation projects.
   • Overestimating the growth rate leads to inflated projections of future traffic.
     • This could result in overbuilding infrastructure, wasting public resources, and potentially creating unnecessary environmental impacts.
     • It might also affect the financial viability of the project, as toll revenue projections are based on these inflated growth rates.

This difference in growth rates is not just a minor statistical quibble. It represents a fundamental issue with how the IBR project is analyzing and presenting traffic data. If the project is consistently overestimating traffic growth, it could lead to a significantly oversized and more expensive project than what is actually needed. This highlights the need for transparent, accurate, and verifiable traffic data and projections in planning such a massive infrastructure project.

With a price tag of up to $7.5 billion, the IBR would be the most expensive transportation project in the region’s history. It’s crucial that decisions about such a massive investment are based on accurate, consistent data. Yet, what we’re seeing is a pattern of inflated numbers, inconsistent baselines, and opaque methodologies. The discrepancies and inconsistencies in the IBR’s traffic modeling raise serious questions about the project’s foundation. If we can’t trust the basic traffic counts, how can we trust the complex projections built upon them?

The cost of the Interstate Bridge Replacement (IBR) is going up:  But we won’t tell you how much . . . And we’re not going to tell you until a year from now, after the 2025 Legislature adjourns

In January, 2024, IBR official publicly acknowledged that their 13 month-old cost estimate of up to $7.5 billion was wrong, and promised a new estimate “later this summer.” 

It’s now summer, and IBR officials are now saying their new estimate won’t be done for another year “about this time next year” (June 2025).

IBR officials are keeping secret the new higher cost until after the Oregon and Washington Legislatures meet.  ODOT has specifically excluded any mention of additional funding for the IBR project from its presentations to legislative committees contemplating a new finance plan for ODOT for the 2025 session.

ODOT is touting a newly announced $1.5 billion federal grant for the project.  But the project’s price tag is rising faster than it is finding money to pay for the bridge.  And Oregon and Washington will be holding the bag for any cost increases or toll revenues shortfalls.

A delayed project is hiding a higher price tag

As we’ve pointed out, the project is two years behind the schedule announced when it was re-started in 2020, and is falling further behind.  The cost of the project has ballooned from a maximum of $4.8 billion in 2020, to as much as $7.5 billion in 2022.  Earlier this year, IBR officials revealed the price tag would be even higher, and promised to reveal a new estimate in the summer of 2024.  But now, this plainly isn’t going to happen.

At a June 13 Community Advisory Committee meeting, project director Greg Johnson conceded the IBR’s budget was going up again, but that it would now be summer of 2025 before they would reveal the actual price tag:

. . . it will probably be around this time next year that we will have that final process completed with a more rigorous and up to date number for overall construction costs.

A chronology of cost estimates

No one should place much credence on IBR cost estimates:  they always go up.

November 2020 Initial cost estimate $3.3 to $4.8 billion

May 2022:  City Observatory predicts costs will rise to $5-$7 billion.  As Willamette Week reported, our City Observatory prediction—made in May, 2022, seven months before the IBR estimates were released—that the cost of the IBR would balloon to between $5 to $7 billion was spot on, and slightly conservative.

December 2022, new cost estimate $5 to $7.5 billion.  And in December 2022, IBR offiicials confidently assured alarmed legislators that they would prevent future cost increases thanks to WSDOT’s “CEVP” process designed to manage risks.  City Observatory filed a public records request for that CEVP, and in January 2023, IBR officials claimed that “no records exist” of any CEVP work.

January, 2024: IBR Director Greg Johnson says “costs are going up.  We are going to be reissuing an overall program estimate probably later this summer.”

June 2024:  IBR testifies it will do another cost estimate “about this time next year”. Greg Johnson, in comments to the IBR’s community advisory group.

. . . it was our plan to to go into another what’s called a CEVP cost validation, estimating process that that looks at risk and evaluates and puts a cost to to risk. And so the last time we did this, which was two years ago, we came up with the range between five and seven and a half billion. And that seven and a half billion was the worst case scenario at that time. But once again, as we have seen, the outpacing of inflation rates beyond what anybody was expecting in the construction industry, those numbers are going higher. We are seeing it across the nation on large construction projects, so we expect that number to be higher. We were going to start another CEVP process on the heels of getting the draft supplemental document done. But now, as that has been pushed, we are pushing that CEVP to understand what we are building. So we will probably it will probably be around this time next year that we will have that final process completed with a more rigorous and up to date number for overall construction costs.

June 2025:  Next cost estimate:  Likely $9 billion or more.

Lying and concealing cost increases

The IBR is the single largest highway project in Oregon history, and will severely tax the managerial and financial capabilities of the Oregon Department of Transportation.  Even as Governor Kotek says ODOT faces “catastrophic funding challenges” the need for additional funding for the IBR project is also consistently omitted from ODOT’s lengthy financial presentation.  Oregon Department of Transportation has been participating in hearings around the state on its financial condition, and its presentations never make any mention of the state’s liability for these cost increases for the IBR.  By postponing the next cost estimate until the summer of 2025, ODOT is concealing this information from the Legislature as it debates a major transportation measure.

This process is a classic example of what Bengt Flyvbjerg diplomatically calls “strategic misrepresentation”—what we would more colloquially call lying:  in this case, low-balling the cost estimate to get the project started and get an initial commitment of funds, and then jacking up the price tag when its “too late” to consider anything different.

And the agency has essentially no process for managing or preventing cost increases.  The price of the I-205 Abernethy Bridge has tripled to $750 million; the price of the I-5 Rose Quarter project has quadrupled to $1.9 billion.  And the financial tools that ODOT says it uses to control costs, grandly called the “Cost Estimate Validation Process” (CEVP) do nothing.

As we’ve pointed out before, the CEVP doesn’t so much manage or prevent risks as document how devastating they are when they occur.  In the case of the Columbia River Crossing, the CEVP process failed completely to identify the cost and schedule risk of the Coast Guard’s decision not to agree to a 95′ navigation clearance, which added more than a year and tens of millions of dollars to project’s cost.  In the case of the IBR, just this year, the CEVP process grossly underestimated the likelihood and schedule risk of IBR’s flawed and outdated traffic models, which were thought to add no more than a six month but are now understood to delay the project by as much as 18 months.

Perishable, special, and local: The economics of unique and fleeting experiences

I pity you, dear reader.  You likely have no idea what a real strawberry tastes like. Unless you spend the three weeks around  the Summer Solstice in the shadow of this mountain, chances are you have never tasted a Hood strawberry.

The Hood is a variety grown exclusively in the Northern Willamette Valley of Oregon, on family-owned farms scattered around the edges of Portland’s urban growth boundary.

The Hood is as different from an industrial strawberry as an heirloom tomato or a piccolo San Marzano is from their rubber factory-farm cousins.

You may not know, for example, that strawberries have juice.  They were meant to be a juicy fruit.  The industrial strawberry has been bred to be a fibrous, indestructible and indefinitely shelf-stable.

You may also not know that a real strawberry is monochromatic:  It is red, without a trace of white.  When you cut a Hood  strawberry open, and it is red through and through (and bleeding, in consequence of its wound).

The Hood is a fragile vessel for carrying strawberry juice.  It’s both delicate and perishable, taking about three days from being picked to dissolving. It can’t be shipped. You either get it at a farmer’s market, go to the farm and “U-pick” the berries yourself, or find one of a relative handful of markets who’ll stock the tender things. It’s one of the things–along with the ending of the rainy season, that marks the beginning of summer in Oregon.  And it’s just here for a few weeks: gone before the end of June. We’re not alone in our obsession: actual scientists say the same thing about the Hood.

The point here is not to brag on the Hood Strawberry (well, not entirely). The point is that in an increasingly globalized world, where often seems everything is the same everywhere, thanks to a combination of the World Wide Web, Starbucks, and Fedex, there are still some things that a distinct and different about every single place. These local goods (and services) things that you can’t get unless you’re there, and that you are simply unlikely to know anything about, absent local knowledge, are what make that place special. Ubiquity is over-rated. What matters isn’t the ubiquitous, the interchangeable, the digital. What makes things interesting and desirable is that they are special, and different and even transitory. If you’re not in the right place and the right time, you’ll not discover or enjoy them.

The growth of global scale commerce has diminished and obliterated many of the differences that characterized different regions and and cities.  As Economist Tibor Scitovsky observed in his book “The Joyless Economy,” mass production systematically reduced the variety of craft offerings available to consumers.  But some local distinctions still persist.  At City Observatory, we’ve documented how consumers prefer local restaurants to national chains, and shown that some cities have much higher concentrations of local businesses than others.

The local, the seasonal, the special, all give us value and produce joy.  A couple of years ago, on Twitter, Paul Krugman waxed poetic about fruit and economic theory.  Krugman is 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.

Krugman’s observation rings true.

Every city and every place has some special, idiosyncratic feature, it could be food, or music or plants or the smell of the forest after a rain. As Jane Jacobs observed:

“The greatest asset that a city can have is something that’s different from every other place.”

Maybe the thing we need to pay attention to in thinking about the global economy is not “the death of distance” but instead “the dearth of difference.” The more things and places and experiences become standardized, homogenized and universal, the less joy and stimulation we’re likely to get from them. I’m going to grab a handful of Hoods; I hope you’ll enjoy something fresh and local, too.

Here’s Krugman’s full ode to seasonal fruit, from Twitter:

Look, the planet and the Republic are both in grave danger, possibly doomed. But it’s Friday night, I’ve just had a couple of glasses of wine, so I’m going to talk briefly about … fruit and economic theory.

OK, two pieces of background. I recently got back from almost a month in Europe, cycling and vacationing, and while it’s nice to not be living out of a suitcase, the adjustment back to reality is proving a bit harder than in the past, for a variety of reasons

The other piece of background is that I’m really into breakfast. I start almost every day with fairly brutal exercise – I’m 66 and fighting it; today that meant an hour-long run in the park. Breakfast, usually starting with yoghurt and fruit, is the reward.

So one of the best things about coming home is that some seasonal fruits — things that aren’t available all year round, at least in version you’d want to eat – have arrived. Mangoes! Fresh figs!

Are these fruits better than other fruits? Objectively, no. What makes them so great now is precisely the fact that you can’t get them most of the year. And that, of course, tells you that standard consumer choice theory is all wrong

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.

Does this have any policy implications? Probably not. What really really matters is being able to afford health care, decent housing, and good education; the things I’m talking about are trivial.

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. Limits are part of what makes life worth living. And the big question is, will those peaches be ripe by morning?

Portland’s $30 Million Container Shipping Folly

Cargo cults are a well-documented sociological phenomenon:  Cargo cults were religious movements that emerged among indigenous people in Melanesia during the early to mid-20th century. The cults were inspired by  the arrival of European colonizers and the material goods they brought. The islanders observed the seemingly magical ability of outsiders to receive vast amounts of supplies and desired objects. The natives didn’t understand the complex economic systems behind these goods and believed they were supernatural gifts. To emulate the magic of the outsiders, the natives performed rituals and practices aimed at appeasing spirits to obtain this “cargo” for themselves often mimicking the trappings of the colonizers, like building crude imitation docks, landing strips or radio towers.  Very much in that vein, Oregon leaders are proposing to prop up a similar cargo cult edifice, in the from of Portland’s failing container terminal.

Oregon policymakers are poised to pour $30 million per year of taxpayer money into a decades-old pipe dream: reviving container shipping service at the Port of Portland. Governor Tina Kotek has asked the legislature to subsidize this nostalgic cargo cult plan under the mistaken belief it will bolster the state’s economy. This is perhaps the most vexing example we’ve seen of policymakers chasing the symbolic images and physical artifacts of a bygone era rather than understanding the real economic forces driving growth and prosperity today.

An honest look at the economics of the container trade tells us this effort is doomed to failure—and irrelevant to our economic future.  Even at its heyday, Portland was never more than a bit player in the containerized shipping game, handling under 2 percent of West Coast traffic. Most container shippers already abandoned the Port of Portland’s container facilities once, from  2015 through early 2020. And what happened next? Oregon’s economy not only survived — it thrived, boasting record economic growth, exports and prosperity during the multi-year period sans local container service. Job opportunities kept expanding as countless innovative companies launched or relocated here, drawn by the talented workforce pipeline and entrepreneurial vision.  The growth of Oregon exports accelerated after the end of container service in Portland in 2015, with total exports growing from $20 billion annually to more than $34 billion in 2022.  Lack of container service was no brake on growth because the vast majority of this output was high value products like electronics, with negligible transportation costs.

The naïve assumption that goods transportation  is essential for urban economic success has been thoroughly debunked by economists like Ed Glaeser and development patterns nationwide. Glaeser wrote:

. . . over the twentieth century, the costs of moving these goods have declined by over 90% in real terms, and there is little reason to doubt that this decline will continue. Moreover, technological change has eliminated the importance of fixed infrastructure transport (rail and water) that played a critical role in creating natural urban centres . . . These reduced costs, and the declining importance of the good-producing sector of the economy, means that in our view, it is better to assume that moving goods is essentially costless than to assume that moving goods is an important component of the production process.

Thriving cities like Denver, Austin, Nashville and Minneapolis clearly demonstrate you don’t need container cranes in your skyline to cultivate a world-class, globally-connected regional economy in the modern era. Production has long since decoupled from high shipping costs, and save for a handful of load center ports like Los Angeles, container shipping is a money losing business — lessons Portland’s cargo cultists stubbornly refuse to learn.

Even the temporary blip of container services resuming in Portland during COVID-19’s supply chain chaos failed to generate positive returns, underscoring how thoroughly uncompetitive its port infrastructure and economics have become. The Port of Portland reports losing $14 million last year alone on its container operations.  The industry is rapidly consolidating into mega-vessel, networks that can only call at a small number of deep-water ports like Los Angeles/Long Beach, leaving decreasingly tiny opportunities for smaller players.

The romanticized imagery of containers may have been an apt avatar for the globalized physical economy of the 20th century. But today those iconic boxes are merely symbols of an economic paradigm that Portland and most other successful metro areas have already outgrown. Futilely throwing $30 million per year at this nostalgic cargo cult is simply flushing taxpayer money down the drain.

If state leaders actually want to cultivate a robust economic future for Oregon, they need to focus on the real drivers of modern prosperity: human capital, amenities to attract talent, innovation ecosystems, and entrepreneurial environments. Not outdated boxes on a boat. Stop chasing the hollow symbols of the past and start capitalizing on Portland’s 21st century strengths. Our economy has clearly moved on — it’s time for policymakers to do the same.

The Oregon Department of Transportation (ODOT) has proposed a $1.9 billion freeway widening project for Portland’s Rose Quarter.  The agency proposes to cover a portion of the freeway in what it calls “restorative justice” for the Albina neighborhood, that was decimated by decades of earlier ODOT highway building.

But ODOT claims it can’t spend highway money to repair the damage its projects have done—and continue to do—to the historically Black Albina neighborhood.  That’s a clear misreading of federal law and policy, which imposes a substantial burden on ODOT to identify and mitigate the damage—past, present and future—from its highway projects.

Rhetorical contrition isn’t enough. Simply acknowledging the damage that its previous projects have done to the Albina neighborhood doesn’t comply with the law:  the Oregon Department of Transportation has a legal obligation to mitigate the effect of its past discriminatory practices.

Federal regulations both allow and require the mitigation of negative impacts caused by highway projects, including impacts on neighborhoods and housing losses. Several federal laws and policies mandate identifying and mitigating adverse effects on communities, including social and economic impacts on communities, not just impacts on the natural environment:

• The National Environmental Policy Act (NEPA) requires assessing adverse impacts and mitigating them, including impacts on the community environment through restoration or providing substitute resources.
• The U.S. Department of Transportation’s Environmental Justice policy requires addressing and mitigating the cumulative negative impacts of transportation projects on community cohesion and economic vitality.
• Title VI of the Civil Rights Act requires recipients of federal funds like ODOT to take affirmative action to overcome the discriminatory effects of previous highway projects.
• The new Reconnecting Communities program allows funds to be used for mitigating impacts identified through the NEPA process.

These regulations authorize and require the Oregon Department of Transportation to spend funds repairing the damage its past highway projects have done to the Albina neighborhood in Portland. ODOT’s own Environmental Assessment acknowledges demolishing 450 homes in Albina for highways like I-5, leading to a population decline from over 14,000 in 1950 to around 4,000 in 1980.

However, ODOT has falsely claimed it cannot spend highway funds on mitigation efforts, whether they involve building housing to replace demolished units, or even the added cost of strengthening proposed highway covers to support anything other than streets. There are many examples of how federal highway funds are routinely used for mitigating a wide range of impacts, including:

• Restoring wetlands, fish habitats, and building sound walls to reduce highway noise pollution
• Off-site improvements like paying for a new jail when the I-205 route impacted the existing facility
• Funding community development projects in the historically white Northwest Portland neighborhood impacted by I-405, while not doing so for Albina

Nationally, there are many examples of state DOTs using federal highway funds specifically to build new affordable housing to mitigate the impacts of highway projects:

• Kentucky used funds to establish a community land trust for up to 100 homes impacted by a highway widening project through a Black neighborhood.
• The Texas DOT allocated $27 million for building affordable housing impacted by the I-45 expansion in Houston.
• Nevada DOT provided funds and land for affordable housing replacement due to impacts from highway work in Reno.

using highway funds to restore housing lost to highways in Albina would achieve the “restorative justice” that ODOT claims to support. The I-5 Rose Quarter’s own public involvement efforts have found that the community has identified affordable housing as the top priority based on ODOT’s own public outreach.

Federal regulations give ODOT the ability and responsibility to use highway funds to mitigate past harms to Albina through efforts like rebuilding demolished housing units. It provides examples of how this approach has been implemented elsewhere as evidence that ODOT can and should take similar measures.

City Observatory has prepared a detailed memorandum documenting each of these laws and policies, and illustrating examples of how highway funds have been used to pay to mitigate the social and enviornmental effects of present and past freeway construction.  It is available here:

The $7.5 Billion Interstate Bridge Project is two years behind schedule

IBR’s Draft SEIS was supposed to be complete in December 2022—It now won’t be done before December 2024.

This two-year delay means the environmental review has taken twice as long as IBR promised

Not to worry, because the consultants will continue billing, and their total costs are now more than $200 million

Two Years Behind Schedule

The Interstate Bridge Project is two years behind schedule.  In December 2020, IBR told the Oregon and Washington Legislatures that it expected to publish and receive comments on its Supplemental Draft Environmental Impact Statement (SDEIS) by the end of calendar year 2022.  This key milestone has to be completed before the project can move on to construction.

As of now, it appears that the IBR may not even release its Draft Supplemental EIS much before the end of 2024, with the comment period possibly extending into the first quarter of 2025.  That would put the IBR project more than two years behind its own announced schedule.  This schedule implied that it would take two  years to complete the DraftSEIS process (from December 2020 to December 2022)—it’s now apparent that completing the Draft SEIS process won’t be completed until December 2024—a full two years longer, twice as long as described in that schedule.

This schedule spelled out specific milestones that it said it had agreed upon with the US Department of Transportation, i.e. completing the NEPA process by mid-2023, and starting construction in mid-2025.

According to the latest publicly available project schedule (dated May 4, 2023), IBR forecast that the Supplemental Draft Environmental Impact Statement would be released to the public in December 2023, and that a Record of Decision would be issued approximately a year later (in December 2024), and that construction would start a year later in December 2025.

That schedule shows that it will take two full years to move from issuing the SDEIS to actually starting bridge construction.  If the SDEIS is issued in December of this year (2024), that means that a ROD would be likely issued in December 2025, and construction would start in December 2026–a year later than forecast in 2023, and a year a half behind the announced 2020 schedule.

There’s little reason to believe the project can meet that schedule.  As the experience of the I-5 Rose Quarter project illustrates, completing the environmental review is no guarantee that the project will move ahead quickly.  ODOT got its initial “finding of no significant impact” in 2020, but then had to withdraw it, and four years later, there’s still no assured schedule of when the project will move forward.  The previous project, the Columbia River Crossing, finished its draft environmental impact statement in 2008, but didn’t obtain a  record of decision until 2011, before finally collapsing three years later in in 2014.  The plan to move from a draft supplemental environmental impact statement to a record of decision in just a few months seems plainly unrealistic, given this history.

Deadlines disappear down the memory hole

Transportation projects are claimed to always be “on schedule,” because transportation departments routinely change the schedule (move the goalposts) to reflect delays.  The IBR project has repeatedly changed the deadline for this key environmental report—but has never acknowledged that the original project schedule called for it to be completed in 2022.

In October, 2023, The Columbian reported

I-5 bridge environmental impact statement delayed, again — this time until 2024

Administrator: ‘We’re still on time and on schedule at this point’

On February 24, 2024, The Columbian reported that the EIS would be available in late April of 2024.

Columbian reported that the original deadline for the EIS was summer of 2023.   In April 2024, the Columbian told its readers

“Originally intended to be released last summer [2023], the document’s release has been pushed back a handful of times.”

But the Columbian dutifully repeated IBR claims that  the project remains on schedule, even though the release of the key environmental document is now more than two years behind the schedule announced by the project in 2020.

State transportation departments simply shamelessly re-write their schedules, and never own up to the fact that they are spending more money, and taking more time than promised when the project was originally announced.  The Oregon Department of Transportation has done this with its Newberg-Dundee Bypass—a years-delayed project that is still only half completed and has already gone well over its originally announced budget—claiming at a ribbon-cutting ceremony that the project was “on time and under budget.”  Similarly, ODOT spent $1 million on a McKinsey report on its management problems which conveniently omitted details of the department’s largest cost-overrun—a project that was several years behind schedule and cost nearly 3 times its original budget.

No accountability or consequence:  Connected consultants keep on billing

Highway agencies are apparently without either honesty or accountability for blowing through schedules and budgets.  And their consultants are more than happy to keep working—and keep billing—no matter how long the project takes.  The Interstate Bridge Project is a warmed-over version of the failed Columbia River Crossing—which itself reaped nearly $200 million in fees for consultants a decade ago.  Oregon and Washington have already awarded another $200 million for consulting work on the IBR, even though project director Greg Johnson has characterized the IBR as “basically the same project” as the old CRC.  Meanwhile, the cost of the proejct has increased from $4.8 billion to $7.5 billion and seems likely to go as high as $9 billion.  There are no consequences for cost overruns or schedule delays, except that Johnson’s former employer, the engineering firm WSP has reaped more than $75 million in fees, and stands to get even more money as the project drags on.

Note:  This commentary has been revised to more accurately reflect current information on the likely release of the Draft Supplemental Environmental Impact Statement.  In a response to a public records request received today (May 6), Washington State Department of Transportation officials say that the project has produced no new schedule for the project in the past five months.  Press accounts say only that IBR officials say the DSEIS will come out “later this year.”

Once again, Portland loses container service:  the economic effects will be minimal.

Economic development has long been obsessed with “cargo cult” thinking:  the idea that economic prosperity is caused by ports and highways moving raw materials and finished goods.  That may have been partly true in the 19th Century, but today the sources of prosperity are quite different, having primarily to do with a city’s ability to aggregate and concentrate talent, to innovate and to learn.  But many still cling to the simpler and more tangible icons of the past, like container ships and railroads.

This week, the Port of Portland announced that it would be ending container service at its Terminal 6 on the Columbia River.  It is the second time in a decade that the Port has shuttered its money losing container terminal.

Containers in Portland:  A declining and small business

Buoyed by a brief period of panicky shipping during Covid-induced supply chain disruptions, Portland enjoyed a brief, but entirely temporary spurt of container traffic.

The truth is that Portland was never more than a bit player in the West Coast container market, peaking at about 2 percent of all West Coast container movements, and with a steadily decline in activity from the 1990s.  Container traffic has increasingly gravitated to “load center” ports, like Los Angeles-Long Beach which have facilities to handle the largest container ships, and where huge facilities and frequent sailings mean that shippers get much faster and more reliable service, and can reap economies of scale.

For smaller ports like Portland, containers are a money-losing proposition:  The Port of Portland lost $100 million on the container business over a decade before shutting down its container terminal in 2015.  Having lost $14 million on its container operations in the past year, the Port is once again pulling the plug because it would have had to subsidize traffic to the tune of almost $100 per container to stay in the business.

The pandemic was an extraordinary moment when the global supply chains seized up, and that produced a spasm of activity to try to quickly find new ways of getting goods to market.  Congestion and backlogs at major ports prompted shippers to find workarounds, leading to a brief surge in business for minor ports, like Portland.  But in the past two years, conditions in the transportation and logistics markets have normalized.  International freight rates, which shot up during the pandemic, have collapsed.  Trucking activity has similarly gone into decline.  And there’s plenty of capacity, especially in the nation’s load-center ports, to handle traffic more efficiently than ever.  And going forward, the ever-growing size of containerships will further concentrate activity at the biggest ports.

An economic non-event

The good news is that container traffic isn’t particularly important to the health of the Portland economy.  Moving physical stuff has long since stopped being a determining factor in economic growth.

Over the past decade, Portland’s economy has outperformed the US economy and the typical large metropolitan area, with total gross regional product increasing by nearly 34 percent, according to the Brookings Institution’s Metro Monitor.

One of the shibboleths of economic development is that we live in a “freight-dependent” economy.  And while the Covid pandemic revealed the vulnerability of the global logistic system to extraordinary disruptions, these have proved, like toilet paper shortages, to be short-lived.  To a certain breed of economic developers, it will always be hard to let go of the “cargo-cult” view of economic prosperity, but for most metropolitan areas, their long term success will hinge on the education level of their population, the entrepreneurship of their businesses and their ability to innovate new ideas, not the presence of container cranes.

The $7.5 Billion Interstate Bridge Replacement project will save the average commuter just 30 seconds in daily commute time

IBR officially determined that “leaking” the project EIS would result in “negative public reaction” to the project

Guess what:  We have an advance copy of the draft EIS:  You can now see what they don’t want you to see.

Oregon and Washington DOTs claim that a massively widening I-5 bridge and approaches is needed to fight congestion between Portland and Vancouver—but their own traffic modeling shows the project will make almost no difference in average commute times.

As we wrote last month, via a public records request, No More Freeways has obtained a copies of previously confidential IBR planning documents that have key facts about the project which would build a 5-mile long, 10- or 12-lane wide highway between Portland and Vancouver, t at cost of $7.5 billion (and likely more).  One of the reasons they kept these documents secret was because they were afraid that a “leak” of the document would adversely affect public opinion.  The project’s previously secret risk register reported:

During the preparation of a draft Supplemental Environmental Impact Statement (DSEIS) admin drafts are shared outside of partner agencies and leaked to the public, resulting in negative public reaction and potentially hindering the decision-making process. The potential negative public reaction could lead to increased pressure on decision-makers to reject the proposal or make changes to it, which could ultimately delay or impact funding to the project

What is it, exactly that they don’t want you to know?

Spending $7.5 billion will save the average commuter 30 seconds a day

Well for one thing, spending $7.5 billion (or more) will do virtually nothing to speed up commutes in the project area.  The project’s draft Environmental Impact Statement presents data on how far people will travel, and how many hours they will spend traveling. The project’s traffic studies, based on the Metro Regional Travel Demand Model, compare how much time we’ll spend traveling in 2045 depending on whether the IBR project is built (the “Build” scenario) or not build (the “No Build” scenario.). These estimates are summarized for the project area (the portion of the region involving travel affected by the project).  This comes from Draft Environmental Impact Statement’s chapter on travel.

From this data its easily possible to figure out how much faster this multi-billion dollar project will make things.  For example, in the “No-Build” scenario, we’ll drive about 14.3 million miles per day, and spend about 436,000 hours making those trips.  If you divide the number of miles by the hours of travel, you get an average speed of 33 miles per hour (in the No-Build). To be sure, in in the “Build” scenario we would drive almost the same number of miles (14.2 million) but spend about 12,000 fewer hours doing so, which results in an increase in speed of . . . 0.4 miles per hour.

If that doesn’t sound like much, that’s because it isn’t.  That’s well within the likely margin of error of Metro’s ability to forecast future traffic and travel times, which means in statistical sense, the difference is really zero.  But even if it is the 0.4 miles per hour improvement that IBR claims, should we care?

To put that gain in context, let’s look at the typical commute trip in the region. According to Metro, the average one-way commute in Portland is 7.1 miles.  By speeding trips up from 33.0 miles per hour to 33.4 miles per hour, the Interstate Bridge Replacement Project will shave about 15 seconds off the average commute.  On a daily basis, that works out to a savings of 30 seconds.  Is that worth $7.5 billion, and probably a great deal more?  You be the judge.

If anything, the Metro model, as used by IBR, probably understates the effectiveness of the project, because it fails to fully account for the effects of induced demand:  adding more capacity will likely encourage additional travel, and that added travel will cause congestion to return (and travel times to degrade) to pre-construction levels.  The widely documented “fundamental law of road congestion” underscores the futility and waste of trying to solve congestion by adding more road capacity; the science is neatly summarized by the brilliant Australian show “Utopia.”

Want to know more?

The Just Crossing Alliance has posted a copy of the Draft Supplemental Environmental Impact Statement on its website.

We invite the public to take a close look.  In the coming days, we’ll have more to say about what’s in the document that the Washington and Oregon highway departments didn’t want you to see.

The $7.5 Billion Interstate Bridge Replacement project is afraid of what you’ll find out when they release their Environmental Impact Statement

IBR officially determined that “leaking” the project EIS would result in “negative public reaction” to the project

Guess what:  We have an advance copy of the draft EIS:  You can now see what they don’t want you to see.

Via a public records request, No More Freeways has obtained a copy of the “risk register” for the proposed I-5 Interstate Bridge Replacement Project, which would proposed a 5-mile long, 10 or 12 lane wide highway between Portland and Vancouver, to be built at cost of $7.5 billion (and likely more).

The risk register spells out everything that could affect the project’s cost or schedule.  We were particularly intrigued to read risk #246:

During the preparation of a draft Supplemental Environmental Impact Statement (DSEIS) admin drafts are shared outside of partner agencies and leaked to the public, resulting in negative public reaction and potentially hindering the decision-making process. The potential negative public reaction could lead to increased pressure on decision-makers to reject the proposal or make changes to it, which could ultimately delay or impact funding to the project

IBR is concerned that an early release of the Draft Supplemental Environmental Impact Statement will trigger a “negative public reaction,” and “hinder the decision-making process.” – meaning the project is delayed or opposed.

The project identified the steps it would take to make sure the public didn’t find out about what it was planning.  It’s “Risk Response Strategies” were to:

1) Ensure drafts are confidential and secure (e.g., utilizing password protected portals, marking documents with disclaimers). Consider the use of watermarks.

2) Work with partner agencies and communicate the legal implications of sharing drafts outside their agencies.

And IBR consultants diligently tracked progress to date:

Q4 2023: No significant/unmanagable [sic] leaks identified so far.
Q2 2023: Sent drafts to Agencies in early June 2023, have not heard of any
leaks to date. Will continue to monitor throughout the end of the calendar year.
Revisit risk Q3 2023.

In short, the EIS has been basically done for the past nine months, but ODOT and WSDOT are powerfully afraid that the draft document might leak out, and that when it does, the public will be outraged.

What could be hidden in the EIS?

You won’t have to wait, because the Just Crossing Alliance has obtained a copy of the Draft Supplemental Environmental Impact Statement—which still hasn’t been released to the public.  (Metro released its copy to the JCA to comply with Oregon’s public records law).

There’s a lot to read, here’s a start:

The IBR is still a pig-in-a-poke:  The Draft SEIS still isn’t saying what kind of bridge the project will build, whether it will be single-level or double level, or whether it will have a lift span.  Despite the fiction that they are proposing a single Build alternative, the project still won’t advance the actual design it plans to build.  And make no mistake, a double-decker bridge has much different environmental impacts than a single level.  The single level causes more land-side disruption, and casts more shadows over the river’s fish habitat.  The two-deck bridge has much steeper on and off-ramps with real safety issues.  And whether the bridge has a lift-span or not makes a major difference to river traffic and long-term economic development.  By not choosing just one design the draft SEIS hides this decision and its consequences from public view.

Visual impacts are still hidden from view.  For years, the IBR project has got to great pains to conceal the visual impacts of its massive bridge, which will tower over the Vancouver waterfront, and construct wide elevated freeways over much of downtown Vancouver and Hayden Island.  There’s still precious little in the DraftSEIS to show what this will really look like, even though IBR has spent nearly $200 million on consultants, and of that, more than $1.5 million building a detailed “digital twin” of the bridge.

Say good-bye to the Hurley Building.  While there aren’t any pictures in the EIS, there is this ominous note buried in the Draft SEIS.  Under land use changes, the report says, vaguely:

“Would displace the Hurley Building (commercial office use) in Vancouver.”

The 6-story Hurley Office Building, a recent signature addition to the Vancouver skyline appears doomed.  The DEIS implies it will be demolished to make way for the elevated approaches to the towering new I-5 bridge.

The Just Crossing Alliance has posted a copy of the Draft Supplemental Environmental Impact Statement on its website.

We invite the public to take a close look.  In the coming days, we’ll have more to say about what’s in the document that the Washington and Oregon highway departments didn’t want you to see.

There’s a yawning chasm of neighborhood level economic distress across US metro areas.  While about 1 in 6 US neighborhoods is classed as distressed, some metro areas have large concentrations of distress, while others have almost no distressed neighborhoods at all.  Focusing on groups of contiguous zip codes classified as “distressed” shows that in some metros 20 percent or more of the population lives in a distressed zip code that is part of a cluster of distress, while in other metro’s less than 1 percent of the region’s population live in such distressed clusters.  Here are the six large metro areas with the largest and smallest shares of their metro area population living in a cluster of distressed zip codes:

In short, the problem of concentrated neighborhood distress appears to be an order of magnitude greater in some metro areas than others.  The problem of persistent, concentrated poverty continues to plague some large metropolitan areas, while others have a geography of much more evenly distributed economic well-being.

These insights are based on data from a new report from the Economic Innovation Group which illustrates the widely varying patterns of neighborhood distress across the nation. EIG’s  uses a series of seven indicators, including job growth, educational attainment, poverty, housing, income, unemployment and business growth to rank states, counties, cities and zip codes as either distressed, at-risk, comfortable or prosperous.  Viewed at its finest resolution, zip codes, the index provides a fascinating mosaic of varied economic conditions.

Overall, 52 million Americans—about 16 percent of the population—live in a zip code that is classified as distressed.

Of these 12.8 million people, about a quarter of the people living in a distressed zip code in the United States live in a zip code that is contiguous to other distressed zip codes in one of the nation’s largest metro areas.

Concentrations of distressed zip codes are disproportionately located in relatively few large metropolitan areas.  Many large metropolitan areas have less than 2 percent of their population living in contiguous distressed zip codes.

Looking past the bewildering jigsaw puzzle.

Viewed at a national level, zip code data looks like a challenging jigsaw puzzle.  The one pattern that emerges consistently is the profoundly rural and regional character of zip code level distress.  Most distressed places are rural, rather than metropolitan, and the entire southern part of the country, from New Mexico to the Atlantic is dominated by rural distressed zip codes.  Metro areas, in contrast, tend to be prosperous or comfortable, and the metropolitan, and bi-coastal character of prosperity is apparent if you look closely.

Where are distressed neighborhoods concentrated?

A critical question is how is prosperity distributed within metro areas.  The great value of the EIG website is you can quickly zoom into a map of a particular metropolitan area and see the geography of distress and poverty.  Looking closely at the pattern of zip codes, some striking patterns emerge.  In most large metros, distressed zip codes tend to be found in the center of the region, and most distressed zip codes are contiguous—that is, there are clusters of distressed neighborhoods.  Some metro areas have large numbers of distressed neighborhoods clustered in their cores, others have far fewer.  Here are maps of several metropolitan areas, with zip codes colored dark red classified as “distressed.”  First, Cleveland, a long-suffering rust-belt city has one of the largest clusters of distressed neighborhoods, which dominate most of its central zip codes.  Nearly 500,000 people live in this contiguous group of 21 zip codes, about 23 percent of the metropolitan area population.

Distressed neighborhoods also occur in growing sunbelt metros as well, as this map of Houston makes clear.  Much of the region’s east side is neighborhoods that are classified as distressed.  About 12 percent of Houston’s metro population, roughly 865,000 people live in this group of 29 contiguous “distressed” zip codes.  (Note that we don’t count a second, smaller separate cluster of distressed zip codes on the city’s southwest side).

Some metro areas have few or isolated pockets of distressed zip codes, according to the EIG metrics.  The Denver and Salt Lake City metro areas have no distressed zip codes, per EIG.  The Portland metropolitan area has two distressed zip codes, with the most of the rest of the region classified as comfortable or prosperous.

Which metro areas have the most concentrated neighborhood distress?

To look at this more systematically, we counted the number of contiguous, distressed zip codes in each of the nation’s largest metro areas.  For each metro, we computed the number of people living in these distressed zip codes, and the total share of the metro area population living in one of those contiguous distressed zip codes.  Overall, 12.8 million people, about a quarter of the people living in a distressed zip code in the United States live in a zip code that is contiguous to other distressed zip codes in one of the nation’s largest metro areas.

Among metropolitan areas with a million or more population, the median metropolitan area has about 5 percent of its population living in its largest cluster of distressed zip codes.  But there’s very wide variation across metropolitan areas.  Memphis and Cleveland, for example, have more than five times as large a share of their metro populations living in a cluster of concentrated distress.  In contrast, the bottom quartile of all metro areas have fewer than 2 percent of their regional populations living in clusters of zip codes experiencing distress.

A national picture of concentrated neighborhood distress.  We’ve taken the same data shown in the figure above, and presented it in mapped form to show the pattern of variation in concentrated neighborhood distress across U.S. metropolitan areas.  In this map, the size of each circle corresponds to the number of persons living in contiguous distressed zip codes in each metropolitan area; the color of each circle corresponds to the share of the region’s population living in contiguous distressed zip codes (with green being fewest, and yellow/red most).  Mousing over the map symbols shows the number of zip codes in each contiguous cluster, and the number of persons and share of the metropolitan population living in each cluster.

There are clear geographic patterns here:  Rustbelt cities tend to have much larger shares of their population living in contiguous distressed zip codes.  Most Western metro’s have relatively small shares of their population living in such neighborhoods.  The pattern in the US South is varied.  And many fast-growing metros have higher proportions of concentrated distressed zip codes:  Oklahoma City, Houston, Las Vegas and San Antonio all have two to three times as large a share of their population living in contiguous distressed zip codes than in the median large metropolitan area.

There are strong reasons to focus on these clusters:  There’s a powerful body of evidence that concentrated poverty–living in a neighborhood where a high fraction of your neighbors are poor, has more devastating effects.  A single, isolated zip code that gets classified as “distressed” is a far less intractable problem than a contiguous cluster of 10 or 20 such zip codes.

About the EIG Distressed Communities Index

The methodology of the EIG Index is explained on its website.  The index consists of seven different indicators, which represent a mix of socio-economic and housing indicators.

Our thanks to EIG for publishing their zip code level maps in a publicly accessible format.  The conclusions presented in this commentary are those of City Observatory, and not necessarily EIG.

Wouldn’t it be nice if we could create valuable new urban land by decking over freeways?

Turns out, its massively uneconomical, and doesn’t eliminate many of the most negative effects of urban freeways

Its massively uneconomical because that “land” thats created by capping freeways costs at least three times more to build than the land is worth.

While covering up a freeway made hide it from view, it does nothing to eliminate the flood of cars and their associated pollution, which simply spew out from under the covers.

Should we pay $5 to create $1 worth of urban land?

There’s a Seattle proposal to create 17 acres of land in the center of the city by building a cap over I-5.  Rough estimates are that the cap would cost up to $2.5 billion.  Long division tells us that creating an acre of land would cost $150 million (that’s without any improvements, and likely without the cost of necessary utilities or adequate substructure to support buildings).  For reference, the average value of square foot of downtown property in Seattle ranges between $500 and $1,500 per square foot.  Even if land over the freeway were worth the midpoint of that range, about $1,000 per square foot, that means an acre of land is worth about $43 million, and 17 acres, in theory, would be worth $700 million or more.  But at typically land needs to be dedicated to street rights-of-way and the net buildable land would perhaps be 80 percent of the total, worth about $500 million or so.

In Seattle, cover proponents argue that the cost of the newly created land can be offset by selling it off for development as apartments or offices.  But no one can afford to pay anything approaching the actual cost of creating such land; at best land sales might recoup a small fraction of the cost of And a $2.5 billion cost estimate for a freeway cover is highly suspect.  On its face, spending $2.5 billion to create $500 million worth of land is a value-destroying proposition.

Washington’s Legislature is likely to pull the plug on a far simpler cover proposed for State Route 520 because of a 70 percent cost overrun.  Portland’s I-5 Rose Quarter project shows how much the price tag of freeway caps can balloon:  the project, featuring a cap over I-5 near downtown Portland has quadrupled from $450 million in 2017 to $1.9 billion last year.

The Rose Quarter project also reveals some of the difficulties with creating covers that can support buildings.  Not all of the land on the covers can be built upon:  some structural elements of the cover have to be kept clear.  Even the parts that can be built on may be restricted to “lightweight” structures.

The perpetrators are asking their victims to pay for fixing the damage done to cities

And finally, there is the issue of who will pay.  Everyone agrees that caps are nice things to have, but highway departments are remarkably loathe to actually pay the cost of patching the scars they’ve inflicted on the urban landscape.

In Austin, TXDOT has flatly refused to pay the cost of “stitches” over a widened I-35 freeway, and is passing the entire cost off to the City of Austin, which will have to come up with as much as $800 million.   The stitches (small bridges with pedestrian amenities) and caps (block long or longer covers), would also have to be maintained by the city at a cost estimated at as much as $48 million a year.

In Dallas:  Cost of trenching I-345 rose from $1 billion to $1.6 billion; and of course, that price tag doesn’t include the cost of covering the freeway, which TX DOT won’t pay for, but instead will become the responsibility of the City of Dallas.

In Denver, Colorado spent roughly 10 percent of the cost of its $1.3 billion I-70 freeway widening project to build a four-acre park atop the roadway.  Neighborhood residents are still concerned about pollution levels near the freeway.

In Portland—where a mile and half long freeway widening project has exploded in cost from $450 million to $1.9 billion—the Oregon Department of Transportation claims it can’t legally pay for any supporting structures beyond those needed to hold up the roadway itself—and that someone else will have to pay the costs of beams strong enough to support buildings.

It’s nice to imagine a world where urban highways didn’t gouge massive scars on city neighborhoods.  And predictably attractive green artistic renderings of what a covered area might look like are, at least when viewed from a distance, more attractive than noisy car-choked roadways.  But as a way to create more urban land, decking over highways is one of the most expensive ways to expand our urban area.  And, in a just world, the highway agencies that carved the scars across the nation’s cities would pay to repair the damage done, in the form of replacing the homes and businesses they destroyed; but in reality, highway agencies plan to foist most of the costs of covers, caps and stitches onto their victims:  the cities eviscerated by highway construction.

How ODOT is trying to re-write history to create a commitment to freeway cost overruns.

The 2017 Legislature authorized zero funding for the I-205 Bridge project

In 2024, ODOT now falsely claims that the I-205 project was a “commitment” of the 2017 Legislature

The original HB 2017 only directed ODOT to produce a “cost to complete” study by 2018,

ODOT”s “Cost to Complete study said the Abernethy Bridge would cost $250 million—its price has now tripled to $750 million

ODOT falsely claims it can’t spend money on preservation and maintenance because of these imaginary “commitments” to freeway expansion.

As George Orwell wrote in 1984, those who control the present, control the past and those who control the past control the future.

“The past was alterable. The past never had been altered. Oceania was at war with Eastasia. Oceania had always been at war with Eastasia.”

In true Orwellian fashion, ODOT is shamelessly re-writing legislative history, manufacturing a supposed funding “commitment” to a massive highway expansion project that was specifically left out of that 2017 legislation.

The Oregon Legislature’s joint transportation committee is holding a “roadshow” a series of statewide hearings to drum up support for a 2025 transportation spending package.  It’s given most of the time on the agenda over to the Oregon Department of Transportation to frame the issue.  And ODOT has done so in the most misleading and inaccurate way.

ODOT, of course, presents this almost entirely as a revenue problem—ODOT simply hasn’t been given enough money—notwithstanding the massive transportation funding bill passed by the Legislature less than seven years ago.  The agency says that it is merely following through on the “commitments” made in HB 2017, passed in 2017.  Here’s the slide from its June 4, 2024 presentation

Seven years ago, in 2017, the Oregon Legislature passed a major transportation bill, HB 2017, which included modest funding for one interstate highway expansion project ($450 million for the I-5 Rose Quarter widening), and no funding at all for a second project, reconstructing part of I-205 (widening the existing I-205 Abernethy Bridge, in one phase, and then widening a five mile stretch of highway in a second phase).

The law adopted by the 2017 Legislature (Chapter 750 Oregon Laws, 2017) contained no funding for the I-205 project. The Legislation mentions the I-205 project, but only instructing the Oregon Department of Transportation to come up with a cost-estimate for the project.

The Legislature didn’t appropriate any money for the actual construction of the project.   Instead, the Legislature’s Ways and Means Committee added a “budget note”—a kind of non-binding advice—directing the Oregon Department of Transportation to explore using congestion pricing funds to pay for I-205 in the future.  In essence, the Legislature said, if and when we toll I-205 we might use toll revenues to pay for the project.

A budget note doesn’t have the force of law, and only applies in the two-year biennium for which the budget was adopted; this budget note expired on June 30, 2019.  This fact is acknowledged by ODOT:

Upon passage of HB 2017, the legislature included a “budget note” directing ODOT to dedicate value pricing revenue for funding congestion relief efforts along I-205, particularly the I-205 Stafford Road to Abernethy Bridge projects. The note attached to ODOT’s 2017-2019 budget was in effect through the
duration of the budgetary biennium, which ended June 30, 2019. Beyond the period of time covered by the budget note, the Oregon Transportation Commission will set policy for where revenue from value pricing should be directed, subject to further direction from the Legislature.
(Emphasis added)

ODOT excels at playing three-card monte with its budget, “finding” money for projects it wants to build, and while slashing spending on basic operations and preservation.  In 2018, after the Legislature provided no funding for the I-205 Abernethy Bridge project, ODOT suddenly “found” more than $50 million in “savings”, “unanticipated revenues” and “unexpended funds” with which to launch the unfunded bridge project.  And it also assumed that someday, somehow, it would have funds from the future (and as yet unimplemented Regional Mobility Pricing Program to pay for the bridge.

As we’ve already chronicled at City Observatory, ODOT’s cost to complete report claimed that widening the I-205 Abernethy Bridge would cost about $250 million.  That price tag has ballooned, first to $495 million in 2021, and then to $622 million, with current estimates now conceding the project would cost $750 million.

As we warned when the Legislature was originally considering HB 2017 seven years ago, the Oregon Department of Transportation was pursuing a “driving stakes and selling bonds” strategy, copied from Robert Moses:  doing anything to get a project started, including low-balling cost estimates, and then coming back to the Legislature in later years, regardless of cost increases and revenue shortfalls, and insisting on being given more money.

Now the agency is busily re-writing history.  It’s saying the 2017 Legislature “committed” to the Abernethy Bridge project and widening I-205, when it only authorized ODOT to prepare a cost estimate—a cost estimate that ODOT understated by a factor of three.  And congestion pricing–the source of funding ODOT used to rationalize issuing bonds, go into debt and divert funding from other projects—evaporated when Governor Tina Kotek pulled the plug on the Regional Mobility Pricing Program.  So in reality, there never was any kind of financial commitment to the I-205 Abernethy Bridge project.

In short, the I-205 Abernethy Bridge project, never authorized in the HB 2017 Legislation, has effectively consumed $750 million (and with interest, even more) of the resources available to ODOT.  That’s money that isn’t available for preservation and maintenance of roads.  ODOT is, once again, playing a kind of financial shell game with funding, claiming that projects it chose to advance without funding represent “commitments.”

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Illegally counting federal funds

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

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

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

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

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

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

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

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

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

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

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

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

Plenty of other problems with highway cost allocation

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

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

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

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

An imagined decline in trip-making is the result of bad data analysis

USDOT counted fewer trips in 2022, because it used a different, and less reliable survey method

USDOT’s social media created a false perception that 2022 data were comparable with earlier years

For all the time we spend talking about transportation, it’s surprising how little good data we have.  The Census Bureau asks a narrow set of questions about our daily journey to work as part of its annual American Community Survey, but this misses the vast majority of travel that is neither to or from a workplace.

The US Department of Transportation commissions a periodic “National Household Travel Survey” to as a richer and more detailed set of questions about all kinds of travel.  The NHTS serves as a vital benchmark for understanding travel patterns.

Completed in 2022, this latest survey seems well positioned to help us answer the question of how the Covid-19 pandemic changed our travel patterns. Last week, US DOT tweeted out an infographic offering a key finding from the latest NHTS.

The graphic seems to show a dramatic—even catastrophic—decline in trip making.  The headline is “Decrease in DAILY TRIPS”. the explanatory text offers “In 2022, household travel decreased compared to 2017.”  The table reports trips fell from 3.4 per person per day, to barely 2 per day.

Big, if true.  The message “decrease in trips” is  clearly the take that active transportation blogger Angie Schmitt got from the data, repeating the top-line number from the graphic, and then musing over our growing isolation, in a Substack essay entitled “Nobody’s leaving the house anymore.”

In 2017, Americans used to average more than three trips a day. Going to work and back and then going somewhere else — that’s three trips. And also maybe they went to the store every other day, or a friend’s house. Now, people are taking just a little over 2 trips a day. . . .

As I said, I find this stunning. And let me explain a little more why. This is a HUGE HUGE change in the way people live their lives and their daily activity. I have been involved in sustainable transportation advocacy for over a decade, and the kinds of changes we try to implement — I cannot imagine it having an impact on this scale this quickly.

But Angie was right to describe this kind of change as unimaginable.  Upon closer inspection, the supposed decline in trip-making is likely an illusion from bad data (or, more precisely, bad data inferences).

There’s a problem with the data.  Between 2017 and 2022, the US DOT made some major changes to its data gathering methodology for the NHTS.  First, it shifted to a primarily on-line data gathering method.  Earlier surveys relied more on in-person interviews.  Second, and more importantly, the survey eliminated the “travel diary.”  Earlier versions of the NHTS sent participants a travel diary, in which to contemporaneously record their travel.  The 2022 online survey doesn’t include a diary, and relies on the recollection of participants.

As the technical notes to the study (which appear on the website of the Oakridge National Laboratory, which conducted the survey for USDOT) reveal, this change almost certainly accounts for much (and perhaps all) of the decline in reported trip-making.  Examining the results of earlier surveys, USDOT concluded that relying solely on recollection (as opposed to contemporaneous diaries) left out about 20 percent of all trips.

To be sure, it may well be that trip-making now is different (and lower) than it was pre-pandemic.  It;s just that you can’t use this data to make any reliable statements about the direction or size of the change because the methodologies are substantially different from year to year.

In Raiders of the Lost Ark, Salah snatched a poisoned date from the air just before Indiana Jones swallowed it, exclaiming “Bad dates”.  Unfortunately, we weren’t able to snatch this bad data before it got swallowed.

The critical takeaway for any user of this NHTS data has to be that it you simply can’t compare the 2017 trip-making data with the 2022 trip making data.  This shouldn’t be an obscure footnote:  it should be a cigarette-pack warning.  But, with its cute-infographic, the USDOT did exactly the opposite.  Its tweet approvingly presents the two data sets as directly comparable.  Thanks to this misinformation, we are running into the “BS-Asymmetry” problem: it takes almost no effort to use social media to create a false (but interesting) finding, and vastly more effort to correct the error.  We hope that US DOT will take steps to correct this mistaken impression.

If it were true that overall trip-making had fallen by about a third, that would have profound implications for the transportation system.  It would, for example, call into question almost every expenditure to expand highway capacity.  Its a shame that the NHTS data are presented in such a sloppy and inaccurate way, by of all entities, the US Department of Transportation.

None of this is to say that the National Household Travel Survey is useless.  The key point here is that 2022 data can’t be directly compared with earlier data to make plausible assertions about changing travel patterns.  It turns out that’s one of the big issues that we want to know about–because it definitely appears that the pandemic and the advent of work-from-home has produced some fundamental changes in travel patterns.

A central message of the highway building sales pitch is that traffic is ever-growing and ever worsening, and that we have no choice but to throw more money at expanded capacity.

The Oregon Department of Transportation (ODOT) claims that traffic is every-rising, congestion is ever-worsening, and we’re always moving more and more trucks.

The reality, as revealed by ODOT’s own statistics is very different:  Post-pandemic, traffic levels are lower than before, time lost to traffic congestion is down almost 40 percent, and fewer trucks are on Oregon’s roads.

This lower level of demand means we don’t need to squander billions on added capacity, as ODOT is proposing.  Instead, measures to reduce or manage demand, like congestion pricing, could give us much faster travel times, at far lower cost.

For decades, highway advocates have described traffic as an ever-worsening menace. That messaging was very much on display in a recent legislative hearing in Oregon.  at a meeting of the Joint Subcommittee on Transportation Planning.  At its November 6, 2023 meeting, the Joint Subcommittee on Transportation Planning heard OregonDOT’s Brendan Finn, who presented a set of slides and made a number of key claims about future trends.  Chief among them, the following:

• Traffic have already rebounded to pre-pandemic levels
• Congestion will only get worse
• Trucking will always increase

None of these claims is, in fact, true, according to data collected and reported by both ODOT and the federal government.

• Travel is consistently below pre-pandemic levels, and its flat as the economy expands
  • Traffic on I-5 is down 7% below 2019 levels in 2023, and is lower than in 2021
  • Traffic on I-84 is down 3% below 2019 levels in 2023, and is lower than in 2021
• Time lost to traffic congestion has declined by 40 percent in Portland
  • Congested lanes miles are down from 400 in 2019 to 256 today
  • Clark County vehicle hours of delay on SR 14, I-5 and I-205 are down 75% from 2019 in 2022
• Average commute times are down 10 percent
  • Portland area commute times were 26.6 minutes in 2019
  • They are now 24.4 minutes
• Trucking less than 20 years ago, and is declining
  • Truck movements across the Columbia River are down nearly 20% from 2005
  • Truck miles in Oregon are down 2.4% from 2019 levels, and down 3.9% for large trucks
  • Truck miles are expected to decline further (HCAS) and are trending below pre-Covid levels, something the ODOT economist admits he can’t explain.

The reality is, now nearly three years after the peak of the pandemic’s effect on daily travel, travel has not returned to pre-Covid patterns or levels.  Work at home has persisted.  Even though the Oregon economy has more than fully recovered the jobs and income lost in the pandemic recession, travel levels and patterns are different and lower than prior to the pandemic.  Work-at-home, at least a few days a week has become a “new normal” for a significant fraction of the Oregon workforce. Likewise, the Oregon economy (and national and global economies) have worked through the supply chain disruptions that plagued the transportation sector during, and just after the pandemic.

In short, claims that traffic is increasingly inexorably, that congestion is steadily getting worse, and we need more room for ever more trucks are flat out wrong.

ODOT’s fear-mongering predictions don’t really inform the policy debate about transportation.  They don’t explain why we have transportation issues, and what can be done to solve them.  They don’t shed any light, they only aim to generate heat.  The reason for these dire forecasts about traffic, congestion and trucking is to serve as a sales pitch for giving ODOT billions of dollars for road building.

ODOT is proposing to undertake a series of incredibly expensive highway widening projects, even as there appears to be a fundamental shift in travel patterns than undercuts the rationale for these projects.  ODOT is living in a world where Covid never happened, where work-from-home never happened, and where the long-term decline in per-capita driving in Oregon never happened.  It is proposing to three giant projects each of which cost more than $1 billion per mile (the IBR 5 miles and $7.5 billion; the Rose Quarter 1.5 miles and $1.9 billion, and the Abernethy Bridge (.5 miles and $622 million).  And it’s proposing to go deeply into debt to pay for each of these projects.

Traffic Levels are down, and staying down

What’s inarguable is that traffic levels are down in Oregon.  The key question is whether these declines persist in the post-pandemic era?  ODOT’s traffic counting staff have prepared a special report on exactly that subject which shows that traffic is not rebounding to pre-pandemic levels even three years after the height of the Covid shutdowns.  ODOT’s staff analysis of travel trends shows that traffic volumes have gone down and stayed down in the post pandemic era.  ODOT’s own traffic counting expert, Rebecca Knudsen reported in July 2023, that traffic levels on I-5 and I-84 in the Portland area were still below pre-pandemic levels in 2023, and were not increasing above 2022 or 2021 levels.  In a document entitled Pandemic Impacts on Future Transportation Planning: Implications for Long Range Travel Forecasts Knudsen reported:

This pattern holds for Portland’s busiest highways.  Current traffic volumes on I-84 in the Portland region are about 5% lower than 2019 overall, weekday volumes are about 3%;  Traffic volumes on I-5 in the Portland region are currently about 6% lower than 2019 overall, weekday volumes are about 7% lower

Traffic congestion is down, and staying down.

ODOT periodically prepares a statewide “congestion report.”  Its latest report, released earlier this year, confirms that congestion in Oregon isn’t growing.  In fact, its declined significantly, even as the state economy grows rapidly following the pandemic.

Table 9 reports 2021 data presented in Figures 17 and 18, but also includes 2019 data to illustrate the difference pre- and post-pandemic. Statewide congested lane miles were 35% lower in 2021 than 2019. The largest decline was in the Willamette Valley. Portland Metro had a 38% decrease in congested lane miles, shifting from 400 congested lane miles in 2019 to 246 in 2021. (Page 27, emphasis added.)

ODOT has a “key performance measure” for statewide traffic performance that it provides routinely to the Oregon Transportation Commission, and which is supposed to guide policy.  This measure shows that Oregon traffic congestion is down 38 percent in 2021 compared to pre-covid (2019 levels).  ODOT is doing dramatically better than its goal. The number of congested lane miles statewide has declined from nearly 500 in 2019 to 322 in 2021.

Oregon’s Portland area data is confirmed by similar data gathered by the Washington State Department of Transportation.  WSDOT’s Mobility Dashboard reports that traffic congestion is down sharply in Clark County with a persistent and sustained decline in congestion-related travel delays.  According to WSDOT data, total vehicle hours of delay in Clark County’s three principal roadways  are down more than 75 percent from pre-Covid (2019) levels.

Vehicle Delay, 1000s of hours (Clark County)

Sourrce:  WSDOT, Mobility Dashboard

Commute times are down 10 percent from pre-Pandemic Levels

Lower levels of traffic and less congestion are showing up in reduced commute times for all workers.  Census data confirm that the average commute trip in the Portland metropolitan area is about 2 minutes 20 seconds faster now than it was in 2019. The average Portland area commuter spends 2.2 minutes less time traveling to work each day according to the latest Census data, compared to the period before the pandemic.  In 2019, the average resident spent 26.6 minutes traveling to work (one way); in 2021, the average resident spent 24.4 minutes. (Census Bureau, American Community Survey). These data actually understate total time savings, because they only represent travel times for workers who still regularly work outside the home; the commute data do not include the time savings for those who work at home.

Truck freight is lower than twenty years ago and is declining

Highway boosters love to assert that unless we expand highways, our economy will somehow grind to a halt.  But the truth is, in the Internet era, and an economy shifting to smaller and lighter products and more services, and ever greater efficiency in production and distribution, truck freight movements have peaked and are declining.  Oregon’s economic growth, in particular, has de-coupled from goods movement.  ODOT’s testimony claims that truck freight in the Portland area will increase 57 percent in the next two decades, and implies we need to expand highway capacity to match.

ODOT actually has detailed data on truck freight movement in Oregon—data that wasn’t presented at the November 6 hearing.  That data shows that statewide, truck freight is down 2.6 percent from pre-pandemic levels, and is decreasing, and is expected to decrease further.  Oregon DOT’s corridor-level data show the number of trucks crossing the Columbia River today is down more than 20 percent from 2007 levels.  ODOT’s just-released revenue forecasts shows a decline in freight movement, contrary to ODOT’s earlier forecasts that truck freight would continually increase.  One reason that the recent Highway Cost Allocation Study (HCAS) shows trucks “overpaid” their share of highway expenses is that truck freight has grown much more slowly than ODOT projected.

ODOT’s statewide congestion report tracks truck mileage by weight class.  The latest report  concludes that truck VMT in Oregon is down below 2019 levels, and is down more sharply for large trucks.

What is true statewide is also true in major corridors.  One key corridor is I-5 and I-205 across the Columbia River.  ODOT’s vehicle count data show that the number of trucks crossing the Columbia River is down almost almost 20 percent since 2006.

ODOT’s forecasts of truck freight have been consistently and wildly overstated

ODOT has long predicted steady increases in trucking.  And it has long been wrong. In 2011, ODOT adopted the “Oregon Freight Plan”. It called for the volume of truck freight to increase 96 percent in 25 years, between 2010 and 2035.  This amounts to an annual rate of increase of 2.2 percent per year.  We are now more than half way through that period, and truck freight has gone down; between 2007 and 2022, truck freight volumes declined at an average annual rate of -0.2 percent per year.

ODOT’s latest financial reports concede that truck traffic is both below expectations, and is expected to decline further.  Both ODOT’s biennial Highway Cost Allocation Study (HCAS) and its October 2023 Transportation Revenue Forecast point to a decline in truck travel in Oregon.  ODOT’s own economist admits its modeling failed to accurately predict the decline in in trucking, which is now below its pre-Covid-forecast.

ODOT’s latest transportation revenue forecast reports a dramatic decline in weight-mile transactions.  ODOT’s April 2023 forecast predicted that weight mile transactions would exceed 4.6 million (orange line), instead they’ve fallen to 4.3 million (blue line), and are now below the department’s pre-pandemic (2019) forecast (green line).

ODOT’s economist is at a loss to explain this decline:

Unfortunately, the prior forecast and our current forecast model do not adequately predict the drop we are currently seeing in the weight-mile transactions. This is concerning, as the forecast model has traditionally done a good job of predicting trucking activity. The last two quarters since the prior forecast have shown a significant drop, bringing us back in line with our pre-pandemic forecast.
(emphasis added)

This clear trend puts the lie to inflated forecasts claiming truck growth would always increase.  In 2010, Metro predicted that truck freight in the Portland area would double by 2035.   In fact, as we’ve seen truck freight has actually declined.

Why this matters

The alarmist warnings that an inexorable tide of traffic will condemn us to permanent traffic congestion is standard fare from highway boosters.  The “predict and provide” approach is a way of rationalizing capacity increases as a way to avoid congestion.  But added capacity has invariably simply generated more travel, more sprawling development patterns and more costly, congested roadways.  The process is so well documented by study-after-study that its called the “Fundamental Law of Road Congestion.”

State highway departments invariably overstate future travel growth and congestion to sell highways.  The State Smart Transportation Institute has cataloged this behavior, which has been going on for decades.  No matter what the actual trend is in transportation, highway agencies predict “hockey stick” growth trends.

What recent Oregon data shows is that traffic increases aren’t inexorable or unavoidable.  Since the pandemic, we’ve fundamentally changed our travel patterns.  If ODOT officials were serious about reducing congestion, they’d be working to understand what about the past few years has enabled the reduction in traffic and congestion.  Clearly, it has not been because of expanded capacity.  Instead, the experience of the past few years shows the efficacy of managing demand.  We saw big reductions in traffic congestion when more people started working at home—and those reductions and travel time savings have persisted.  While initially it was due to the pandemic restrictions, workers and firms have embraced greater flexibility, and work from home is the new normal for a significant segment of the workforce.  The underlying point is that measures that reduce or manage travel demand are the most effective means of reducing congestion.

What that should signal to ODOT and Oregon policy makers is the urgency of adopting a comprehensive congestion pricing system for the Portland area.  Congestion pricing would directly manage demand.  And critically, congestion pricing would enable us to greatly reduce congestion and improve travel times without spending billions on expanding highway capacity.  ODOT’s own analysis of the I-5 Rose Quarter project showed that congestion pricing would be more effective in eliminating congestion and reducing traffic and pollution than spending $1.9 billion widening the roadway.  In addition, congestion pricing makes urban freeways work better and carry more traffic:  by keeping traffic flowing smoothly, pricing avoids traffic jams that actually reduce capacity.

Highway departments like ODOT view congestion data as a gimmick to sell roadway expansions, nothing more.  When states actually chalk up big reductions in congestion (invariably, not because they’ve built more highways), there are crickets.  OregonDOT and its peers are uninterested in learning from places that actually reduce congestion.  When data provider Tom-Tom reported that Portland recorded the biggest decrease in congestion of any US metro area in 2019, ODOT said . . . nothing.  At the time, we observed:

There’s a calculated asymmetry here: You can bet that if Portland had the biggest increase in congestion per Tom-Tom, it would be a front page story on the Oregonian, and a regularly repeated talking point by the Oregon Department of Transportation. If you’re a highway engineer, or traffic reporter, drawing attention to the terrible (and worsening) nature of congestion is a big part of the way you justify your existence.  But good news, it seems, is no news.  If there were any science or objectivity here, you’d think that the media would be celebrating this success (and praising the policies that led to it), and that the transportation agency would be looking to do more of whatever it was that made the congestion numbers improve.

The reason for this asymmetry, as we’ve suggested before at City Observatory, is that for all their bloviating to the contrary, highway departments really don’t care about reducing traffic congestion. Traffic congestion statistics and rankings are simply convenient public relations fodder for selling the next big highway construction project. If they were serious about reducing traffic congestion, these highway engineers would have looked seriously at the big declines in traffic congestion in the early part of this decade (thanks to higher gas prices), and the decline in traffic generated by tolling congested roads, like I-65 in Louisville, and moved aggressively to implement congestion pricing, which is the only strategy that’s been shown to be effective.  But building things, not solving traffic problems, is really their priority.

 

Metro’s Regional Transportation Plan (RTP) claims it will meet state and regional climate objectives by slashing vehicle travel more than 30 percent per person between now and 2045.

Meanwhile, its transportation plan actually calls for a decrease in average travel of less than 1 percent per person.  Because population is expected to increase, so too will driving.

Rather than reducing driving, and associated greenhouse gas emissions, Metro’s RTP calls for accommodating more than 5 million additional miles of driving a day—a 20 percent increase from current levels.

The RTP climate strategy asserts the Portland area will drive 20 million miles a day and meet our greenhouse gas reduction goals.  But Metro’s transportation modeling shows the RTP is planning for a system that will lead to 25 million miles per day of driving.

This disconnect between Metro’s climate modeling, and the modeling it’s using to size the transportation system, and make investments violates state climate rules.

The Portland region is a self-styled environmental leader.  Oregon has a legislatively enacted goal to reduce greenhouse gases 75 percent from 1990 levels by 2050.  Metro, the regional government, adopted a “Climate Smart Strategy” in 2014, calling for taking steps to achieve that goal by reducing driving.  A new, federally required (and state regulated) “Regional Transportation Plan” is supposed to spell out how the region will manage its transportation system and spend its limited resources over the next couple of decades to stay on a path to achieve that goal and other regional priorities.

Unfortunately, the Metro region is nowhere close to achieving its climategoal, is actually headed in the wrong direction, and the new Regional Transportation Plan will likely make things worse.  As we previously documented at City Observatory, the RTP’s climate analysis left out the inconvenient fact that Portland area transportation greenhouse gas emissions are actually increasing, rather than decreasing as the plan assumed–indicating that our efforts are actually failing. In addition, the climate policies in the plan give a pass to a ten-billion dollar plus program of freeway expansion that will lead to more driving and more pollution.  That’s bad enough.

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

Under state law and regulations, Metro has an affirmative legal obligation to monitor and report its performance—something it simply hasn’t done.  At the state’s land use regulator, the Land Conservation and Development Commission is required to review and approve their climate work and policy.  LCDC should reject the Metro climate plan and RTP as out of compliance with these state regulations, and send Metro back to the drawing board to produce a transportation plan that is consistent with professed climate goals and state law.

The key problem here is two sets of books:  An ambitious climate plan that would dramatically reduce average driving (and comply with state regulations), and a second set of books that is a “driving as usual” projection, that’s being used to fuel a highway spending spree.  The difference is 5 million miles a day—and vastly more carbon pollution.

Ambitious climate rhetoric:  We’ll reduce per capita driving 31 per cent compared to 2020 levels

Metro’s current RTP purports to put the region on a path to reducing greenhouse gas emissions by making investments in the transportation system that reduce driving.   And when it comes to its climate analysis, the RTP makes a bold claim that the region will cut driving by more than 30 percent from current levels.  The Climate Analysis (Appendix J, page 9) makes this claim:

But that’s the climate portion of the plan.

Reality:  We’re going to drive 20 percent more, and per capita driving will decline less than one percent

A separate portion of the report offers metro’s “system performance measures” for judging the overall operation and success of the region’s transportation system.  Here, the RTP uses its transportation demand model to estimate how much we’ll drive in the future under various scenarios.  These are the numbers that are used to select projects, estimate traffic delays, and guide investments.  And the picture here is very different.  According to this modeling, per capita driving in the Oregon portion of the metropolitan area will decline by just two-tenths of one percent from current levels.  And these performance measures indicate that the RTP investments make almost no difference in reduced driving:  the RTP “constrained” scenario, representing billions of dollars in spending, reduced driving by only one-tenth of a percent more below current levels compared to doing nothing.  Either way, the Metro performance measures suggest almost no change in per capita driving, and as a result, total travel in the region will increase by more than 5 million miles per day—making it that much harder to reach the region’s and the state’s climate objectives.

These data are contained in Appendix I:  Performance Evaluation Documentation

This duplicity is important, because in Appendix J, Metro has concocted an almost entirely fictitious scenario, in which the state government imposes very high per mile fees  fees on driving.  Metro’s climate analysis uses these assumptions to pretend per capita driving will decline sharply.  But the rest of the RTP makes no such assumptions; it plans for a world where we won’t charge drivers much more than they pay today, aside for some tolls, and that we’ll invest in big capacity expansion projects, like the Interstate Bridge and the I-5 Rose Quarter freeway widening.  In reality, as Metro’s performance measures report shows, the region has no intention or expectation of meeting state climate goals, and is going to continue building car infrastructure as if it were 1950, rather than to head off a devastating climate crisis by 2050.

As we pointed out, Metro uses its climate analysis, with its dubious assumptions, to assert that it doesn’t need to worry about the polluting effects of spending billions of dollars expanding highways.  It claims because we’ll only drive 20 million miles a day, we’ll meet state climate targets, and therefore there’s no need to even examine how much widening roads will increase driving.  But the agency’s own transportation modeling—which it uses to justify these expenditures, and select investments—is planning for a world where we drive 25 million miles a day, with arguably 25 percent more pollution, no matter how “green” vehicles are in 2045.

Make no mistake, Metro planners are really counting on their 25 million mile a day forecast.  They only include the 20 million mile projection as a fig leaf, to be able to assert that they’ll meet climate objectives.

If Metro really believed its climate forecasts, and planned accordingly, it would create a plan that provided for no increase in total driving in the region above today’s levels.  But they clearly have no intention of planning for such an outcome.  They—and the Oregon Department of Transportation—are pushing forecasts claiming we’ll drive vastly more miles and that congestion will only get worse, unless we do something—in this case, spend billions on expanded highways.

Having two completely inconsistent travel forecasts–really two sets of books–is effectively perpetrating a climate fraud.

Metro is failing to comply with state law showing it is making progress

Metro has had a climate plan for nearly a decade.  It adopted its Climate Smart Strategy in 2014, and at the time, as an integral part of that plan, pledged to monitor progress—i.e. whether its efforts were leading to the needed reduction in greenhouse gases.  Since then Land Conservation and Development Commission has adopted further rules that direct Metro to plan to achieve statewide climate goals, and again, periodically report on their progress.

OAR 660-044-0060

Monitoring

(1) Metro shall prepare a report monitoring progress in implementing the preferred scenario including status of performance measures and performance targets adopted as part of the preferred scenario as part of regular updates to the Regional Transportation Plan and preparation of Urban Growth Reports.

(2) Metro’s report shall assess whether the region is making satisfactory progress in implementing the preferred scenario; identify reasons for lack of progress, and identify possible corrective actions to make satisfactory progress. Metro may update and revise the preferred scenario as necessary to ensure that performance targets are being met.

(3) The commission shall review the report and shall either find Metro is making satisfactory progress or provide recommendations for corrective actions to be considered or implemented by Metro prior to or as part of the next update of the preferred scenario.

Metro’s Regional Transportation Plan fails to demonstrate whether the region is making progress, and makes no effort to say that it is making “satisfactory progress.”  In fact, emissions inventories show that actual greenhouse gas emissions from transportation have increased by between 1.4 percent and 5 percent per year since 2014.

When presented with these facts, Metro’s only response is kicking the can down the road—saying it will revisit this entire subject in its next Regional Transportation Plan (to be adopted in 2028).  That fails to comply with OAR 660-044-0060, which requires the progress report do gauge progress as of now.

Instead of acknowledging the failure of current actions, and proposing stronger and more effective policies, Metro has simply chosen to embrace a new set of assumptions that we’ll make even faster progress by the adoption or enforcement of as yet un-enacted policies in future years.

Metro acknowledges that it is wrong about current GHG trends, but isn’t making any substantive changes to the current Regional Transportation Plan.  Instead, it says it will use the updated as the basis of “future climate analysis.”  In its response to comments made on the RTP dated October 18, 2023, Metro staff says it will:

2. Update RTP climate assumptions in Chapter 7 and Appendix J to:
a. Describe which state assumptions are required to be used in the RTP climate analysis and why.
b. Document state assumptions in more detail, including a table describing key state assumptions (e.g., vehicle fleet turnover rate, share of SUV/light truck vs. passenger vehicles, share of electric
vehicles), as well as current trends with respect to these assumptions and discussions of state policies, programs or other actions the state is taking to support the state assumptions used in the RTP climate analysis.
c. Describe that the region will not meet its targets if the state assumptions used in the analysis are not met, along with the results of the RTP 23+AP scenario, which quantifies how much the region falls short of its targets if the Statewide Transportation Strategy (STS) assumptions are not included in the analysis.
d. Describe current trends in GHG emissions, both in the region and state, and nationally, based on DARTE and other inventory sources.
e. Use the updated assumptions as the basis of future climate analysis.

Part 1 to Exhibit C to Ordinance No. 23-1496
MTAC Recommendation to MPAC on Key Policy Topics, October 18, 2023
(Emphasis added)

These changes to the RTP do not put the document in compliance with OAR 660-044-0060:  They do not include the required status of performance measures, they do not identify whether the region is making “satisfactory progress”—it isn’t: transportation greenhouse gases are increasing when the plan said they would be decreasing—and it doesn’t explain why we’re not making progress or identify actions that would be corrective.  Instead, Metro has in effect, deferred all of these obligations until the next update of the RTP (scheduled for 2028).  And, notably, Metro is not proposing to do anything to reconcile the conflicting assumptions about future vehicle travel in its environmental analysis (Appendix J), with the 25 percent increase in vehicle travel it says it is planning for in its transportation plan (Appendix I).  As we’ve said:  This is a “Don’t Look Up!” climate plan.

As a result of these failings, the Metro RTP isn’t in compliance with OAR-044-0060, nor is it in compliance with Metro’s own adopted Climate Smart Strategy (which similarly pledged to report progress in reducing emissions, and take additional steps as needed).  As shown above, the RTP has two separate sets of books and actually contemplates a future where total vehicle miles traveled in the Portland area expands by 20 percent—completely inconsistent with achieving climate goals, and exactly the opposite of what Metro asserts in its claims that it is complying with state law.

The proposed re-design of the I-5 Rose Quarter Project now includes two deadly hairpin freeway off-ramps.

Just last week, Brandon Coleman was killed at a similar hairpin highway ramp in downtown Portland 

The Oregon Department of Transportation doesn’t really care about safety.

The plan to widen I-5 through the Rose Quarter, at the staggering cost of $1.9 billion, has a new added safety problem, a complicated new freeway offramp, of the kind that often leads to serious or fatal crashes.

Earlier, we reported how ODOT’s plan for the so-called “Hybrid 3” re-design of the Rose Quarter project called for moving the I-5 southbound off-ramps about half a mile south to N. Williams and Wheeler, and in the process creating a dangerous 210-degree hairpin off-ramp from I-5.  Even ODOT’s own safety analysis noted the off-ramps would cause big trucks to veer across marked traffic lanes, and would increase the number of crashes.

In part because of these safety concerns—and objections from the Portland Trail Blazers (who own the Moda Center arena abutting the proposed off-ramp location)—ODOT has developed yet another re-design of the project.  This one calls for constructing another off-ramp which would make a second hairpin turn, up and over both the Southbound and Northbound lanes of I-5, and joining the existing I-5 Northbound off-ramp at NE Weidler.

As a result, the latest proposed re-design of the I-5 Rose Quarter project proposes not just one, but two hairpin off-ramps.  Rather than improve safety, this new ramp arrangement would likely be even deadlier for those traveling in and through the Rose Quarter.

ODOT’s initial description called this the “anchor” design, because the freeway off-ramp splits in two, with hairpin turns to both the left and right.  Here is an illustration of ODOT’s proposed “Anchor+Wheeler” Design.  The two hairpin off-ramps are shown in red.  One hairpin off-ramp turns right, and pours traffic exiting the Freeway onto N. Wheeler Avenue.  The second hairpin off-ramp turns left, vaults up and over the I-5 freeway mainline, and then circles back North to merge with the existing I-5 northbound off-ramp as it meets N. E. Weidler Street.  (The circular inset picture with the anchor logo shows the exit ramps emerging from under ODOT’s freeway overpass/cover).

In an earlier commentary, we pointed out the inherent risks of forcing freeway traffic to make a 180-degree (or greater turn) as they exit from a highway (with a design speed of 70 miles per hour) on to local streets with high levels of bicycle and pedestrian users.

We know the combination sharply curving freeway on- and off-ramps feeding into busy arterial streets are deadly to vulnerable road users.  Just this month, Brandon Coleman was killed in a hit-and-run crash where the Morrison Bridge ramps intersect with S.W. Morrison Street and Naito Parkway.  Here’s the police report:

A pedestrian has died in a Downtown Portland hit and run crash.

On Saturday, October 21, 2023 at 4:30a.m., Central Precinct officers responded to a crash at Southwest Naito Parkway and Southwest Morrison Street. When officers and EMS arrived, they found a person, believed to be an adult male, laying on Southwest Naito Parkway at the ramp connected to the Morrison Bridge. He was confirmed deceased at the scene. The involved driver left the scene of the crash and was not immediately located.

Just like the proposed Rose Quarter configuration, this intersection combines a curling, high speed and low visibility ramp with local arterial streets and a dangerous pedestrian crossing.  Traffic turning left or right from Naito Parkway does a tight 180-degree turn on to the Morrison Bridge.

As we’ve pointed out, ODOT has cynically and falsely portrayed the I-5 Rose Quarter freeway widening as a “safety” project, claiming (again falsely) that its the “#1 crash location in Oregon.  It’s latest proposed re-designs actually make the area much more dangerous, both for those traveling in vehicles, and especially people traveling on foot and by bike.  The pair of 180-degree hairpin off-ramps proposed for I-5 southbound funnel high speed traffic exiting the freeway right into arterial streets that carry high volumes of people walking and cycling.  They’re recreating exactly the same fatal design error at the Morrison Bridge ramps that led to the death of Brandon Coleman.

Earlier, we branded Portland Metro’s proposed Regional Transportation Plan (RTP) a climate fraud because in falsely claimed the region was reducing greenhouse gases, and falsely claimed its transportation investments were on track to meet adopted state climate goals. Metro’ staff has responded to these critiques, but  proposes only to fix these mistakes at some vague future time, and more importantly, make absolutely no substantive policy or investment changes to the RTP.
In essence, the staff response puts the lie to the claim that climate/GHG reductions are the “controlling measure” in RTP system planning.  Whether Metro is on track to achieve its committed GHG reductions or not has no bearing on any of the substantive policy and spending decisions in the RTP.
Moreover, this is a straightforward violation of the policies enacted in Metro’s 2014 Climate Smart Strategy (and reiterated in the 2018 RTP, and current RTP draft), to continuously monitor progress in GHG reduction and undertake additional measures if we were not making adequate progress.<
Metro staff treats GHG estimates as a perfunctory and irrelevant codicil to the RTP, and continues to rely on fanciful and speculative assumptions about the future vehicle fleet and an extraordinarily aggressive state pricing policy, to allow it to simply ignore taking any further steps to reduce GHG, or stop widening highways.

City Observatory recently published two detailed commentaries examining the climate analysis and policies contained in Portland Metro’s proposed Regional Transportation Plan (RTP).<
The RTP claims that the region is “on track” to reduce greenhouse gas emissions as required by state law, and that it can afford to spend more than ten billion dollars on highway widening projects and meet its stated climate objectives.
In reality, transportation greenhouse gases in Portland are increasing, not decreasing, illustrating the failure of existing climate policies; the models Metro uses to estimate future GHG reductions are flawed (based on demonstrably incorrect vehicle age and fleet composition assumptions), and the policies in the RTP do nothing to prioritize policies and investments that would actually reduce greenhouse gas emissions.

As part of its review process, Metro staff has prepared its rejoinder to these comments.  In this commentary, we show that Metro’s analysis ignores many of City Observatory’s  comments, mis-states others, and suggested changes do nothing to correct the deficiencies we identified.

For clarity:  both state law and adopted regional plans call for a significant reduction in greenhouse gas emissions.  Oregon law (ORS 468A.205) , and Metro’s adopted 2014 Climate Smart Strategy call for an 75 percent reduction in greenhouse gas emissions from 1990 levels by 2050.  The RTP fails to comply with these policies.

Metro:  “Yes, our climate analysis is wrong, but we’re not going to change our policy or spending”

The analysis contained in the RTP mis-states actual trends in greenhouse gas emissions from transportation (they are increasing, not decreasing), and falsely claims that the region is on track to meet that legislatively adopted goalMetro acknowledges City Observatory’s comment that it has failed to include accurate GHG inventory information in the RTP, and that transportation GHGs in Portland are increasing, rather than decreasing (as shown by DARTE, DEQ and Multnomah County inventories). It proposes, at some unspecified future time, to include more accurate information on transportation GHGs.<
Specifically Metro says it will “amend” its analysis at an unspecified future date and “discuss the potential impact of these trends on RTP achieving climate targets.” (Metro Staff Response to Comment #210).

Metro’s proposed changes to the RTP labeled “Climate Tools and Analysis”  makes it clear that this will not have any effect on the current RTP, and that corrected inventories and trend analysis will be deferred to an unspecified later date:

“use the updated assumptions as the basis of future climate analysis.”

Elsewhere, the RTP concedes that the region is not on track to meet its Vision Zero safety goals.  The RTP needs to have a definitive statement that the region is not on track to meet its climate goals, either.  And while that’s a necessary first step, the RTP must go further.

Admitting error, but doing nothing to fix it

The issue here is not simply whether the RTP contains correct emissions inventories and trend analyses; The actual issue is that Metro has falsely portrayed the progress (actually backsliding) on transportation emissions. The fact that emissions are increasing demonstrates that adopted measures since the 2014 Climate Smart Strategy are failing, and that much more powerful and effective steps need to be taken to achieve stated Metro and State climate goals. Metro needs to both correct its inventory data, and modify its policies and investments to achieve these greenhouse gas goals. It is not sufficient to simply admit we are going rapidly in the wrong direction; Metro needs to change course. Acknowledging that the inventories and trends are wrong, and doing nothing violates the policy commitment in the CSS to periodically adjust the strategy to reflect actual progress. If the RTP is not on a path to achieving climate targets then the policies and investments contained in the plan need to be changed.

The proposed changes in the “Climate Tools and Analysis” include no substantive changes to further reduce greenhouse gas emissions from transportation to compensate for the errors and false assumptions in the RTPs current climate analysis.

As City Observatory pointed out, the climate analysis of the RTP can be summarized briefly as claiming that because the overall RTP is “on track” to meet the 2050 goals, that there is no need or obligation to either prioritize projects and investments that reduce GHGs, or to analyze the GHG increasing impacts of projects, particularly highway expansions. The climate analysis contained in the RTP represents a fraud on the public. Despite labeling greenhouse gas reductions “a controlling measure” in system planning, the RTP fails to achieve adopted state and regional greenhouse gas reduction goals, fails to prioritize expenditures and policies that would put us on a path to reduce greenhouse gas emissions as it has pledged, and fails to strengthen its policies or change its investments in light of its demonstrated failure to achieve promised progress.  The climate analysis is not a “controlling measure” if major flaws in the climate analysis don’t immediately necessitate a revision to RTP policies and investments.

A double standard for pricing

As City Observatory has pointed out, road pricing (tolls, road user fees and congestion charges) are an essential component to achieving the RTP’s purported GHG reductions.  But Metro has a blatant double standard for pricing: It assumes that the state will achieve dramatic GHG reductions by enacting widespread pricing (a carbon fee, a very high road user fee, nearly universal congestion pricing on throughways), and yet it fails to incorporate the effects of those pricing measures on the need/justification for billions in highway widening projects. Pricing roadways will reduce or eliminate the need for capacity expansion.  For example, Metro ignores City Observatory’s comment noting that ODOT’s own analysis of Regional Mobility Pricing (RMPP) pricing would obviate the need for additional lanes in the $1.9 billion I-5 Rose Quarter project.

Metro also fails to analyze the negative greenhouse gas effects of major RTP projects. The blatant double standard in the RTP is obvious in the treatment of major capacity projects (the IBR, Rose Quarter and I-205 widening projects). As Metro has acknowledged, adding lane capacity will induce additional travel, and additional greenhouse gas emissions. The only aspects of these projects which moderate or reduce greenhouse gas emissions are the potential tolls that may be used to pay for them. Yet Metro’s RTP fails to acknowledge that tolling/pricing alone would be more effective in both moderating the growth of traffic and reducing GHGs, and would obviate the need for additional capacity. In that same vein, Metro ignores City Observatory’s comment that ODOT’s own analysis procedures manual denies the existence of induced travel and bars use of the scientifically based induced travel calculator.

Whether the state will actually impose high and widespread road pricing as as assumed in the STS and Metro’s climate analysis, or even imposes tolls, for example, on I-205, is still uncertain and speculative. But the RTP commits to building this additional capacity, regardless of whether these GHG (and traffic) reducing measures are actually implemented. An honest and accurate GHG analysis would also show what would happen to regional VMT, GHG and congestion if these speculative and uncertain pricing measures aren’t enacted.

In essence, the RTP pretends it will achieve state GHG goals because of the imaginary and speculative pricing policies described in the State Transportation Strategy (STS). In contrast, the RTP provides a regional commitment to spend billions on freeway widening, which—absent pricing—will certainly make our already bad transportation GHG trajectory much worse.

Hiding behind ODOT’s flawed policies and modeling

City Observatory’s analysis documented the significant deficiencies in the ODOT modeling used to predict future transportation greenhouse gas emissions, and also showed the speculative nature of assumed pricing policies. ODOT’s STS has Metro asserts that the RTP complies with state law and the Climate Smart Strategy because they are consistent with the state’s Climate Friendly and Equitable Communities (CFEC) regulations.

1. CFEC compliance does not assure that either the Climate Smart Strategy goals or ORS goals are met.
2. CFEC rules are the minimum required to comply with state land use laws. The state’s GHG gas reduction law and Metro’s own climate smart strategy predate and supercede the CFEC rules.
3. Nothing in CFEC precludes Metro from doing more to reduce transportation GHG emissions; in fact, Metro’s own Climate Smart Strategy independently commits the region to a larger reduction in VMT and greenhouse gases.

It’s clear that Metro staff are trying to shift the blame for their flawed greenhouse gas analysis to their colleagues at the Oregon Department of Transportation, who developed the State Transportation Strategy (STS), and have prepared their own greenhouse gas estimates.

Failure to correct policies and investments is climate fraud

Metro’s adopted Climate Smart Strategy, adopted nearly a decade ago, committed to monitoring progress and taking additional steps if fell behind.  Metro pledged to monitor transportation greenhouse gas trends, and:

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.

While Metro has acknowledged that it has overstated progress, but is proposing no additional regional actions, no changes in policy, no different investment strategy, despite the demonstrable failure of its current efforts.
Metro staff’s response to comments confirms the toothlessness and irrelevance of the climate commitments in the RTP. The staff admits that the GHG analysis in the RTP is simply wrong—that it ignores trends of increasing transportation greenhouse gases, and that modeling is based on demonstrably flawed assumptions about fleet turnover and composition—and that this means that the region will definitely not meet its climate commitments. But then, in the staff’s view, these errors and failures necessitate no substantive change to the RTP; no imposition of new policies, no shift in investments. The climate analysis is not, in reality, “controlling” in any way of the RTP. Whether the RTP is on track to meet greenhouse gas reduction targets or not matters not at all to the policy substance or investment choices in the RTP. This is simply climate fraud.

Oregon’s Department of Transportation (ODOT) says it doesn’t have enough money to maintain roads, fix potholes or even plow snow.

This is a Big Lie: Mega-projects and their cost-overruns, not maintenance, are the cause of ODOT’s budget woes

ODOT has chosen to slash operations, while funneling hundreds of millions to billion-dollar-a-mile mega-projects and consultants

Plowing is a trivial part of the $3 billion ODOT budget; ODOT has voluntarily chosen to sacrifice plowing and other safety operations

ODOT’s gambit is a cynical and deadly version of the “Washington Monument” strategy:  Give us money or we won’t plow your roads.

ODOT has aggravated this problem by repeatedly diverting operations and maintenance funds to road-widening projects

ODOT is choosing to make roads even more dangerous as Oregon road fatalities have increased 71 percent; it’s violating its own “Vision Zero” and “Safety First” policies.

The Snow Job:  “Budget cuts are forcing us to reduce snow plowing“

Winter is nearly upon us, and the Oregon Department of Transportation has launched a new seasonal budget campaign, it’s claiming its too broke to plow state roads this winter, with the not-at-all-subtle message that people need to give ODOT more money.  The agency’s PR machine has generated a raft of media stories uncritically repeating this story line:

ODOT says highways ‘may not be safe’ this winter due to budget cut

▶️ Expect less snowplowing of road to Mt. Bachelor, other roads this winter

• Bend Bulletin, “Central Oregon Roads will look different this winter after ODOT reduces services“
• KTVZ (Bend) ODOT Sparks Central Oregon Concern over plan to reduce serivces this winter
• Central Oregon Daily, Expect less snowplowing of road to Mt. Bachelor, other roads, this winter.
• KPTV (Portland) ODOT says highways many not be safe this winer due to budget cuts.
• KATU (Portland) ODOT budget shortfalls will impact plowing, de-icing and salting.
• Bend Bulletin Highway near La Pine and Sunriver will get plowed less” ,

Fortunately, one media outlet didn’t fall for this contrived message.  KGW-TV’s Pat Dorris has a long-form analysis that asks some basic questions and debunks

The Big Lie:  Megaproject Cost-overruns, not maintenance are the cause of ODOT’s budget woes

ODOT has chosen to slash operations, while funneling hundreds of millions to megaprojects and consultants

The trouble is, as Dooris reported, the ODOT message is false:  Snow removal (and other operations) are a minor, nearly trivial part of the ODOT budget, which instead is dominated by giant construction projects, which have been so badly mismanaged that they have cost-overruns running to billions of dollars.  ODOT’s strategy is to threaten to slash snow plowing and other vital, and visible maintenance to build public pressure for greater funding.  And in addition, ODOT’s budget is going up, not down:  As KGW’s Pat Dorris has pointed out:

“it’s not accurate to say that fuel tax revenues have gone down — they are still going up”

As Dorris pointed out, the agency’s own revenue numbers show it  has more money for the current fiscal year than previous fiscal years.

What this means is that ODOT is choosing to cut spending on operations and maintenance–and the reason it is doing that is because it is devoting huge sums to and handful of expensive highway projects in the Portland area.  ODOT knows these projects aren’t popular, and it can’t defend its persistent cost overruns and expensive consultants, and so, instead, its threatening to cut vital and popular services like snowplowing, in order to gin up popular support for more funding.

It’s a cynical and deceptive ploy, one that endangers road users.  ODOT is planning to reduce snow plowing on some roads, and not repaint fog lines on the sides of many rural highways.  Cutting these  modest expenditures won’t save much money, but what they will do is  directly endanger road users.

ODOTs Budget Problems are from Squandering Billions on Megaprojects

To be absolutely clear:  the problem with the ODOT budget is not a lack of funds to fix potholes and plow snow, but rather the exploding cost of highway widening megaprojects in the Portland Metropolitan Area.  The maintenance “crisis” is purely a product of ODOT choices to slash funding for re-paving and regular operations, and instead dedicate hundreds of millions of dollars to a handful of expensive highway expansion projects–that are all experiencing dramatic cost-overruns.

• Item:  The cumulative cost of three Portland mega-projects is nearly $10 billion.  ODOT is prioritizing projects costing more than $1 billion per mile of roadway–the Rose Quarter is $1.9 billion for 1.5 miles; the I-5 Bridge is $7.5 billion for 5 miles, and the I-205 Abernethy Bridge,  is $622 million for barely a half-mile.
• Item:  Each of the three largest projects has experienced 100 percent or more cost-overruns.  The cost increases announced in the past year amount to a total of more than $3 billion ($600 million increase for the Rose Quarter, $2.5 billion increase for the IBR, and $370 million increase for the I-205 Abernethy Bridge.
• Item:  ODOT won’t even say how much will be saved by plowing less—it is at best a few million dollars, and will come mostly from laying off or not hiring ODOT front-line workers
• Item:  ODOT’s says it needs to cut its overall budget by 5 percent, but ODOT has chosen to slash operations by four times as much:  20 percent, while holding harmless mega-project construction (in fact, funding continuing cost-overruns).
• Item:  The Oregon Legislature gave ODOT $500 million in short-term borrowing authority in 2021.  ODOT has used none of this authority to maintain operations.  Instead, it has used all of this authority for highway widening projects–and the debt service on these short term bonds cuts in to revenue that could be used for operations.
• Item:  The Highway Cost Allocation Study revealed that over the past several years, ODOT has systematically slashed spending for pavement preservation (repaving) and operations, and diverted more money to highway widening projects.
• Item:  ODOT proposes to plow fewer roads, stop painting fog lines on many rural roads, and not fix as many potholes, just as the number of persons dying on Oregon roads has skyrocketed, with road deaths up 71 percent since 2010.
• Item:  ODOT routinely juggles its books to “find” revenue for highway widening projects.  It diverted $32 million in maintenance funds to Interstate Bridge Replacement project consultants and planning.  It routinely finds  “savings” and “unanticipated revenue” and uses them to launch expensive expansion projects, that experienced cost-overruns, instead of using those funds to maintain and fix existing roads.
• Item:  ODOT proposes to spend $40 to 60 million over the next two years, largely on consultants, to advance the planning for the I-5 Rose Quarter project to the “30 percent” level of design—even though it lacks committed funds to pay for the full $1.9 billion project.
• Item:  ODOT has spent more money on consultants for its highway widenings—over $100 million each for the I-5 Rose Quarter project and the Interstate Bridge Replacement project—than it will ever save by slashing snow plowing.  ODOT has spent more than $16 million on public relations and communications consultants for these two projects (see below for details).
• Item:  ODOT’s overall budget is more than $3 billion per year and was cut less than 2 percent from the previous biennium, yet the agency is cutting operations (like snow plowing) by ten times as much (20 percent).

In short, ODOT’s PR push to slash snow plowing is a cynical ploy to get Oregonians to give more money to an agency that has been reckless and irresponsible.  The reason ODOT doesn’t have enough money for roads isn’t electric vehicle adoption or faltering revenues, its a spendthrift agency that’s chosen consultants and big contractors over the safety of road users and tax payers.

Plowing is a trivial part of the ODOT budget; ODOT has voluntarily chosen to sacrifice plowing and other safety operations

A close look at ODOT’s explanation shows a strong bias against basic safety operations.  The agency has a $3 billion annual budget, and is seeing revenue increase—plus implementing a 2 cent a gallon gas tax increase in January.  Yet it’s choosing to slash operations, like snow plowing ten times as much as its other parts of its operating budget–like administrative expenses.

While much of the agency is being asked to make a 5 percent reduction, ODOT has chosen to impose a four-fold higher reduction on basic operations, cutting them by 20 percent.  In the agency’s regional “fact” sheets justifying the cuts, it says:

For our next budget, we implemented a 5% cut across all programs funded with state dollars. Within maintenance, we cut our services and materials an additional 15% to account for inflation and our reduced buying power.

ODOT’s region 4 report notes it cut its maintenance budget by 20 percent

Implementing our 2023-2025 budget For our next budget, we implemented a 5% cut across all programs funded with state dollars. Within maintenance, we cut our services and materials an additional 15% to account for inflation and our reduced buying power. We are reducing service in three primary areas:

• Low-volume road maintenance.

• Roadside maintenance.

• Winter maintenance

Despite its emphasis on cutting snow plowing, none of ODOT’s explanations show how much money the state will save by cutting these services.  It’s not likely to be much.  Overall, ODOT spends about $288 million on all “emergency services:–a broad category that includes everything from dealing with crashes, to plowing roads, to cleaning graffiti, and helping disabled motorists .  A 20% cut in that mount is $56 million or about $29 million per year.  $30 million per year is about one-tenth of one percent of ODOT’s annual spending.

Meanwhile, the agency is not imposing these same cuts on its plans for bloated freeway widening projects.  Projects like the $7.5 billion dollar IBR, the $1.9 billion dollar Rose Quarter project, and the $622 million Abernethy Bridge projects–all of which have experienced 100 percent or more cost-overruns, are held harmless from ODOT’s proposed budget cuts.  In fact, ODOT is doing just the opposite:  promising to spend money it doesn’t have on these projects, and likely further cost overruns.

While ODOT has been mum about how much not plowing roads will save, it’s clear that its no a major amount of money in a $3 billion agency.  How much does snow removal cost?  The Pennsylvania highway department spends about $200 million per year on snow removal.  The agency reports plowing, sanding and salting about 94,000 lane miles of highway, for a rough annual cost of $2,000 per lane mile, per year.   The Klamath County road department reports spending about $1 million per year to plow about 100 miles of roadway in the county (about $5,000 lane mile per year).  If ODOT were serious about its budget, it would tell us how much cutting back snow plowing will save–instead, they simply menace us with more dangerous roads, and ask for more money, which will mostly be used for highway widening.

Shorter ODOT:  “Your money or your life.”

ODOT’s PR strategy boils down to:  “Your money or your life.”  We’ve squandered the gas tax increases you approved just six years ago on expensive boondoggle highway widening projects, and unless you give us more money, we’ll stop fixing potholes and plowing snow, and your roads will be more dangerous.  And to be clear, plowing less comes at a cost in human life and limb.  ODOT may not be adequately plowing roads to protect traveler safety.  In 2021, a car plunged off the I-205 bridge, killing the vehicle’s driver; his family is suing ODOT for improperly plowing the bridge, creating a snow ramp that caused the vehicle to jump the guard rail.

ODOT’s plans to reduce plowing come after a decade in which statewide road deaths have spiked by 71 percent.  In spite of the rising death toll, ODOT is choosing to slash its budget for basic safety operations, like plowing snow-covered roadways, and repainting fog lines on many roads.  And ODOT admits its choice to slash plowing and other safety expenditures will likely injure and kill more Oregonians.

Glenn, the ODOT spokesperson, said the state transportation agency is troubled by the trend of increasing traffic deaths, both Oregon and nationwide.

But he said those findings won’t preclude major budget cuts that would eat into the agency’s operations and maintenance budget. The agency is facing a budget shortfall largely due to declining gas tax revenue and inflation.

“We cannot commit that these service level reductions won’t impact safety,” Glenn wrote in an email. “However, we are working to prioritize safety for as many travelers as we can and data like this is helpful in that effort. We are working with our policymaking partners to identify solutions to this structural revenue issue so that we can better invest in building and maintaining a safe system for all users.”

ODOT diverts maintenance funds to highway expansion projects

ODOT routinely diverts funds allocated to and available for maintenance to fund capital construction projects.  ODOT 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.

In 2021, ODOT diverted $36 million in funds dedicated to maintenance to pay for consultants for the Interstate Bridge Replacement project.    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.

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.

This is still going on today:  At its November 9, 2023 meeting, the Oregon Transportation Commission is being asked to approve using $7.6 million in “savings” from a construction project to pay for further overruns on the I-205 bridge.  If it wanted to the Commission could use these savings to pay for snow plowing—but it’s choosing not to.

ODOT excels at playing three-card monte with its budget, “finding” money for projects it wants to build, and while slashing spending on basic operations.  In 2018, after the Legislature provided no funding for the I-205 Abernethy Bridge project, ODOT suddenly “found” tens of millions dollars in “savings”, “unanticipated revenues” and “unexpended funds” with which to launch the unfunded bridge project.  Here’s a slide from ODOT’s December, 2018 briefing on the project:

Most of these funds (regional flexible funds, “reallocated savings,” “unanticipated federal revenue” and especially the “operation program funds,”) could all otherwise be used to pay for ODOT operations and maintenance—but instead they’re being used here to fund a capital construction project.

ODOT routinely pleads “pothole poverty” when asking for tax increases–then diverts the money to megaprojects

This is nothing new.  Back when the Legislature was considering more funding for transportation in 2017, ODOT swore up and down it would use additional money to keep up roads, not build new ones. In 2017, ODOTs sales pitch for gas tax increases consisted of telling the public how much it cared about maintenance: Here’s the agency’s current deputy director, Travis Brouwer, speaking to OPB, in April, 2017 as the Legislature was considering a giant road finance bill.:

Of course, patching potholes are far from the only thing ODOT has to spend money on. So how does the agency decide what to prioritize? According to ODOT assistant director Travis Brouwer, basic maintenance and preservation are a top priority.“ Oregonians have invested billions of dollars in the transportation system over generations and we need to keep that system in good working order,” he said. “Generally, we prioritize the basic fixing the system above the expansion of that system.”

Back in 2017, the Oregon Department of Transportation put out a two-page “Fact Sheet” on the new transportation legislation.  It’s first paragraph stressed that most of ODOT’s money would be for maintaining the existing system:

“Generally,” meaning, unless we decide to build shiny new projects—which they do.  Make no mistake:  When it comes to one of the agency’s pet mega-projects, there’s always money lying around, and if there isn’t, they’ll pretend like there is and charge full speed ahead, maxing out the credit cards to generate the cash.

A deadly take on the “Washington Monument” strategy

Budget wonks talk about a bureaucratic ploy known as the “Washington Monument Strategy.”  Asked to cut their budget by a few percent, an agency chooses its most visible and valued service.  The National Parks Service says if it its budget is cut, it will have to close the Washington monument (the nation’s most visited and visible national monument). The object is to rally public support for the agency’s budget, not to promote efficiency or focus on priorities.  ODOT’s “we won’t plow” because of budget cuts is the same idea, with a lethal twist.  Closing the Washington Monument doesn’t endanger tourists, it merely inconveniences them.  Reducing plowing and not painting fog lines will likely lead to more crashes, injuries and deaths.

Mocking ODOT’s supposed “Safety First” and “Vision Zero” Policies

ODOT plans to slash these basic safety expenditures even as the state is experiencing increasing levels of traffic crashes, deaths and injuries.  Just this month, the Oregon Health Division released a new dashboard showing the increasing death toll on the state’s roads and highways.  Fatal injuries on Oregon roadways are up 71 percent since 2010, with more than 600 Oregonians killed.

The dashboard:  Highway deaths up 71 percent since 2010

ODOT’s own stated goal is Zero fatalities and serious injuries–something it is utterly failing to do.  The state’s Transportation Safety Action Plan says says the long term goal is for zero fatalities and serious injuries.  The state’s target for 2022 was 444 deaths (TSAP, page 9); the actual number was over 600.

Oregon is committed to zero transportation-related fatalities and serious injuries. To make progress and improve traffic safety, stakeholders and partners are tasked with coordinating priorities, leveraging joint resources where possible, and using quantitative data-driven tools (e.g., benefit-cost analysis). Funds are limited; therefore projects, programs, and policies will need to be prioritized to focus on those treatments which will have the greatest benefit toward achieving the vision of zero fatalities and serious injuries. (TSAP, page 72, emphasis added)

ODOT’s own plans call for making safety a priority, even when there are tradeoffs with other objectives.  It’s adopted Transportation Safety Action Plan calls for a quote “Safety First” prioritization.

For those who address transportation and/ or safety in their jobs, including the . . .  ODOT,. . . cultural shifts will be seen when safety is prioritized as a core value. A strong safety culture means that agency leadership and employees, at all levels, are encouraged, and rewarded for prioritizing safety, and identifying safety issues and solutions while carrying out their agency’s missions and their individual job responsibilities.
TSAP, page 60.

ODOT’s decision to slash maintenance expenditures by 20 percent, while cutting its overall budget by 5 percent (and holding harmless a handful of megaprojects and consultant spending) flies in the face of its professed “Vision Zero” policies, and clear direction to prioritize safety first.

Megaprojects and ODOT Cost Overruns

ODOT is pursuing three massive highway expansion megaprojects in the Portland Metropolitan area wiht a total price tag of about $10 billion.  Each of these projects costs more than $1 billion per mile of highway:  The five-mile IBR is $7.5 billion (about 1.5 billion per mile), the one and a half mile  Rose Quarter project is $1.9 billion (about $1.3 billion per mile) and the half-mile long I-205 Abernethy Bridge is $622 million (again, more than $1 billion per mile).  Each of these projects has experiences enormous cost increases in the past three years, totalling more than $2.5 billion in increased costs.  ODOT has shown no ability to accurately predict or control project costs, so further cost increases on all these projects are possible.  These costs dwarf the cost of snow plowing and the revenue impacts of electric vehicles, yet ODOT says nothing about these expensive projects or their cost overruns in their explanation of their budget problems.

A $7.5 billion highway boondoggle doesn’t meet the basic test of cost-effectiveness

The Interstate Bridge Project is a value-destroying proposition:  it costs more to build than it provides in economic benefits

Federal law requires that highway projects be demonstrated to be “cost-effective” in order to qualify for funding.  The US Department of Transportation requires applicants to submit a “benefit-cost” analysis, that shows that the economic benefits of a project exceed its costs. We take a close, critical look at the benefit-cost analysis prepared for the proposed $7.5 billion Interstate Bridge Replacement project between Portland and Vancouver.

City Observatory’s analysis of the Interstate Bridge Replacement Benefit-Cost Analysis (IBR BCA) shows that it is riddled with errors and unsubstantiated claims and systematically overstates potential benefits and understates actual costs. . 

• It dramatically understates the actual cost of the project, both by mis-stating initial capital costs, and by entirely omitting operation and maintenance and periodic capital costs.
• The construction period is under-estimated, which likely understates capital costs, and overstates benefits 
• In addition, the study also omits the toll charges paid by road users from its definition of project costs, in clear violation of federal benefit-cost guidelines. 
• In addition, the IBR BCA study dramatically inflates estimated benefits. 
• It uses an incorrect occupancy estimate to inflate the number of travelers benefiting from the project. 
• The IBR BCA analysis also presents inflated estimates of safety benefits, based an incomplete and un-documented crash analysis. 
• In addition, ODOT’s study fails to separately present the benefits and costs of the project’s tolling and capacity expansion components, and omits an analysis of the distribution of benefits and costs among different demographic groups.

A correct evaluation of this project shows that its costs exceed its benefits by a wide margin.  What this means is that the proposed freeway widening is not cost-effective; not only is it not something that qualifies for federal funding, it also is a demonstrably wasteful, value-destroying expenditure of public funds.  The amount of money that the federal government, the States of Oregon and Washington, and highway users would pay in tolls, exceeds by a factor of more than two the actual economic benefits that would accrue to a subset of highway users.  This is a project that would make us worse off economically—exactly the kind of project that the cost-effectiveness standard is established to prevent.

Benefits are overstated

ODOT and WSDOT claim that the present value of benefits from the IBR project amount to more than $4 billion; nearly all of these benefits are attributed to travel time savings, congestion cost reductions and seismic resilience, and reduced crash losses.  ODOT’s estimates of both travel related savings and crash reductions lack documentation.

Travel Benefits:  The IBR BCA claims that the project will produce $2.4 billion in travel time benefits.  ODOT’s estimates are plagued with errors and a lack of documentation

• Travel benefits are minuscule to individual travelers—averaging about 20 seconds in a typical five-mile trip, according to the BCA.  These savings are imperceptible to individual travelers and are likely to be of no significant economic value.
• The estimates use the wrong value for peak hour vehicle occupancy, exaggerating peak travelers by 13 percent.  The BCA assumes 1.67 passengers per vehicle while USDOT guidelines prescribe a figure of 1.48 passengers per vehicle.
• The project fails to document the diversion of traffic to the parallel I-205 bridge as a result of charging tolls on I-5; this will cause longer trips for 33,000 diverted vehicles per day, and will increase congestion and travel times for the 220,000 persons crossing the I-205 bridge.  These costs will largely offset the travel time savings purported to accrue to travelers in the project area.

The Benefit Cost Analysis concedes that tolling the I-5 bridges will divert traffic to the I-205 bridge, but the project’s benefit cost analysis only models the effect of the project in the study area.  The added cost, pollution and other effects on the I-205 area are not included in the benefit cost analysis.

The Benefit Cost Analysis admits:

The Build scenario assumes tolling for the highway river crossing. The added cost from inclusion of tolls causes a reduction in I-5 auto trips as people shift to transit, use the alternative I-205 crossing, or change their destination to avoid the crossing

As described, this benefit-cost analysis is highly selective:  it counts beneficial time savings in the project’s “study area” but ignores the costs in added travel distances, travel times and congestion that will occur outside the study area when traffic diverts to avoid tolls.

Resiliency Benefits:  The IBR BCA claims savings for lives lost in a potential earthquake, savings on the cost of a replacement bridge, and added savings in traveler delay in the event that the bridges collapse in an earthquake.  All these estimates are exaggerated, including probability of a major seismic event, likelihood of collapse, fatality rate in the event of a seismic event, number of persons on the bridge at the time of an event, the cost of replacing the bridge, and the scale of added travel that would result from traffic disruption if the bridge collapses.  

Safety Benefits:  The IBR BCA claims that the project will reduce crashes on I-5 and will produce benefits with a present value of approximately $53 million.  The IBR-BCA asserts that it has used the ISATe model to predict a 17 percent decline in crashes in the project area. Also, it has not documented what features of the project produce the supposed ISATe benefits, and it has failed to calibrate the ISATe model for I-5, and the ISATe methodology can’t be used to accurately compute crash reduction on highways with ramp-metering, which I-5 has. 

Costs are understated

The IBR BCA  claim that the present value of the initial capital costs of this project are $2.7 billion.  That is a significant understatement.  The project’s construction cost, according to other IBR BCA documents is as much as $7.5 billion.  IBR BCA’s failure to comprehensively account for project costs violates federal benefit cost guidance which requires that costs include “the full cost of the project. . . regardless of who bears the burden . . including state local and private partners . . ”  This should include tolls paid by users.

Costs Exceed Benefits by a Wide Margin

After we correct IBR BCA’s study for under-counted costs, and unsubstantiated benefit claims, the project’s benefit-cost ratio falls to dramatically less than one, which is the minimum standard for meeting the statutory requirement that the project be cost-effective.  Our corrected estimates show that the actual cost of the project ranges as high as $5 billion. The actual benefits of the project, are roughly $2 billion.  This means that the project has a benefit-cost ratio of between 0.4 and 0.3, well below the minimum threshold of 1.0.  The correct analysis shows that the I-5 Bridge Replacement project is a value-destroying endeavor:  it costs users and taxpayers far more than it provides to the public in benefits.  It is not cost-effective, and should not be approved by FHWA.

Failing to disaggregate benefits and ignoring distributional impacts

Federal regulations require that a benefit-analysis separately report the benefits and costs of independent elements of a project.  This is to prevent a prospective applicant from combining an ineligible project (with costs that exceed benefits) with an eligible project (with a positive benefit-cost ratio) in order to get a larger amount of federal funds.  The IBR project consists of at least two elements with independent utility:  a plan to toll I-5, and the proposed widening of the highway, intersections and approaches.  Nearly all of the travel time benefits associated with the project result from tolling, according to IBR BCA’s own analysis.  Appraised separately, the tolling would have a far more favorable benefit-cost ratio than the highway expansion. To comply with federal requirements, IBR BCA should produce separate benefit cost estimates for each component of the project.

Federal regulations strongly encourage applicants to examine the distribution of benefits and costs among different segments of the population.  IBR BCA included no distributional analysis in its benefit-cost study.  Nearly all of the travel time, and congestion reduction benefits accrue to peak hour travelers.  Yet a majority of the the cost of tolls are likely to be paid by travelers who use the I-5 during off-peak hours; these off-peak travelers get no travel time benefits.  In effect, they are made worse off:  they have to pay a toll even though they get no better service than under the no-build scenario.

Conflict of interest and risk of fraud

The benefit-cost analysis is more than a mere formality:  it is a legal requirement for the $7.5 billion project to qualify for federal aid.  False representations made in the IBR BCA could represent fraud. It is concerning that the benefit-cost analysis is prepared by a private sector contractor with a direct financial interest in the construction of the IBR. The Benefit-Cost Narrative report indicates that the report was “Prepared by WSP.” Financial records obtained from the IBR project pursuant to a public records request show that WSP has current contracts to perform paid work on the Interstate Bridge Replacement Project valued at $76,282,807.03. Indeed, WSP is the single largest contractor for the project. In the event that federal funding is not forthcoming, it is unlikely that the project will proceed, and WSP will lose this lucrative source of income. WSP is not, and cannot be, an independent and objective evaluator of the benefits and costs of this project. It has a blatant conflict of interest, which is not disclosed.

City Observatory Analysis of Interstate Bridge Project Benefit-Cost Analysis

UK Prime Minister Rishi Sunak proclaims the primacy of drivers

“We are a nation of drivers”

Those who don’t own cars, or can’t, or choose not to drive, are second class citizens

The transportation culture war is flaring up in Britain.  Conservative Prime Minister Rishi Sunak has cancelled the nation’s big high speed rail initiative (HS2), even plowing salt into the ground by pledging to aggressively sell off property acquired for rights-of-way.  But that’s just part of his posturing, like that of Phillips Oil’s “76” brand, to show he’s “on the driver’s side.”

Hot on the heels of the rail cancellation, Sunak prominently issued a Driver’s manifesto, proclaiming that the United Kingdom is “a nation of drivers.”

On Sunday, I slammed the brakes on anti-motorist measures. For many, our car is a lifeline. We use them to get to work or see our family. But too often drivers feel under attack. Our new plan will put drivers back in the driving seat and improve their experience on the road.

A caste system for transportation, and those not in cars are the untouchables

In a “nation of drivers” people who walk, cycle and take transit are non-citizens.

Sunak’s comments lay bare the caste-system of transportation in Britain.  Those wealthy enough and able enough to own and drive cars are in the favored caste.  Those who can’t or choose not to drive, are in the lower-caste untouchable and unimportant.

The “war on cars” strategy is a blatantly political attempt by Sunak, who’s Conservative Party trails badly in polls and which will confront a general election in the next year or so.  It’s evident that campaign advisers have made a cynical calculation that many voters will identify themselves as oppressed victims.  According to UK Census data, though, 17 million Britons live in households that don’t own a car, and such households represent about 22 percent of all UK households.  And even households that own a car frequently include many residents who don’t or can’t drive, and who may choose or want to walk or cycle near their homes.

Phony claims of a “war” on drivers

In addition to cancelling a major rail project, Sunak also has attacked 20 mile per hour speed limits in dense urban neighborhoods calling them “against British values.”  He also spoke out against and “low traffic zones”—local policies that have been shown to reduce traffic and improve safety.  Sunak proposes stripping local councils of the ability to implement such measures on local streets.

The claim that drivers feel “under attack” met with appropriately graphic replies on social media.

More substantively, The Economist wrote that Sunak’s claims of a “war on drivers” were simply hogwash.

Prominent claims of a “war on drivers” will likely inflame passions, but as the media coverage of Sunak’s obviously political gambit shows, it may help generate some objective scrutiny of these claims.  If we look closely at the data, the aggrieved victims of our manifestly unfair transportation system are not drivers, but those who cannot or choose not to drive.  The success of local initiatives to reduce driving, lower traffic speeds, make walking and cycling safer, and make transit more available and more convenient, all signal that we can make or transportation system better and fairer by moving away from a world where a car is effectively a prerequisite to full citizenship.

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

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

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

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

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

New York Lost 100,000 Homes to Consolidation

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

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

Combinations and Gentrification

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

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

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

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

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

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

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

An invisible process produces cognitive bias

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

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

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

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

Adam Brodheim, 2023. “Bigger Houses, Fewer Homes: Dwelling Unit Consolidation in New York City.” M.S. Historic Preservation Thesis, Columbia University.
https://www.thecity.nyc/housing/2023/8/24/23843686/100k-apartments-lost-to-house-conversions?s=09

Secret ODOT plans obtained by City Observatory show ODOT is planning a ten-lane freeway through the Rose Quarter

Though the agency claims its “just adding one auxiliary lane” in each direction, the I-5 Rose Quarter project is engineered with a 160-foot wide footprint, enough for 10 full travel lanes and extra wide shoulders. 

In places the I-5 Rose Quarter project would be as much as 250 feet wide.  ODOT’s plans are to double or triple the width of the roadway from its current 82 feet.

ODOT plans are drawn to conceal the massive width, with cartoons and misleading “Not to scale” drawings.  The project’s 2019 Environmental Assessment implied the roadway would be only 126 feet wide, but these newly obtained plans confirm it will be vastly wider.

Once built, ODOT could re-stripe this massive roadway for 10 lanes in an afternoon.

The agency has not disclosed the true size of the project, and its Environmental Analysis doesn’t consider the traffic, pollution and safety effects of a ten lane structure.

The project’s massive width—not its covers—are the real reason for the project’s huge expense, which has exploded from $450 million in 2017 to an estimated $1.9 billion today.

ODOT has ignored its own international expert consulting engineers who called for a much narrower roadway, and alternating refuges in the tunnel section to minimize expense.

For years, we’ve been pointing out the lengths that the Oregon Department of Transportation (ODOT) has gone to in concealing the width of it’s I-5 Rose Quarter “Improvement” Project.  ODOT claims that it is merely adding one “auxiliary lane” to the freeway.

But documents—newly obtained by City Observatory from a public records request—show that the I-5 Rose Quarter Freeway will be as 160 feet wide, and in places much as 250 feet wide as it slashes through Northeast Portland.  That’s about two to three times wider than the existing 82 foot roadway.

The proposed Rose Quarter I-5 mainline is 160 feet wide, enough for a ten-lane freeway

As it passes under Broadway and Weidler streets, the main stem of the widened I-5 freeway (excluding the separate on- and off ramps) is a full 160-feet wide according to the previously unreleased ODOT drawings.  The ODOT diagram purports to show the number of lanes and the width of shoulders, but if you look closely, there’s something fishy going on here.  First, the fine print at the bottom of the drawing says “No Scale” which is an admission that despite the measurements shown, this is not a true scaled drawing of the project. That becomes clear when you start comparing the measurements indicated for the lane and shoulder markings with the overall width of the project.  Let’s take a closer look at the plans.

Both the Northbound and Southbound clear-span areas is about 81 feet wide.  According to ODOT’s labeling there are just three 12-foot wide travel lanes in each of these 81 foot openings, meaning that 45 feet of the width under the span isn’t actually being used for travel lanes and is available for shoulders.  We’ve added the red annotations to the ODOT diagram below.

Despite ODOT’s misleading and incomplete labeling of this diagram, its apparent that the project will easily allow construction of a 10-lane freeway (with five through travel lanes in each direction) at Broadway-Weidler.  We’ve further annotated the ODOT drawing to show full 12-foot travel lanes and ten-foot inside and outside shoulders.

ODOT’s own consultants, the international design firm ARUP recommended narrower lanes (11 feet) and much narrower shoulders (as little as three feet) to minimize project costs.  Elsewhere in the project, ODOT is using 11-foot through-travel lanes and narrower shoulders.  If it used followed standard industry practice here, ODOT could stripe the freeway for twelve-travel lanes, and urban-standard freeway shoulders.

The freeway will be as much as 250 feet wide

While the mainstream of the freeway at Broadway-Weidler will be 160 feet wide, the project is actually even wider at its North end.  As it crosses under Hancock Street, the I-5 freeway will be 250 feet wide—more than three times wider than the current roadway, and more the twice as wide as depicted in the project’s 2019 Environmental Assessment.  ODOT provided an image of the project that provides some key details, including the fact that the two spans of the overpass will be 130 feet and 120 feet wide.  On this section, the freeway consists of two southbound offramp lanes, six travel lanes (three in each direction) and two northbound on-ramp lanes, plus considerable additional room for shoulders as well as other space which is not labeled (more on that in a moment).

The Rose Quarter project  so  expensive because its too wide

The reason the Rose Quarter project’s budget has exploded from $450 million just six years ago, to as much as $1.9 billion today is because of the bloated size of the proposed roadway. Building a roadway that is two to three times wider than thecurrent I-5 freeway is the primary driver of high costs, according to ODOT’s consultants ARUP. The overly wide freeway requires enormous beams to support the lengthy overpasses: the girders (BT84) for the overpasses have to be about 7 feet tall.  To accommodate the wider footprint, and provide sufficient vertical clearance over the roadway, ODOT will have to excavate an enormous area, and dig deeper to lower the level of the freeway (notice the brown area to be removed on the Broadway-Weidler diagrams). And while ODOT wants to blame the covers for the high cost of the project, its actually the grossly oversized width of the freeway that drives up the cost of both the roadway, and the covers: a narrower freeway would be vastly cheaper to cover. As part of the Interstate Bridge project, WSDOT is proposing to build an acre-sized cover over I-5 to connect downtown Vancouver to historic Fort Vancouver for a cost of less than $40 million.

ODOT has actively concealed the width of the Rose Quarter Project

ODOT has undertaken multiple and sustained efforts to hide the actual width of the highway widening.  They’ve falsely repeated the Orwellian claim that they’re adding a single auxiliary lane in each direction.

They’ve published false and misleading “not to scale” illustrations that understate the true width of the project as part of the federally required Environmental Assessment.

Instead of presenting the actual plans, ODOT has repeatedly published misleading, not-to-scale illustrations purporting to show the width of the project.  The original 2019 Environmental Assessment contained this drawing.  It didn’t show the actual overall width of the project, but labeled lane and shoulder widths that together totalled 127 feet

In the Supplemental Environmental Assessment released late in 2022, ODOT updated and repeated this same tactic, producing two new illustration).  It shows the existing alignment and the proposed allignment, as follows.  The fine print at the bottom says “not to scale), but the diagram make the proposed project look narrower than the existing roadway.

.  

City Observatory and others have long pointed out that ODOT is planning a much wider roadway at the Rose Quarter than it lets on.  In 2020, the Oregon Transportation Commission directed ODOT staff to provide City Observatory with information about the actual width of the freeway. When pressed to provide details, and actual overall width measurements, ODOT provided elliptical and disingenuous responses to specific written questions asking for a statement of the project’s actual width.  Here is an image of ODOT’s 2021 written response to a question asking the width of the project.

There is not a single number mentioned.  Even when explicitly directed by the Oregon Transportation Commission to say how wide the road would be, ODOT officials dissembled and obfuscated, failing to reveal information that was clearly known to them.

In 2021, City Observatory obtained, via Freedom of Information Act requests and other sources, plans produced by ODOT showing that the project was actually designed to be 160 feet wide.  These internal documents date back to 2016, and show a decision on project width was locked in by ODOT staff for years–just not revealed to the public.

Now, the latest plans for the Rose Quarter project show that it will be, at least in places, more than 250 feet wide.  As before, these are documents that have not been released to the public until ODOT was forced to provide them via a public records request.  In July, 2023, ODOT initially insisted on being paid more than $2,000 to release these records, asserting that their release to the group No More Freeways was “not in the public interest.”  After an appeal to the Oregon Attorney General’s office, the records were released without charge.  ODOT continues to treat the actual size of this hugely expensive project as a state secret, something the public is not allowed to know.

ODOT’s persistent efforts to conceal the true width of the proposed I-5 Rose Quarter project are an attempt to cover up the reasons for the extraordinary cost increases and un-disclosed environmental impacts of this project.  A 160- to 250-foot wide roadway will further divide the neighborhood—repeating and aggravating the historic harms ODOT has inflicted on Albina.  The ten through lanes this widened roadway will enable will produce additional traffic and pollution, and it will pour this added traffic onto nearby city streets, creating safety problems and turning nearby areas into hostile, traffic-burdened places, inhospitable to people and new development.  ODOT has failed to look at a right-sized solution—simply capping the existing highway, or only widening it enough to accommodate the single additional auxiliary lane they say they want (something that could be accommodated in a roadway perhaps 24 feet wider than the existing 82-foot wide roadway).

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

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

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

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

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

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

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

RTP Priority:  Billions for highway construction and expansion

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

RTP travel speed standards prioritize projects to increase capacity

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

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

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

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

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

RTP climate compliance depends on imaginary, unadopted policies

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

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

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

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

Failure to include pricing in transportation demand modeling and project evaluation

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

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

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

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

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

The Cop-Out:  We’re following state rules

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

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

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

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

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

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

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

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

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

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

The RTP is climate denial

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Transportation and Climate:  Plans ignore reality

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

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

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

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

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

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

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

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

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

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

 State, regional and local climate plans are failing

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

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

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

Climate plans haven’t been adjusted to reflect reality

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

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

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

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

The RTP substitutes inaccurate models for actual data

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

REALITY:  Average Vehicle Age is Increasing

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

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

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

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

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

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

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

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

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

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

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

A too wide freeway.

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

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

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

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

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

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

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

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

Covers alone could be vastly cheaper

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

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

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

What to do instead:

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

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

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

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

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

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

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

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

A disparity in Black contracting

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Along the way, ODOT:

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

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

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

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

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

A 2017 Earmark for the Rose Quarter:  Diverted by ODOT

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

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

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

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

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

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

ODOT gave preferential treatment to the I-205 bridge project

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

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

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

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

Rose Quarter:  Cost Overruns and No Funding Plan

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

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

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

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

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

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

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

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

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

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

Rose Quarter’s Fatal Flaw:  A Too Wide Design

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Scratch one flat top

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

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

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

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

In Cincinnati, the $3.6 billion Brent Spence Bridge Project

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

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

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

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

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

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

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

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

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

Honey:  I shrank the bridge

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

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

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

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

This was a major concession to local leaders:

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

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

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

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

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

 

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

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

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

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

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

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

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

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

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

That leaves another $1.5 billion in costs to be split between Ohio and Kentucky. The Kentucky General Assembly last year pledged $250 million toward the project, with Ohio Gov. Mike DeWine also promising his state would pay its share.

ODOT isn’t giving buses the shoulder, it’s giving transit the finger.

IBR is planning a transitway for the new $7.5 billion interstate bridge that can’t be used by buses.

It’s sketching in a “bus on shoulder” option as an excuse to justify building an even wider highway crossing.

Meanwhile it plans to place light rail tracks on raised concrete blocks, rather than embedding rails in the road surface, so that the transit right of way can be used by both light rail trains and buses.

Direct Fixation:  No buses allowed

Each of the bridge’s carrying Portland’s light rail and street car lines across the Willamette River has flush-mounted, recessed rails, that allow both trains and rubber-tired vehicles to use the same travel lanes.  Even the original Interstate Bridge, built more than a century ago, had recessed rails for interurban trains.  Flush mounted rails allow buses and light trains to use the same lanes.

Yet, IBR’s plan is to use embedded LRT track at only at intersections and “direct-fixation track throughout the rest of the program improvements.”  As the Portland Mercury reported:

In their plans for the MAX light rail extension, IBR program leaders have indicated the train will travel across the bridge on direct fixation rails. Direct fixation rails are raised on blocks above the surface of a roadway, making it so non-rail vehicles can’t utilize the same road space. In comparison, the Broadway, Steel, and Tilikum Crossing bridges in Portland all have embedded railways, allowing for increased transit capacity on the same roadway.

Only where the light rail line crosses or intersects with a roadway will they use embedded tracks—so as not to inconvenience cars.

“Direct fixation” is techno-speak for rails raised up on blocks above the surface of the roadway.  In contrast to embedded or flush-mounted rails, the “direct fixation” rails create a roadway that can’t be navigated by non-rail vehicles, in this case, specifically, buses.  It’s marginally cheaper to do direct fixation, but it means that the roadway then can’t be used by buses (or emergency vehicles). A short section of Portland’s streetcar crosses over Interstate 84 on a bridge that has rails mounted in raised concrete blocks:

Every other light rail and streetcar bridge in Portland has surface-mounted rails that allow rail vehicles and rubber tire vehicles to use the same right of way.

The proposed IBR will have about one train every ten or fifteen minutes in each direction.  There’s no reason why buses can’t run on the same exclusive transit right of way as the light rail trains.  The bus-on-shoulder option requires buses to run in mixed traffic, and for all entering traffic to cross the bus-shoulder lane to reach the auto travel lanes.

This is a reprise of a tactic that the “Power Broker” used in the 1930s to block transit service to suburban parks and homes.  Just as Robert Moses intentionally designed all of the overpasses on the Long Island’s South Shore Parkway to be too low to be cleared by buses, this one design decision is designed specifically to thwart optimal use of this roadway for transit.

Bucolic sure, but built so no buses will ever travel here. Just like the transitway on the Interstate Bridge Replacement.

As Robert Caro wrote in his biography of Moses, a New York planner observed:

In practice, no practical bus operator would run his buses on any road on which the clearance at the curb wasn’t at least fourteen feet . . .  the old son of a gun had made sure that buses would never be able to use this godamned parkways. (The Power Broker, page 952).

Bus-on-shoulder

IBR advertises “bus-on-shoulder” as a key part of its high capacity transit plans for the $7..5 billion project.

In reality, though, bus-on-shoulder is just an excuse to build an extra wide bridge.  Once the bridge is built, ODOT and WSDOT can easily re-stripe the bridge to include more travel lanes.  Elsewhere, ODOT and other highway agencies have used the excuse that they aren’t expanding the footprint of the roadway (or acquiring added right-of-way to argue that adding a lane via painting new lines qualifies for a categorial exclusion from environmental review—so no one ever looks at the added driving and pollution caused by widening the roadway.

It then becomes the justification for widening the roadway deck of the bridge, ostensibly to provide for “bus on shoulder” but in reality, to rationalize building a roadway that with a few hours work by a paint truck, can be re-striped to the full twelve-lane freeway ODOT and WSDOT have always wanted to build.

Instead of bus-on-shoulder, IBR could much more readily build “bus-on-shared-transitway” with embedded track, that would give buses an exclusive lane with no conflicts with road traffic.  On a double-decker bridge design, the transitway would be 35 feet lower than the highway deck (and its shoulder), meaning that buses would have less of a grade to climb, and would perform better.  And the last new bridge completed in the Portland area, the Tillikum Crossing, has exactly this technology which allows both buses and light rail vehicles to use the same right of way.

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

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

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

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

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

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

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

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

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

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

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

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

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

Intentionally Misleading Images

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

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

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

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

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

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

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

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

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

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

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

Reference

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

https://olis.oregonlegislature.gov/liz/2023R1/Downloads/CommitteeMeetingDocument/271285

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

HB 2098-2 amendments would:

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

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

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

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

“If wishes were horses, beggars would ride”

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

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

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

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

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

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

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

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

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

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

A Blank Check for the Highway Lobby

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

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

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

Eliminating the Sideboards

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

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

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

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

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

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

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

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

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

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

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

It’s true! It’s true! The crown has made it clear.

The climate must be perfect all the year.

A law was made a distant moon ago here:

July and August cannot be too hot.

And there’s a legal limit to the snow here

In Camelot.

The winter is forbidden till December

And exits March the second on the dot.

By order, summer lingers through September

In Camelot.

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

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

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

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

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

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

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

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

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

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

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

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

A camel is a horse designed by an devious highway engineer

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

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

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

The missing tunnel option

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

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

The Vancouver Columbian reported:

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

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

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

(emphasis added)

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

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

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

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

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

A “Design Option” not an “Alternative”

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

Coast Guard Letter, February 8, 2023

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Editor’s Note:  For the past two year’s the Federal Highway Administration has been investigating a civil rights complaint brought against the proposed I-45 freeway expansion project in Houston.  This week, FHWA and TxDOT signed an agreement to resolve this complaint.  

Urban freeways have been engines of segregation and neighborhood destruction for decades, a fact that even highway builders are now acknowledging.  You might think that civil rights laws might provide some protection against a repetition of the devastating consequences of such projects, but this case shows that federal and state highway builders aren’t about to make any serious changes to their plans to either right historical wrongs or avoid making them worse.  Officials will give lip service to the egregiousness of past mistakes, but then blithely repeat them.

Kevin DeGood of the Center for American Progress has taken a close look at the agreement, and published his analysis as a series of tweets.  His analysis deserves a wider audience, and with his permission, we’re repeating it here.  The twitter original is available here.

1/ FHWA and TxDOT have signed a Voluntary Resolution Agreement (VRA), which allows TxDOT to build the massive $10 BILLION I-45 North Houston Highway Improvement Project (NHHIP). It’s not good. Let’s take a look.

2/ Numerous complaints against the NHHIP project argued the design violates Title VI of the Civil Rights Act of 1964. Why? Because the expansion will cause massive displacements — especially of low-income residents in communities of color:

3/ The disparate impacts from the NHHIP are not limited to affordable housing loss. The Air Alliance complaint states the project would degrade air quality in “predominantly lower-income communities of color…” (Note: MSATs are mobile source air toxics)

4/ I-45 will also supercharge sprawl. The transportation improvement program (TIP) for 2021-2024 shows how the exurban growth machine leverages highway expansions like I-45. This $386M for highway widening in Montgomery County is a small sample of the region total.

5/ This is FHWA’s quick summary of the Voluntary Resolution Agreement (VRA). Let’s dig in a little, starting with “Highway ‘Footprint’ Reduction.” Wow, that sounds promising. But what has TxDOT actually promised to do…?

6/ Short answer: Nothing. TxDOT has only committed to…”evaluating reasonable opportunities to reduce the project footprint…” but ONLY if they would “not compromise the integrity and functionality of the purpose and need…” Welp.

7/ Ok, what about “Mitigating displacements”? Since TxDOT isn’t reducing the project footprint, the displacement totals will not change. Instead, TxDOT will provide $30M for affordable housing. But TxDOT already agreed to $27M in the ROD [Record of Decision]! The $3M is an…11% increase.

8/ Ok, what about “Air Quality Mitigation“? TxDOT has agreed to install air quality monitors. Be still my heart. Billions of additional VMT producing emissions and PM 2.5 and residents will get a few monitors and some data buried on TxDOT’s website.

9/ Ok, what about “Structural Highway Caps“? Again, FHWA is bragging about something that TxDOT already agreed to. TxDOT is set to build 4 caps. But, it’s up to a third party to “fund the design, construction, operations and maintenance of amenities…” Piece of cake!

10/ The NHHIP will result in:
– More VMT, GHG emissions, & auto dependence
– Worse air quality
– Huge residential displacements
– Huge business displacements
– More sprawl
– More wetlands loss
The VRA has not meaningfully changed the project design or its negative impacts.

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.

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.

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

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

   

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

What we should do instead.

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

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

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

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

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

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

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

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

Junking the double decker design

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

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

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

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

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

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

A Bridge Too Steep and the Secret CEVP Report

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

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

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

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

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

Resurrecting a discarded 15-year old alternative

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

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

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

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

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

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

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

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

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

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

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

Why now? 

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

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

IBR’s Stacked Highway Bridge Alternative (2021)

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

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.

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:

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.

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

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

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

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

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

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

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

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

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

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

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

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

Washington Commuters have higher incomes than Oregonians

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

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

A tale of two counties, and two toll bridges

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

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

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

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

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

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

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

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

Subsidizing Sprawl

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

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

Fairness and the User Pays Principle

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

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

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

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

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

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

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.

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.

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.

Just 13 months after raising the price of the Interstate Bridge Replacement (IBR) project by more than 50 percent, the state DOTs ay it will cost even more

We estimate project costs are likely to increase 20 percent or more, which would drive the price tag to as much as $9 billion, almost double the 2020 estimate..

While the DOTs blame “inflation” their own estimates show construction cost disinflation, with expected increases of no more than 3.5 percent per year for the rest of the decade.

The likely increase in costs will more than wipe out the $600 million in federal funds awarded to the project in December.  The cost of the IBR is increasing faster than the DOTs can find money to pay for it.

The “Cost Estimate Validation Process” (CEVP) that state DOTs implied would remedy future cost increases utterly failied

The use of lowballed construction cost estimates to sell highway megaprojects is part of a consistent pattern of “strategic misrepresentation.”  It’s  the old bait-and-switch:  get the customer to commit to buying something with a falsely low price, and then raise the price later, when its too late to do anything about it.

There will be likely future cost increases:  There are huge and unresolved risks to the projects actual cost, and the DOTs haven’t even turned a shovel of dirt yet.  The real price increases will likely come after construction starts.

ODOT has a consistent track record of lowballing pre-construction cost estimates, and recording huge cost overruns, with the average price of a major project doubling between pre-construction estimates and final costs.

Just 13 months ago, with great fanfare, the Interstate Bridge Replacement Project released a definitive new cost estimate for replacing  the I-5 bridges.  Costs jumped by 54% from earlier estimates, from $4.8 billion to as much as $7.5 billion.

Now IBR leaders are signaling the project will be even more expensive.  Oregon Public Broadcasting reports:

Planners for the effort to replace the aging span revealed Wednesday that it is going to be more expensive than previously thought. Program leader Greg Johnson didn’t put a number on the growing price tag, but he said the replacement project is falling victim to a “continuing creep of costs.”

How big a cost increase?  Likely a $9 billion project

IBR officials are being purposely vague about the cost increase, but given the wide range of their previous cost estimate–anything from $5 billion to $7.5 billion–the increase would have to be significant to lie outside this window.  At a minimum, we should probably expect an increase of 20 percent, with the costs increasing from a minimum of $6 billion to a maximum of $9 billion (or more).  Any smaller increase in costs would not significantly move the project out of the current range.  It seems entirely possible that the increase could be more than 20 percent.

While we’re generally reluctant to speculate on such matters, our earlier prediction of the increase in IBR costs was almost exactly correct.  As Willamette Week reported, our City Observatory prediction—made in May, 2022, seven months before the IBR estimates were released—that the cost of the IBR would balloon to between $5 to $7 billion was spot on, and slightly conservative.

Falsely Blaming Inflation

As they did a year ago, the DOTs are painting themselves as victims of inflation.

“One of the things all mega projects are experiencing is this inflation we’ve seen in the construction industry,” Johnson said. “We are going to be reissuing an overall program estimate probably later this summer.”

The trouble is, all of their earlier estimates–including those in 2020 and 2022–already allowed for inflation.  And more to the point, highway construction cost inflation, which did spike briefly during the pandemic, has subsided to historically typical levels–according to the official revenue forecast of the Oregon Department of Transportation. Here’s ODOT’s prediction of future capital cost inflation from their October 2023 forecast

From 2023 through 2031, ODOT expects that construction cost inflation will be about 3 percent per year—no higher than its long run historic average..

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.

By not showing their work, and describing exactly how their inflation estimates changed between their 2020 project cost estimate and their December 2022 cost estimate, the IBR is exaggerating the importance of inflation, and downplaying its inability to accurately calculate future costs.  It’s 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.

The failure of “CEVP” to prevent further cost increases

At the time it presented its last set of cost estimates, IBR officials responded to legislative concern about cost increases by claiming that they had a sophisticated risk analysis tool to accurately predict future costs.  That tool, called the “Cost Estimate Validation Process” was presented as a kind of “magic wand” to avoid future increases. 

IBR administrator Frank Green assured the Oregon and Washington Legislators that the CEVP would help them manage costs:

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 

As we pointed out a year ago, the IBR actually did not present the results of the “CEVP” when it released its new cost estimates, and claimed, in response to a public records request” that it had “no records” of having conducted a CEVP.

In reality, the CEVP doesn’t so much prevent cost increases as simply document, after the fact, why they occurred.  The next iteration of the CEVP will show how IBR officials made bad assumptions about design, schedule, environmental factors (like the in-water-work-window) that drove up costs or blew up the schedule.  In theory, the CEVP should anticipate these “risks”—in reality, it does nothing to prevent systematically bad or mistaken assumptions about project cost drivers.

ODOT’s Reign of Error:  Consistent Cost Overruns

For anyone who has followed ODOT cost estimates, this latest round of further cost increases comes as no surprise.  ODOT has consistently and badly under-estimated the ultimate cost of virtually every single one of its major highway construction projects.  As we’ve reported at City Observatory, ODOT’s cost estimates are a series of “exploding whales“—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.with the average large ODOT highway project seeing a 100 percent cost escalation between the time it is approved and its ultimate completion cost.  The likely $9 billion maximum cost of the IBR project, up from an estimated $4.8 billion “maximum” estimated by IBR in 2020 would put the IBR right in the middle of this cost doubling pattern.

As public finance scholar Bent Flyvbjerg has documented, these consistent errors are no accident:  they are a conscious, institutionalized practice of using low-balled initial cost estimates to secure support for a project, coupled with a strategy of revealing true costs only once the project is committed or under construction.

Cost Overruns Matter

The ever-increasing cost of the Interstate Bridge Project is problematic for many reasons.  First, the agency hasn’t fully identified (much less obtained) the funding needed for the current $7.5 billion cost estimate.  Oregon and Washington taxpayers will be on the hook for these amounts, and every cost increase raises they amount they have to contribute.  In effect, even a 10 percent increase in costs (and its likely to be double that, or more), would more that wipe out the value of the much ballyhooed $600 million grant awarded to the project in December, 2023.  In a real sense, project costs are escalating faster than ODOT and WSDOT can find new revenue.

There’s a second problem:  Rising costs could also invalidate the existing (and future) awards of federal funds.  As we’ve noted, federal law requires that highway projects be “cost-effective” in order to qualify for federal funds.  Cost-effectiveness is judged by a benefit-cost analysis.  In simple terms, if benefits don’t exceed costs, a project isn’t eligible for federal highway funds.  The current benefit cost analysis is already full of errors and suspect assumptions that inflate benefits, and was prepared by an IBR contractor with a clear (but undisclosed) conflict-of-interest.  If the new, higher level of costs were factored into the benefit-cost analysis, the project would be even shakier–and likely ineligible for federal funds because it isn’t cost effective.

Third, rising costs may force the project to try to extract more money from tolls.  If the project raises tolls, it will likely increase traffic diversion to I-205, with adverse effects on congestion and pollution.  The financial need for higher toll revenues may also undercut the viability of proposed toll-discounts for low income commuters.

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.

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’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.

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.

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.

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 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).

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.

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.

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.

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.

“You’re kind of a nerd, aren’t you.” Pete Buttigieg explains traffic, and it actually makes sense. This man is going to be president one day. pic.twitter.com/fbW5qqAp10

— Mike Sington (@MikeSington) October 30, 2022

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:

With respect to interchange spacing, the panel offers the following secondary recommendation:

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

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.

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.

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.