- Our Full Take on the SDEIS
A few weeks ago we shared our hot takes on the IBR SDEIS. Now, believe it or not, we’ve had the opportunity to take in all 12,500+ pages and we have organized thoughts in five theme areas:
- The need for more credible traffic modeling
- Maximizing the potential of active transportation and transit
- A need for stronger pricing policy and tolling equity
- Health and equity impacts
- Right Sizing the project
You can find these organized in three documents that we’ve submitted as an overview comment to the project (we and our allies have also submitted LOTS of detailed comments):
- Our overview comment letter
- A vision document for Transit and Active Transportation
- A detailed critique of the traffic modeling (the Marshall Report)
You can also hop over to our comment form page where you’ll find these organized as talking points you can use in your comments! We’ve got about a week left to get all our comments on the record.
- Independent Traffic Modeling Analysis – Garbage In, Garbage Out
Today the Just Crossing Alliance (JCA) released an independent assessment of IBR traffic modeling conducted by Norman Marshall, president of Smart Mobility. Mr. Marshall specializes in analyzing the relationships between the built environment and travel behavior and doing planning that coordinates multi-modal transportation with land use and community needs.
A key finding of the report is that the Draft Supplement Environmental Impact Statement (DSEIS) forecasts more traffic in the corridor in the no-build scenario than is physically possible (a similar error in the CRC EIS has been confirmed by historical data). JCA members reacted to the information noting that if the no-build forecast is invalid, then all the environmental analysis in the DSEIS is without basis!
Other conclusions of the Marshall report:
- The Interstate bridge is not the I-5 bottleneck in either direction
- Congestion to the south “meters” traffic on the bridge during peak periods, and traffic cannot grow without road expansion to the south
- Metro’s regional Kate model relied on in the DSEIS significantly overestimates peak period traffic today and forecasts impossible traffic growth in the future
- This impossible traffic growth forecast is the basis for the DSEIS traffic metrics, i.e., garbage in – garbage out
- Higher speed AND higher throughput are possible without expansion through better ramp metering, and/or system-wide tolling
- What the mysterious Express Bus delay reveals about IBR
One of the surprising results in the IBR Draft Supplemental EIS (SEIS) is that the express buses running from downtown Vancouver to downtown Portland get SLOWER in the morning in the 2045 horizon year. In the no-build scenario these buses take 48 minutes. In the build scenario (aka Modified Locally Preferred Alternative or MLPA) they take 59 minutes.
This was significant enough to get called out specifically in the press conference for the SEIS release.
Meanwhile, Light Rail, even with 16 stops between Vancouver and Pioneer Square gets there in 47 minutes.
Of course, this is counter-intuitive. We’re adding at least one new lane in each direction on the bridge and express buses will be allowed to use the shoulder when there’s congestion on the bridge.
So what’s behind this? The bridge is actually not the relevant bottleneck in this equation. When traffic flows south more smoothly it bumps into the next bottleneck.
Your mind went straight to Rose Quarter, didn’t it? Well, that’s not the answer! IBR’s modelling in 2045 assumes that the Rose Quarter project has been built by then.
In fact the next key bottleneck is the I-5/I-405 split in North Portland, and that’s where express buses will sit in traffic. That bottleneck is due to folks merging in at the ramps in North Portland and then the merge/weave behavior at the split. And that bottleneck, with more traffic pushed south by removing bottlenecks north of the bridge will actually back up across the bridge!
But wait! Aren’t we using variable rate tolling to try to smooth out that peak hour congestion? We are, but it turns out that’s mostly going to impact discretionary trips. Apparently commuters are a lot less elastic in their response to pricing. The bottom line is there will be more drivers hitting the I-5/I-405 split in the morning MLPA scenario (versus the no-build) and that congestion may well back up into Vancouver as the SEIS reveals:
“but congestion in North Portland would worsen approaching the downstream I-5/I-405 bottleneck in North Portland because traffic would no longer be as constrained by a bridge bottleneck. The combined congestion from the I-5/I-405 bottleneck in North Portland plus the bridge volumes would extend back into the study area as far north as the C-D system in Vancouver between Mill Plain Boulevard and SR 14.” (SEIS Chapter 3.1, p. 27)
Does this mean commuting drivers will also face longer morning commute times? We think so, but the SEIS measures cars and buses differently. Buses are measured downtown-to-downtown. Auto travel times are reporting in the SEIS from I-205 in Vancouver to I-405 in Portland, which obscures this effect to some degree.
Here’s a remix of charts from the SEIS describing the southbound AM traffic (to be clear, this is 100% IBR info, we just put them side-by-side, which the SEIS does not) that spell this out:
The timing and location of the congestion changes a bit, but mostly it’s still there. Somebody’s going to be disappointed about what $5-8B is buying! [To be fair, the return commute in the afternoon does appear to be somewhat improved.]
What lessons do we take from this? Maybe somebody should be thinking about managing the system, rather than chasing each bottleneck? Thoughtful congestion pricing throughout the corridor could yield very different results. Meanwhile we’ll watch for ODOT to propose the next multi-billion dollar bottleneck project, got to keep the Freeway Industrial Complex busy…
- Hot Takes on the IBR Draft Supplemental EIS
We’ve had the document for a week now (all 12,500+ pages). We’re still reading, but here are some initial thoughts to stimulate your review.
We may update this post as we learn more. Comments are open below, so let us know what you think and what you’re reading in the SEIS.
- 20 year old Purpose and Need
- Same six purpose bullets as CRC, from a process started in 2005
- Equity and Climate “lenses” that have been added haven’t had any impact we’ve seen yet other than adding more sections to the EIS
- The “original sin” is bundling congestion with the important objectives of seismic resilience, transit and active transportation
- Traffic Forecasts are unmoored from facilities design
- Repeats error from CRC modeling: traffic and congestion in no build alternative will continue to rise despite the fact that the current facility is constrained. The CRC EIS predicted the “no build” alternative would see 180,000 vehicle crossings daily by 2028. The Draft Supplemental EIS now predicts the “no build” will now see 180,000 vehicles in 2045. Zero learning from history!
- Actual data since CRC forecast proves this point
- If no build VMT forecast is wrong, then all other analyses based on this (air quality, GHG) are wrong as well when compared to the build alternative.
- Actual data since CRC forecast proves this point
- Induced demand does not show up in the index.
- Only actual reference to induced traffic is from a Metro memo on “induced development” (deep in the Transportation Technical Report document) from the CRC project written in 2010
- Takes essentially the same line that ODOT does, induced demand only occurs if land use changes occur (i.e., denies that reduced congestion prompts more people to use a road)
- Makes the assertion that land use patterns already anticipate IBR being completed
- We’d note that in addition to the auxiliary lane(s) the project proposes collector-distributor ramps and lanes on the Vancouver side, and it would seem apparent that these increase capacity
- No meaningful VMT difference between one aux lane and two aux lanes (see induced demand) – fails common sense.
- Impact of tolling is left as an open question between base tolling case and “high toll scenario”. We know the state Transportation Commissions will make the decision on toll rates and suspect they may be a lot more focused on paying off construction bonds than managing demand.
- Suggests that diversion to I-205 due to tolling will be relatively small.
- Totally unintuitive conclusion that variable (by time of day) toll rates will INCREASE peak hour travel, resulting in increased trip times for morning express buses to Portland. We’ve reached out to get a better understanding of this.
- Repeats error from CRC modeling: traffic and congestion in no build alternative will continue to rise despite the fact that the current facility is constrained. The CRC EIS predicted the “no build” alternative would see 180,000 vehicle crossings daily by 2028. The Draft Supplemental EIS now predicts the “no build” will now see 180,000 vehicles in 2045. Zero learning from history!
- Climate
- Touts benefits from green construction methods/materials and reducing GHG from maintenance but acknowledges that main source of GHG (94%) is from traffic on the facility
- Essentially throws in the towel on climate change, saying RCP 2.6 scenario (i.e., high mitigation efforts, keeping warming to 1.5-2.0 ºC) is unlikely (no acknowledgement that this project could be part of why that’s unlikely).
- They are designing the bridge assuming higher CO2 scenarios to withstand frequent temperatures over 100ºF and up to 10 days a year over 105ºF
- Makes claim for a small GHG benefit from 2nd aux lane because congestion is reduced slightly more, the current fig leaf of DOTs: “we’ll help GHG by reducing stop and go traffic”
- Transit
- Acknowledges that LRT capacity is constrained at Rose Quarter, does not propose workarounds to that
- Express bus preferred operation scenario on shoulder of highway
- See above issue with AM express bus delay
- Cumulative Effects
- Temporary cumulative effects (i.e., construction effects) do not mention Rose Quarter construction happening simultaneously. Also no mention of EPA Harbor Cleanup happening at the same time
- 20 year old Purpose and Need
- What’s Up with the Fabricators and the Coast Guard?
Project nerds that we are, one of the documents we like to track (via public records request) is the IBR ‘risk register’, a document updated roughly quarterly that tracks what keeps the project managers up at night.
The most recent edition (July) features this interesting tidbit under “new risks”:
Risk #299: Revised PNCD for Fixed-Span Bridge – The USCG may not issue a revised PNCD, which is needed for a fixed-span bridge. If a revised PNCD is not issued, the program will need to elevate the decision which may delay the program schedule.
The backstory on this is that the project strongly desires to build a bridge with a 116 foot fixed clearance over the river, i.e., NOT a drawbridge or lift bridge like we have now.
The challenge is that there are river users upstream who like to ship things taller than 116 feet. The governing authority for this conflict is the Coast Guard, which issued a document called a Preliminary Navigation Clearance Determination (PNCD) which says the project needs to maintain the current 178 foot (lift bridge) vertical clearance. As a result, one of the project’s three “design options” is a lift span – an option they definitely want to rule out!
So how do they that? They have to negotiate with the upstream users to compensate them for the lost opportunities. Ten years ago, they agreed on payments totaling $86.4 million. Once such an agreement is reached for IBR, the Coast Guard would issue a new PNCD at a lower clearance and IBR can cross that options of their list.
Risk #299 is an indication that this hasn’t happened yet and possibly might not happen (what’s their new price tag?). We’re popping a bucket of popcorn to watch how this drama plays out!
- There are Rocks Down There!
A records request recently turned up a copy of the draft geotechical report, i.e., what they found after some test drilling.
We’re not geotechnical engineers, but it certainly seems like they found more than a few obstacles (the report is replete with “difficult drilling conditions”). Given that the project will require MANY drilled shafts as part of construction, this creates both cost and delay risks.
The project can potentially push some of the cost risk to the drilling contractor (which will result in higher bids), but as Project Administrator Greg Johnson has said many times, delay is very expensive and we don’t see how the project can duck that risk. - The Human Impact of IBR Property Takings
The Planned SR 500 Interchange, with the first half of that new Braided Off Ramp.
Did you know that we are still demolishing houses and businesses to make way for more lanes on freeways? Like, this year. 2024. You might have heard stories of Houston, where as many as 1000 people may be displaced by widening of I-45 [1], or Austin, where 111 households will have to move [2]. These kinds of projects would never have been greenlit in a blue state, right? Wrong. The IBR Project, a $5 Billion freeway expansion inexorably grafted onto a $2 Billion Bridge Replacement [3], is planning on displacing at least 76 Washington & Oregon homes in the name of… more cars traveling from Portland’s northern exurbs into its center city. Priorities, I guess?!?
In the Environmental Impact Statement (“Property Acquisitions and Displacements” report) for this project, IBR asserts that these impacts are actually quite modest:
“The real estate acquisitions required for the Modified LPA are high in the context of other recent actions in this vicinity, but they are relatively low for a project of this size located in an already urbanized area…There would be few residential displacements in neighborhoods that were directly affected by the original construction of I-5…For example, when the segment of I-5 known as the Minnesota Freeway was constructed from the Rose Garden area to the Columbia River Slough in northeast Portland, it removed more than 180 dwellings and displaced more than 400 residents (Kramer 2004).”
Only disrupting “new” neighborhoods, and not the original ones affected by I-5 is an odd metric of success if you ask me. If the bar for progress is displacing 150 residents rather than 400, then I think its time we question the very premise here. How necessary is the of demolishing any homes for a project that we know will waste Billions of dollars, blight the Vancouver and Hayden Island waterfronts, pollute the air we breathe, and not even solve traffic? Surely those billions could be better spent on literally anything else. [4] [5] [6]
ODOT/WSDOT knows how unsavory mass displacement is, and so the Environmental Impact Statement is very careful to obscure the human impact of this project. Documents like the Draft EIS are far from impartial; they are written BY the agencies who proposed the project in the first place (and hold close relationships with Contractor Firms who stand to profit on projects like these getting approved)! When reading a planning document, remember to always read between the lines. Ask yourself: Who stands to benefit from a project like this getting approved? What perspectives may the document lack? Is the document trying to draw my attention to, or away from any topic? Anyway, lets move on to the actual Property Acquisition Map:
It’s easy to lose focus on a map like this. Let’s break it down: Partial Acquisitions of land—often big, largely uninhabited parcels (like Delta Park, Jantzen Beach Shopping Center, and Fort Vancouver) are colored a pale yellow, and the entire lot is generally highlighted, even when the acquisitions are marginal. The same could be said about the Temporary Construction Easements (generally, permits to park equipment, site construction materials, and subject residents to construction noise), which are colored a pale green. These blow out the map with relatively modest impacts–“temporary” and “partial” frame the project as pretty benign. Only once we begin to zoom in do we notice the parcels marked for Full Acquisition, highlighted with a red border. Businesses acquired are outlined a bold red, drawing attention to them, and Temporary Residential Impacts are outlined in a bold green (y’know, for when your HOUSE is only going to be MOVED temporarily). Lastly, Residential Impacts are outlined with a solid yellow, seamlessly blending into the sea of Partial Acquisitions… wait, what were we talking about? Oh yeah, each “Residential Impact” is a house that will no longer exist once this project is done. Not to Bury the Lede, IBR! Lets get counting, from the southern terminus of the project:
- IBR counts 4 displaced homes on mainland Oregon and 5 businesses. The homes are all west of current I-5 on the waterfront, and the businesses can be found on both sides.
- IBR counts 32 outright Displacements of floating homes on Hayden Island. We both count 6 floating homes “temporarily displaced” on Hayden Island. Note the 20-something floating homes outside of the “Temporary Construction Easement” zone but not listed as “Temporary Displacements”. We both count 14 businesses displaced on Hayden Island; everything between Center Ave & I-5 will be gone, as well as JayBees Chicken Palace.
- IBR Counts 10 businesses demolished in Downtown Vancouver. These are all either in the Hurley Building, a 6-story office building constructed in 2019, or an office park across the street from Hurley.
- Normandy Apartments, a 33-unit apartment building, *may* be demolished, along with the Regal City Center movie theater building, provided IBR pursues the “Westward Shift” option. The Westward Shift would build the new bridges parallel to the existing ones, and this option seems likely to me. If you couldn’t tell from the map, I don’t blame you; the potential eviction of dozens is represented by a hatched grey box around a yellow parcel bubble. The Columbia Credit Union building and/or the Webber Office Building may also be demolished for a parking structure, to be determined.
- I count 5 outright home demolitions + a residential duplex demolition, and 17 “partial acquisitions” of residences between SR 500 and 4th Plain Boulevard. All of this for a “Braided Off-Ramp” that starts somewhere north of E 40th St and continues almost a full mile south to E 26th St. I may not be a traffic engineer, but this design choice feels especially strange to me. Most freeway offramps do not last a mile, to my knowledge!
By IBR’s estimates, this totals 76 homes displaced outright, 33 Businesses, and 2 Public Facilities (An ODOT permitting office on Hayden Island and a Clark Public Utilities building on the Vancouver Waterfront). The partial acquisitions are more subjective and the project refuses to go into more detail on most of them, but I would assume that some partial acquisitions between SR 500 and 4th Plain Blvd will eventually result in the condemnation of a house. The impacts are also subject to change: If you want to look more closely at the land acquisitions for this project, I recommend checking out my public Google Maps project cataloging all of them. If something seems wrong, it might be; I’m working from the same single low-res image above.
Note: this blog was only about the “Permanent acquisitions”, or buildings which would literally be demolished or moved. In a future blog post, I will be digging deeper into the Partial Impacts. Just because your house wasn’t demolished doesn’t mean your yard, your trees, your business or your peace of mind will be spared. Stay tuned!
[1] www.texastribune.org/2023/03/07/houston-interstate-45-highway-expansion/
[2] www.kut.org/transportation/2023-10-16/austin-i-35-expansion-displacements
[3] cityobservatory.org/why-does-a-500-million-bridge-replacement-cost-7-5-billion/
[4] www.opb.org/article/2023/12/01/explaining-oregon-school-funding-challenges-taxes/
- What About the Fish?
The Columbia River is of course migratory habitat for endangered species including Salmon and Steelhead, so construction of the IBR has to be sensitive to these issues.
Among the permitting agencies, the U.S. Army Corps of Engineers publishes as standard in-water work window of November to February. The IBR project however has argued that this would unjustifiably lengthen the number of years required for construction. A Biological Assessment published last year suggests the project would seasonably restrict some activities:
But the same document proposes no restrictions on other activities:
Of particular interest are vibratory hammers and oscillators. ODOT is currently using oscillators to drive pilings for the Abernethy Bridge on I-205 at Oregon City. Interestingly, the Army Corps only appears to be allowing use of oscillators on the Abernethy from July 1 to December 31.
Why are the fish in the Columbia deserving of less protection? Will the Army Corps issue IBR a permit for year-round use of oscillators and vibratory hammers?
- The Public Comment Period is Coming!
The public comment period for the Supplemental Draft EIS will likely begin within a month or two. The Alliance is creating resources to help you understand and meaningfully comment. You can find resources in our library (including draft review copies of some EIS files) as well as an ongoing series of insights from Alliance members.
- RIP Hurley Building (2020-202?)
Among the pre-release files that the Alliance has obtained via public records request is a draft report on the bridge design options: double-deck, single-deck or lift.
An interesting line the “Land Use” line in the comparison table:
Would displace the Hurley Building (commercial office use) in
Vancouver.That’s true for all three options. What’s interesting is that the Hurley Building is brand new, just completed in 2020. It’s a six-story office condominium project.
Here is coverage in The Columbian while the project was under construction. It includes this fateful quote:
“This particular site is located outside of the last set of concept designs shown for the bridge,” Hurley said. “We don’t expect the building to impact any future plans of a bridge.”
Oops…