ODOT has claimed a “peer review panel” vindicated its air pollution analysis
Now the panel says they didn’t look into the accuracy of ODOT’s travel forecast
Travel forecasts are critical, because they determine air and noise pollution impacts
In short: the peers have done nothing to disprove the critiques of ODOT’s flawed traffic modeling
A key claim opponents made about the I-5 Rose Quarter freeway-widening project is that the traffic projections are wrong, over-stating baseline traffic by pretending the CRC was built in 2015, exaggerating “no-build” traffic levels by allowing link volumes to exceed capacity, and under-estimating “build” volumes by failing to account for induced demand and also modeling a 6-lane roadway rather than the 8- or 10-lane roadway they’re actually constructing.
ODOT’s defense is that their environmental modeling was endorsed by a so-called independent peer review panel. As we pointed out when panel’s report was released, this was largely a whitewash. As we wrote at City Observatory last June, when the Panel’s report was released, the critical problem was that the panel failed to look at the flawed traffic projections on which the air and noise estimates are based. We wrote:
In theory, the PRP undertook an environmental review, looking at air pollution, greenhouse gases and noise pollution. But because all these impacts depend on the volume of traffic and whether the project increases or decreases traffic, they are all subsidiary to the accuracy of the traffic modeling. And the panel apparently did absolutely nothing to validate the accuracy of these traffic projections.
The air and noise impacts of the project come from vehicles using the freeway; both air pollution and noise pollution increase with the increasing number of cars and trucks on the roadway. If ODOT got the traffic numbers wrong, then the pollution estimates are wrong as well.
The Peer Review Panel admits it didn’t evaluate the validity of traffic forecasts
Earlier this month, the leader of the peer review panel publicly acknowledged that the group she led did not take any critical look at the travel forecasts. On April 5, ODOT consultant and panel facilitator Grace Crunican presented the so-called “peer review” panel results to the Historic Albina Advisory Board. Board member John Washington asked about the traffic projections. Crunican said that the peer review committee didn’t judge whether their were accurate or appropriate and only looked at whether the model’s outputs were correctly used to compute air/noise impacts.
Here’s the transcript:
John Washington (Historic Albina Advisory Board)
We had a public announcement about some people suing us or something, right. And how closely related is what they’re talking about to what you’re talking about?
Grace Crunican (ODOT Peer Review Consultant)
It is related. What they [No More Freeways] are saying is that the traffic data that was provided, that ODOT provided as a basis of the analysis that they did, is not accurate. We were not charged with looking at that traffic analysis original data. We were looking at the implications of the traffic data that was there. We did ask some questions about it and we got mostly the information, some of the information, Megan gave us today. She can say it again, but in my lay terms, she used the models from the metro area, she used Metro’s models and she used City of Portland’s model. And they did their analysis and then what we looked at is, given how much traffic was going through, and we look at the air quality analysis that was done. And that’s where our work was, and so the underlying data is what somebody is trying to challenge, the No [More] freeway people, I think are trying to challenge, and we looked at how that data was applied, and found that it was applied appropriately.
Historic Albina Advisory Board, April 5, 2021, Meeting Video at 1:03:45. (Emphasis added)
In effect, the peer review panel simply assumed that ODOT’s traffic projections were right. It took no independent effort to examine those projections, nor did it consider any of the technical objections that No More Freeways and other commenters offered to the model. For reference, City Observatory has documented the critique extensively: It includes inflated baseline traffic due the counterfactual assumption that the Columbia River Crossing was built in 2015; the over-assignment of traffic to congested road links in the No-Build scenario, and the failure to model the effects of induced demand in the build scenario, as well as the fact that ODOT modeled a six-lane freeway, rather than the 10-lane roadway that the project actually proposes to construct.
This is important because ODOT relied on the peer review panel to discredit the critique of its flawed traffic modeling. When it released the report, in June 2020, it claimed that the peer review “supported ODOT’s findings for air, greenhouse gas and noise impacts” for the freeway widening.
In January 2020, the Oregon Transportation Commission directed ODOT to conduct an environmental peer review associated with the project’s Environmental Assessment after hearing stakeholder concern over the potential impacts from the project related to air quality, noise and greenhouse gas emissions. The Peer Review Report supported ODOT’s findings for air, greenhouse gas, and noise impacts for the project.
Most recently, ODOT used the peer review panel as a kind of talisman to ward off criticism after No More Freeways filed suit against the Federal Highway Administration challenging the project. Here is ODOT spokesperson Tia Williams in Willamette Week:
“This project underwent a robust environmental assessment that showed future air quality would improve in part due to the congestion relief provided by this project. Those findings were reviewed and confirmed by a panel of national air quality and transportation experts. We are confident in the findings,” a statement from ODOT provided by spokesperson Tia Williams said.
At long last, the peer review panel has shown a modicum of independence: It has made it clear that claims that its review “supports” ODOT’s work and “confirms” its findings are simply false. The panel members were instructed to look only at a small, and as it turns out, derivative question, and simply ignored whether the freeway widening increases traffic. This is hardly a reasonable basis for a claim that this project has “no significant environmental impact.”