Most Recent Comments

Critique of the stated Purpose and Need: I have just spent some time reading Smart Mobility Inc's "Review of Interstate Bridge Replacement Project DSEIS," previously submitted to you by Chris Smith. I now see that the project designers have chosen to focus on not the upstream causes of the congestion you are trying to solve, but only their effects on the Interstate Bridge. Your "Purpose and Need" are wrong to start with, and the problems that need to be solved do not originate on the bridge. One relatively inexpensive and relatively quick solution suggested is reprogramming the existing ramp meters. That should be done regardless, and conditions and need reevaluated several months afterwards.

I understand the need to replace the I-5 bridge, but the project is simply too big and too expensive in light of equally urgent transportation issues facing the region. As the mom of a toddler killed by a careless driver in Portland, I have been told multiple times that there are not enough funds to support relatively simple infrastructure changes that could have saved my son's life. Pedestrian deaths are at a 30-year high in Portland. Recently I met with Portland Bureau of Transportation officials about a dangerous intersection near the neighborhood middle school my children attend. Everyone from the traffic engineer to the PTA and school principal agree this is a treacherous crossing for the dozens of children who walk and bike through it every day - a tragedy waiting to happen - and yet, there is no funding to improve the crosswalk or add a protected bike lane. At the same time, I read about the money ODOT has spent on *consultants* alone for the IBR project ($127 million! - nearly 100 times the annual budget for Safe Routes to Schools) and I think Oregon's transportation leaders have lost the plot. Please stop trying to sell us on a highway mega-project when a less costly replacement would solve the seismic problems of the existing bridge. Please prioritize transit options and leave some transportation funds available for safe streets for families like mine.

My name is Chad Lykins and I live in SW Portland. I am a regular motorist, cyclist, and public transit user. The City of Portland has articulated clear transportation and climate goals. It does not appear to be the case that the IBR project, as currently proposed, advances progress toward those goals. Specifically, it does not make it easier to walk, bike, or access transit as one moves between Washington and Oregon. The vast majority of Portlanders would use alternative transit if it were safe, convenient, and pleasant. The proposed methods for accommodating alternative transit prioritize the safety, convenience, and pleasantness of drivers to the near exclusion of all others. As such, I am concerned that this project would delay progress in carbon emissions by decades. And by making Portland more car dependent, it would also have cascading effects on land use throughout the city, impacting everything from air quality to housing prices. Please build a bridge that prioritizes achieving the goals set out by Portlanders, not just people driving through Portland. Sincerely, Chad Lykins

Please see attached overview comments from the Just Crossing Alliance.

Please find attached the Just Crossing Alliance vision for immediate improvements to the Transit and Active Transportation components of the SDEIS design as well as suggestions for preparing for near- and long-term transit opportunities.

Variable tolling, or congestion pricing, has great potential to reduce congestion at peak traffic periods, to reduce overall VMT and to reduce tailpipe pollution emitted by vehicular travel across the Columbia River bridges. This is in addition to its role in financing the construction and maintenance of a seismically-resilient crossing. The DSEIS repeatedly identifies variable-rate tolling as a means for financing and for demand management. The DSEIS identifies the burdens of tolling on low-income drivers and on EJ populations. The DSEIS notes that tolling decisions will ultimately be made jointly by the Oregon Transportation Commission and the Washington State Transportation Commission. Given the severity of current climate-related catastrophes, such as Hurricane Helene’s devastation and the ongoing drought now involving 48 out of 50 states, it is imperative that every possible design feature of the Columbia River bridges be directed toward reducing greenhouse pollution. I applaud the IBRP’s intention to use variable-rate tolling to reduce VMT. I would encourage planning toward maximizing this benefit while mitigating negative effects for bridge users. Reducing VMT will facilitate freight transit, improve travel times for drivers and for riders of buses. The goal of generating funding from tolling must not override the environmental benefits of congestion-pricing. If tolling is not going to generate enough funds, then the bridge project should be scaled back to save costs. Wise use of tolling will encourage mode-shift to transit and active transportation, as long as those facilities are efficient, safe and attractive to commuters and other travelers. Tolling will have negative effects on low-income and EJ communities, as here noted on page . 3.20-26: “Four-member households at or below the federal poverty level would be the most significantly impacted by a future tolling program. Since these households already spend a relatively larger proportion of household income on transportation, the effect of tolling would increase household transportation costs from 29% of total household income under the No-Build Alternative to 35% under the Modified LPA. Tolling impacts to households at or below the federal poverty level constitute a disproportionately high and adverse effect on EJ populations. On page 3.20-27: In conclusion, tolling on the proposed Columbia River bridges would result in a disproportionately high and adverse effect on EJ populations.” I support the IBRP plans for mitigation of these negative effects that would include a low-income and/or equitable toll program, equitable access to technology and information, and early, inclusive, and equitable public engagement, as noted on page 3.20-40 and 41. These should be considered necessary elements of any tolling regime to avoid damaging effects to these historically disadvantaged communities. I am strongly in favor of initiating tolling as soon as possible so that actual resulting reductions in traffic volumes can be used to guide construction of bridges that are of more modest size, designed to fit that actual vehicle volumes rather than the flawed traffic modeling currently used by the IBRP. Overall, tolling will be necessary and will be beneficial if well-designed for maximal impact on reducing congestion and reducing VMT, while having robust mechanisms to offset its negative effects on low-income and EJ communities.

cityobservatory.org /ibr-contradicts-regions-climate-commitments/ IBR contradicts region’s climate commitments By Joe Cortright ⋮ 8-10 minutes ⋮ 11/4/2024 IBR Traffic Forecasts Violate Portland Region’s Climate Commitments Portland’s adopted Regional Transportation Plan commits the Metro area to reduce total vehicle miles traveled by 12 percent over the next twenty-five years. But the traffic forecasts used to justify the $7.5 billion Interstate Bridge Replacement (IBR) Project call for more than a 25 percent increase in driving over that same time period The RTP is required under state law to plan for a reduction in VMT per capita; the RTP is the way that regional and local governments show they comply with these state climate requirements But the IBR planning is predicated on a world where we drive much more and not any less. Projects like the IBR are required by state and federal law to be consistent with the adopted Regional Transportation Plan, but they are being planned for traffic levels that flatly violate that plan and state requirements. The Interstate Bridge Replacement project’s traffic forecasts are on a collision course with reality – and with legally binding climate commitments. While the Portland region has adopted ambitious goals to reduce driving and greenhouse gas emissions, IBR’s plans assume we’ll do exactly the opposite, projecting a massive 26-27 percent increase in vehicle miles traveled (VMT). This disconnect isn’t just poor planning – it may violate federal law. State law and Metro’s RTP commit the region to reducing total driving by 12 percent Let’s start with the legal requirements. Metro, Portland’s regional government, has adopted a Climate Smart Strategy calling for a 75 percent reduction in greenhouse gases. The state’s Climate Friendly and Equitable Communities (CFEC) rules require Metro to reduce per capita vehicle miles traveled by 35 percent between 2005 and 2050. These aren’t aspirational goals – they’re legal requirements incorporated into Metro’s federally mandated Regional Transportation Plan (RTP), adopted in November 2023. Under state land use regulations, Metro is required to adopt a Regional Transportation Plan (“RTP”) in which Vehicle Miles Traveled (“VMT”) declines by 30 percent from 2005 levels by 2045. The Climate Friendly and Equitable Communities Rule OAR 660-012- 0160(6) provides: Metro shall adopt a regional transportation plan in which the projected vehicle miles traveled per capita at the horizon year using the financially- constrained project list is lower than the estimated vehicle miles traveled per capita at the base year by an amount that is consistent with the metropolitan greenhouse gas reduction targets in OAR 660-044-0020. [emphasis added] Metro’s adopted RTP promises to meet this goal: By 2045, the plan, together with advancements in fleet and technology, is expected to reduce VMT per capita of light-duty household vehicles by 39 percent (compared to 2005 levels) and by 31 percent from (compared to 2020 levels). Metro 2023 Regional Transportation Plan, Appendix J. page 9. The per capita reduction translates into a real reduction in total driving over the next two decades. The math is simple: to meet these targets, the region needs to hold total vehicle miles traveled at about 12 percent below current levels through 2045, even as population grows. Metro’s RTP specifically projects a 31 percent reduction in per capita VMT from 2020 levels by 2045. IBR traffic forecasts plan for 36 percent more driving But IBR’s traffic forecasts live in an alternate universe where these policies don’t exist. The project’s Supplemental Draft Environmental Impact Statement (SDEIS) projects that regional VMT will balloon from 43.1 million daily miles today to 58.8 million by 2045 – a 36 percent increase that assumes driving per person will remain essentially unchanged. Here are the details: The DSEIS claims that base level of driving in the Metro area was about 43.1 million miles in 2015: The DSEIS summarize the results of its modeling to show that the region will drive about 58.8 million miles in 2045. This represents annual VMT growth of about 1 percent per year, and essentially no-per capita decline in VMT, completely at odds with adopted regional policy. Traffic forecasts for the area in and near the IBR project tell the same story. IBR projects VMT in the “study area” will jump from 11.7 million daily miles to 14.2-14.3 million – an increase of roughly 22 percent. This growth directly contradicts Metro’s RTP, which calls for reducing total regional VMT about 12 percent in order to achieve the mandated reduction in VMT per capita of more than 30 percent. The SDEIS Leaves out Oregon climate regulations Perhaps most telling is what’s missing from IBR’s climate analysis. While the SDEIS includes a lengthy inventory of state climate policies, it completely ignores Oregon’s Climate Friendly and Equitable Communities (CFEC) rules requiring Metro to reduce per capita VMT by 30 percent. This selective amnesia is hardly surprising – acknowledging these requirements would expose how fundamentally IBR’s traffic projections conflict with binding regional commitments to reduce VMT. This isn’t just about numbers on a spreadsheet. By assuming away adopted climate policies, IBR creates a self-fulfilling prophecy: project a future of ever-increasing car dependence, then build massive infrastructure to accommodate it. This approach not only undermines regional climate goals but also violates the National Environmental Policy Act’s requirement that environmental analyses be based on reasonable assumptions consistent with adopted plans and policies. NEPA requires that the EIS demonstrate consistency with adopted State and local statues and plans (40 C.F.R. § 1506.2(d)). Specifically, an EIS must evaluate “[p]ossible conflicts between the proposed action and the objectives of Federal, regional, State, and local . . . land use plans, policies and controls for the area concerned.” 40 C.F.R. § 1502.16(c) (1978). “Where an inconsistency exists, the statement should describe the extent to which the agency would reconcile its proposed action with the plan or law.” 40 C.F.R. § 1506.2(d) (1978). The Draft Supplemental Environmental Impact Statement fails to identify this conflict with Oregon climate regulations and the Metro RTP, and also therefore fails to explain how it will reconcile its proposed action to these plans. IBR officials might argue that their much higher traffic projections are somehow more realistic forecasts of future behavior. But this misses the point entirely. The region has made legally binding commitments—codified in its federally required Regional Transportation Plan—to reduce driving to achieve climate goals. The National Environmental Policy Act and federal transportation planning regulations require that projects like the IBR be consistent with this adopted policy framework, not against a hypothetical future where we abandon our climate commitments. The solution is straightforward but would require a fundamental rethinking of the project: IBR must revise its traffic forecasts to align with adopted regional policies as required by federal and state law. This means lowering future VMT levels to about 12 percent below today’s traffic levels, not more than 25 percent higher as in the current modeling. Until then, IBR’s traffic forecasts remain an exercise in illegal magical thinking – assuming away binding climate commitments to justify a massive highway expansion. It’s an approach that not only fails to meet legal requirements but also locks the region into precisely the car-dependent future we’ve committed to avoiding. The choice is clear: either revise the project to align with regional climate commitments, or admit that IBR represents an abandonment of those goals. What we cannot do is continue pretending that we can meet our climate targets while building infrastructure designed for ever-increasing levels of driving.

cityobservatory.org /needless-purposes-how-ibr-violates-nepa/ Needless purposes: How IBR violates NEPA By Joe Cortright ⋮ 8-10 minutes ⋮ 11/1/2024 The $7.5 billion Interstate Bridge Replacement Project’s two-decade old “Purpose and Need” statement is simply wrong, and provides an invalid basis for the project’s required Environmental Impact Statement. Contrary to claims by project proponents, the “Purpose and Need” statement isn’t chiseled in stone, rather it is required to be evolve to reflect reality and better information. Yet IBR is relying on a 2005 purpose and need statement that rests on exaggerated traffic forecasts that have been proven wrong. The IBR’s 2005 Purpose and Need Statement (still forms the basis for the 2024 SDEIS) claimed the I-5 needed to accommodate 1.7 percent more vehicles each year. In reality, traffic growth has been less than a fifth of that amount, 0.3 percent from 2005 to 2019. For decades, highway builders have been pushing a “predict and provide” paradigm, pretending that we needed to plan for an ever-increasing flood of vehicle traffic, and threatening gridlock if highways weren’t expanded. But these self-serving predictions have consistently proven wrong. Law and policy require that the “Purpose and Need” statement be reasonable, and not drawn so narrowly as to exclude alternatives, and that the statement evolve over time as conditions change. But IBR is using, nearly unchanged, a two-decade old statement that falsely claims that I-5 must accommodate ever greater traffic. IBR officials are clinging to an out-dated and simply incorrect purpose and need statement to inflate the size of the project, and to rule out lower cost alternatives with fewer environmental impacts, in violation of NEPA. In the world of mega-infrastructure projects, few things are more important than accurately defining the problem you’re trying to solve. For Portland’s proposed Interstate Bridge Replacement project, that definition comes in the form of a “Purpose and Need” statement – a crucial document required by the National Environmental Policy Act (NEPA). This statement isn’t just bureaucratic paperwork – it’s the legal foundation that shapes the entire environmental review process. Under NEPA, the Purpose and Need statement determines which alternatives must be studied and which can be eliminated from consideration. It essentially sets the parameters for what counts as a potential solution. The current Interstate Bridge Replacement (IBR) project is recycling, wholesale, a Purpose and Need statement originally drafted in 2006 for its predecessor, the Columbia River Crossing. That document’s central claim – that daily traffic demand would grow by more than 35 percent over 20 years – has proven wildly inaccurate. Rather than growing at the predicted rate of 1.7 percent annually (later revised to 1.5 percent), actual traffic on the I-5 bridge has grown at just 0.3 percent per year from 2005 through 2019, and an even lower 0.1 percent rate from 2005 to 2023. This isn’t just a technical detail – it’s fundamental to the entire environmental review process. Under NEPA, agencies must rigorously explore and objectively evaluate all reasonable alternatives that could meet the project’s purpose and need. By vastly overstating future traffic growth in its “Purpose and Need” statement, the project artificially constrains the range of possible solutions, effectively mandating an oversized project while eliminating potentially more modest and less environmentally damaging alternatives from consideration. In essence, the exaggerated traffic projections become a self-fulfilling prophecy – by claiming we need infrastructure sized for phantom traffic growth, the project excludes more modest solutions from even being studied. The Purpose and Need Statement must reasonable, not narrow This matters because federal environmental law requires that projects consider a reasonable range of alternatives. As the 7th Circuit Court of Appeals noted in a key decision, it is “contrary to NEPA for agencies to contrive a purpose so slender as to define competing ‘reasonable alternatives’ out of consideration (and even out of existence).” Yet that’s exactly what appears to be happening here – by defining the project’s “need” as accommodating 35 percent more vehicles in twenty years, when all evidence suggests we won’t see anywhere near that growth, the IBR effectively eliminates smaller-scale alternatives from consideration. The Purpose and Need Statement should evolve—but hasn’t The federal Department of Transportation’s own guidance recognizes that Purpose and Need statements should evolve as new information becomes available. Their NEPA implementation guidelines explicitly state that “the purpose and need section of the project may, and probably should, evolve as information is developed and more is learned about the project and the corridor.” Yet despite having nearly two decades of actual traffic data that contradicts their original assumptions, the IBR team has chosen to simply copy and paste the old statement rather than update it to reflect reality. And the old purpose and need statement has been proven hopelessly wrong. In 2005, the Purpose and Need Statement claimed traffic would increase “more than 40 percent in the next twenty years” implying an annual growth rate of traffic of 1.7 percent per year. The 2008 Purpose and Need Statement downgraded that to 1.5 percent per year, and the “Re- evaluated” purpose and need statement adopted in 2022 made exactly the same claim. Now, with the passage of time, we know that actual traffic growth, even in the “normal” times prior to the Covid-19 pandemic, was less than one-fifth as fast–about 0.3 percent per year. And none of the forecasts that have been done since the original purpose and need statement confirm its extremely high growth rate. This isn’t just about traffic forecasts – it’s about fiscal responsibility and environmental stewardship. Building infrastructure based on phantom traffic growth risks saddling the region with excessive debt for oversized facilities we don’t need, while potentially causing unnecessary environmental damage. The Purpose and Need statement’s exaggerated growth projections are being used to justify a massive project when more modest alternatives might better serve the region’s actual needs. The implications are serious. If the Purpose and Need statement artificially eliminates reasonable alternatives from consideration by overstating future traffic growth, the entire environmental review process is legally suspect. Courts have consistently held that agencies cannot define project purposes so narrowly that they eliminate reasonable alternatives from consideration. The Ninth Circuit Court of Appeals, which covers Oregon and Washington, has explicitly stated that “an agency cannot define its objectives in unreasonably narrow terms.” But that’s exactly what the IBR project has done: called for a project that accommodates 1.5 percent annual traffic growth, even though traffic is growing one-fifth as fast. The solution is straightforward: update the Purpose and Need statement to reflect actual traffic trends and realistic projections. This would allow for consideration of a broader range of alternatives, potentially including more modest solutions that might better match the region’s real needs while reducing environmental impacts and costs. Instead of being locked into a massive project designed for phantom traffic, the region could explore solutions scaled to actual demand. The Interstate Bridge Replacement project is potentially the region’s largest-ever infrastructure investment. Getting it right matters. But you can’t get the right answer if you start with the wrong question. By clinging to demonstrably incorrect traffic projections in its Purpose and Need statement, the project risks building tomorrow’s infrastructure based on yesterday’s flawed assumptions. Before proceeding further, project leaders should revise their Purpose and Need statement to reflect reality, not highway engineer fantasy.

cityobservatory.org /ibr-traffic-modeling-violates-professional-standards-and-federal-rules/ IBR traffic modeling violates professional standards and federal rules By Joe Cortright ⋮ 11-14 minutes ⋮ 10/30/2024 Traffic modeling is guided by a series of professional and administrative guidelines. In the case of the proposed $7.5 Interstate Bridge Replacement Project, IBR and Metro modelers did not follow or violated these guidelines in many ways as they prepared their traffic demand modeling. IBR modelers: Didn’t assess accuracy of their previous modeling Failed to calibrate their models to observed traffic levels Failed to accurately account for capacity constraints Ignored other models and more accurate data that contradicted their conclusions Failed to exhibit scientific integrity Failed to document their data and methods Failed to commission an independent review of their analysis Each of these errors constitutes a violation of professional standards for traffic forecasting, and invalidates the claims made the the IBR Draft Supplemental Environmental Impact Statement. The Interstate Bridge Replacement (IBR) project’s traffic modeling efforts represent a significant departure from professional standards and federal guidelines, raising serious questions about the reliability of its projections and the integrity of its environmental review process. Sponsoring agencies are generally given substantial deference in their technical analyses, but such deference is completely unwarranted when the agencies systematically disregard or violate professional standards. Google Gemini A detailed examination of the project’s modeling work reveals systematic failures to follow established professional practices, federal directives, and state guidelines. Ignoring errors in previous forecasts Perhaps most troubling is the project team’s failure to examine the accuracy of their previous forecasting efforts. Federal Highway Administration (FHWA) guidelines explicitly direct agencies to: “. . . critically review past efforts to be aware of the prior work and to improve on or complement that work” before undertaking new projections. FHWA, Interim Guidance On The Application Of Travel AndLand Use Forecasting In NEPA, 2010, page 6. The National Academy of Sciences specifically recommends that agencies periodically report forecast accuracy, noting that such reporting “reveals any bias in the traffic forecasts” and “provides the empirical information necessary to estimate the uncertainty surrounding their traffic forecasts.” (National Academies of Sciences, Engineering, and Medicine. 2020. Traffic Forecasting Accuracy Assessment Research. page S-10). IBR officials utterly failed to look at their prior modeling efforts and acknowledge or learn anything from their earlier failures. The evidence is stark: While the CRC modeling predicted 1.5 percent annual traffic growth in vehicle traffic on the I-5 bridges between 2005 and 2030, actual growth was just 0.3 percent annually through 2019, and 0.1 percent per year from 2005 through 2023. Despite this significant disparity, the latest iterations of Metro and IBR models inexplicably predict that traffic growth will more than double to 0.63-0.79 percent annually through 2045 in the “No-Build” scenario. This represents a fundamental failure to learn from past mistakes and adjust methodologies accordingly as demanded by FHWA and NAS standards. Metro and IBR models simply failed to look at whether their previous models were accurate; instead choosing to hide these forecast misses from the public. The SDEIS fails to report that the forecasts that were contained in the 2008 Environmental Impact Statement have proven to be wrong by a factor of four. This failure is a fundamental violation of professional standards. Failure to calibrate the model to actual conditions The modeling effort suffers from serious calibration issues. FHWA guidance emphasizes that traffic models must be accurately calibrated to real world values for use in NEPA analyses In the context of a NEPA study, it is important for the study team to focus any calibration and validation efforts that they undertake on the study area. Typically, a regional travel demand model will have been adequately calibrated and validated at least at a regional level prior to adoption. While it is important for the study team to critically review the documentation of this effort, it is suggested that more emphasis be placed on checks at the study area level. It is suggested that the study team scale their calibration and validation effort according to the scale of the analysis, such as its geographic scope. Calibration A meaningful calibration effort would include: . . . Comparison of modeled traffic volumes with traffic counts both for individual roadway segments and at more aggregate levels such as throughout the study area Federal Highway Administration, Interim Guidance On The Application Of Travel And Land Use Forecasting In NEPA, March 2010, page 10 (emphasis added) Metro’s own validation report reveals that their model overestimates daily traffic volumes on I-5 by tens of thousands of vehicles per day, and over estimates PM peak hour northbound traffic at the I-5 Bridge by 18 percent. This overestimation leads to exaggerated predictions of congestion and potentially misrepresents both the project’s benefits and environmental impacts. These calibration errors are not disclosed the the DSEIS. Not constraining “No-Build” forecasts to reflect highway capacity Both Metro and IBR models predict physically impossible traffic flows, violating FHWA guidance on realistic capacity constraints. The FHWA Traffic Analysis Toolbox specifically warns that “care must be taken to ensure that forecasts are a reasonable estimate of the actual amount of traffic that can arrive within the analytical period.” Federal guidance makes it clear that this is critical to the accuracy of the modeling. While the I-5 bridges’ northbound capacity is approximately 5,000 vehicles per hour, the models estimate peak hour flows of 5,740 to 6,290 vehicles – 16 to 25 percent above capacity. These predictions continue to rise in the No-Build scenario, reaching 6,375 (Metro) and 6,905 (IBR) vehicles by 2045. The IBR Traffic Technical Report fails to acknowledge that its estimates of peak hour traffic flows exceed the physical capacity of the roadway, in plain violation of federal guidance. Deficient documentation and lack of transparency The project’s modeling process operates as a “black box,” contradicting established professional standards. As NCHRP Report #765 emphasizes: “Providing transparency in methods, computations, and results is essential.” IBR and Metro have effectively concealed many of the details and limitations of their traffic forecasts. Professional standards impose an affirmative responsibility on modelers to fully disclose this information. Metro and IBR generally refused to provide detailed information about their traffic modeling, except when compelled to do so under public records laws. Metro does not publish on its website the calibration report for its travel demand model, which shows that the model systematically over-states I-5 traffic levels. As noted above, Metro and IBR models failed to disclose the errors in their earlier forecasts. Providing transparency in methods, computations, and results is essential. . . . The analyst should document the key assumptions that underlie a forecast and conduct validation tests, sensitivity tests, and scenario tests—making sure that the results of those tests are available to anyone who wants to know more about potential errors in the forecasts. National Cooperative Highway Research Project Report, “Analytical Travel Forecasting Approaches for Project-Level Planning and Design,” NCHRP Report #765 Federal regulations (40 CFR § 1502.23) explicitly require “scientific integrity” in environmental documents, mandating that agencies “shall identify any methodologies used and shall make explicit reference to the scientific and other sources relied upon for conclusions in the statement.” Ignoring and omitting better models and more accurate data Perhaps most egregiously, the IBR project has completely disregarded more precise modeling work it already paid for. In 2013, the states spent over $1.5 million commissioning CDM Smith to prepare a detailed “Level 3” traffic model for the Columbia River Crossing. This model achieved less than 1 percent variance with actual traffic levels – far better than Metro’s current 18 percent overestimation. In 2023, spent nearly $800,000 to have traffic modeler Stantec estimate traffic levels for the I-5 bridges. The Stantec model was calibrated with about 2.5 percent variance from actual traffic levels. Yet the IBR team has made no mention of these more accurate modeling efforts in the Supplemental Draft Environmental Impact Statement. Not obtaining independent review The U.S. Department of Transportation’s guidance is unequivocal about the need for independent review: “A senior-level peer review, internal and/or external, is therefore necessary... An external peer review by an independent third party can greatly improve its credibility with potential investors, lenders, government officials with oversight and approval responsibilities, and others.” Yet neither Metro nor IBR commissioned such a review. Not verifying value of time assumptions The IBR will be a tolled facility; accurately forecasting traffic levels on tolled roads and bridges depends directly on accurately estimating the value that travelers attached to time savings on tolled routes. Guidance from the Federal Highway Administration directs states to document the reasonableness and reliability of their value of time estimates. (Federal Highway Administration, Interim Guidance On The Application Of Travel And Land Use Forecasting In NEPA, March 2010, page 13). Both the Metro “Kate” travel demand model and the Stantec Level 2 traffic and revenue study purport to predict traveler reactions to varying toll levels, but rely on questionable and largely un-documented assumptions about travelers’ value of time. Stantec’s own report acknowledges the speculative nature of their work, stating that “in many instances, a broad range of alternative assumptions could be considered reasonable... and any changes in the assumptions used could result in material differences in estimated outcomes.” Stantec explicitly disclaims liability for their assumptions, noting that “by their very nature, assumptions regarding information or data are accepted as true or certain to happen without actual proof of same.” Because these value of time assumptions are undocumented, it is likely that the travel demand model substantially mis-estimates actual traffic patterns, invalidating the project’s claims about environmental impacts. Implications These systematic failures in traffic modeling raise fundamental questions about the Interstate Bridge Replacement project’s planning process and environmental review. The consistent pattern of overestimating traffic growth, ignoring capacity constraints, and failing to document key assumptions suggests that the project’s justification rests on questionable analytical foundations. The project’s refusal to acknowledge past forecasting errors, examine more accurate existing models, or subject their work to independent review indicates a troubling lack of scientific rigor. These shortcomings not only violate federal guidelines and professional standards but also potentially mislead decision-makers and the public about the project’s necessity and impacts. As the project moves forward, these modeling deficiencies must be addressed. At minimum, the SDEIS should incorporate the more accurate Level 2 and Level 3 modeling (like that done by CDM Smith and Stantec), properly document assumptions and methods, and submit their work for independent peer review. Without these basic steps, the project’s traffic projections – and the broader environmental review process that depends on them – lack the scientific integrity required by federal law.

Cooking the Books: How IBR used “Post-Processing” to alter the Metro Model By Joe Cortright 29.10.2024 To hear project officials tell it, traffic projections emerge from the immaculate and objective Metro “Kate” traffic model But in reality, IBR traffic projections are not the outputs of the Kate travel demand model. Instead, IBR consultants have altered the Metro numbers, something the label “post-processing.” But what they’ve done, doesn’t meet the professional standards for post-processing—they cooked the books. Post-processing of Kate’s estimates isn’t needed because Kate produces detailed, daily and hourly estimates for the I-5 bridges IBR made contradictory, and unexplained adjustments to Kate predictions: moving thousands of daily vehicles from I-5 to I-205, and hundreds of peak hour vehicles from I-205 to I-5. IBR consultants failed to follow the accepted and required practice of fully documenting their so-called “post-processing” calculations IBR traffic estimates can’t be replicated using the post-processing steps described in the DSEIS The Interstate Bridge Replacement project has been caught fudging its traffic numbers. While IBR officials repeatedly claimed their traffic forecasts came directly from Metro’s supposedly authoritative regional travel model, internal documents reveal IBR consultants secretly altered these numbers without proper documentation or justification. Through public records requests, we’ve learned that IBR staff made substantial undocumented changes to Metro’s model outputs, which they misleadingly labeled as “post-processing.” These alterations further inflated already questionable peak-hour traffic projections for I-5 and present a distorted picture of the project and its environmental impacts. The myth of the Metro model In planning circles, people regularly genuflect to the supposedly infallible Metro “Kate” travel demand model, representing it as an independent and objective source of precise travel information. IBR officials, including project director Greg Johnson, repeatedly assured the public and elected leaders that their numbers came straight from Metro’s modeling. Johnson testified to Metro Council in January 2022 that “What sizes the bridge is the data that we take from the regional models that are a part of Metro and RTC.” RTC Director Matt Ransom went further, claiming the modelers were “walled off” from policy people to ensure objectivity. IBR consultants altered the outputs of the Metro Model These claims were false. IBR didn’t use Metro’s model outputs – they changed them. The alterations were substantial. For 2045 “No Build” forecasts, IBR moved about 15,000 daily trips from I-5 to I-205 compared to Metro’s model. But then for their preferred alternative, they shifted 10,000 trips in the opposite direction – from I-205 back to I-5. They provided no explanation for these contradictory adjustments. Here are the receipts. First, the output from the Metro model, taken from a Metro spreadsheet, obtained via public records requests: This is the February 27, 2023 version; rows showing vehicle class, travel direction and columsns showing hourly volumes are suppressed. Values shown are average weekday traffic in both directions for the No Build (“NB”) and Locally Preferred Alternative (“SDEIS”). Metro’s model outputs are substantially similar or identical for early model runs, such as a spreadsheet dated April 29, 2022, which also says, for example, that the daily No-Build volume would be 190,841. And here are the IBR’s “post-processed” data. The first post-processed data was released in response to a public records request of IBR in July, 2022. The IBR project used its “post-processing” to dramatically shift the picture painted by the Metro travel demand model: In the 2045 No-Build scenario, it moved nearly 15,000 vehicles from I-5 to I-205, changing predicted traffic on I-5 from 190,841 (Metro model) to 176,000 (IBR, post-processed), and changing I-205 traffic from 200,129 (Metro Model) to 215,000 (IBR post-processed). Conversely, “post-processing” shifted trips in the “build” or Locally preferred alternative, from I-205 to I-5. These huge adjustments aren’t fully explained; it is clearly a strong indictment of the inaccuracy of the Metro Model if its predictions are off by such a large amount. In addition, if the model results need to be altered so substantially, then the process, method and calculations used to make those changes need to be more fully documented and explained. Inflated Peak Hour Estimates Even more troubling, IBR inflated peak hour traffic estimates above Metro’s already high projections. For northbound PM peak traffic in 2045, IBR boosted Metro’s forecast by 8-15%. Their “post-processed” estimate of 6,905 vehicles per hour is 530 vehicles higher than Metro’s model output of 6,375. As we’ve noted before, the failure to constrain traffic predictions to the actual peak hour capacity of the I-5 bridges (fewer than 5,000 vehicles per hour in the afternoon peak) produces highly inaccurate forecasts. This isn’t legitimate “post-processing.” In transportation planning, post-processing typically means making technical adjustments when a model only provides daily totals or corridor-level data. But Metro’s model already generates hourly volumes specifically for the I-5 bridge. No such adjustments were needed. To be sure, there are serious problems with Metro’s Kate model. As we’ve pointed out, it systematically overstates traffic levels on I-5, and predicts traffic that exceeds the freeway’s capacity at peak hours. Part of the reason that IBR is altered Kate’s outputs is that they too recognize that Kate overstates I-5 traffic levels. What IBR is really saying is something no one in the region will acknowledge: the Kate model is wildly inaccurate, especially when it comes to predicting traffic for this $7.5 billion dollar project. IBR failed to follow basic professional standards in documenting these changes. Oregon DOT’s Analysis Procedures Manual requires detailed documentation of all assumptions, factors and calculations used in traffic forecasting. (See Appendix I below for details). IBR provided only a vague one-paragraph description of their methodology in response to public records requests. They failed to produce the required spreadsheets showing their work. When we attempt to replicate IBR’s stated methodology, their numbers don’t add up. They claimed to calculate growth rates from Metro’s model and apply them to 2019 base year traffic. But their final outputs don’t match what this process would produce. Their “post-processed” 2045 No Build estimate of 176,000 daily vehicles is over 7,000 higher than their own methodology would generate. IBR made conflicting adjustments in “post-processing.” IBR’s adjustments completely change the story about how their preferred alternative would affect traffic patterns. Metro’s model shows building the project (moving from the No-Build to the Locally Preferred Alternative) would significantly reduce I-5 traffic (-14 percent) while increasing I-205 traffic (+9 percent). But IBR’s altered numbers claim minimal changes: just a 1 percent reduction on I-5 and a 4% decrease on I-205. Other models of I-5 traffic required no post-processing What makes these alterations particularly suspicious is that IBR only claimed to have “post-processed” their numbers after being challenged to reveal their methodology through public records requests. Neither the CDM Smith Investment Grade Analysis nor the Stantec Level 2 study – both based on Metro’s model – mention any “post-processing” adjustments. And calibration reports show that both the CDM Smith and Stantec Level 2 models have a much better “fit” with existing traffic levels than the Metro model. “Post-processing” is an industry-wide euphemism for altering model results highway agencies don’t like Unfortunately, “post-processing” is a widespread practice among highway planners across the nation. A study undertaken by Transportation for America, discussed in the article that Ben Ross and I wrote for Dissent—Highway Robbery—found . . . modelers from seven states told the advocacy group Transportation for America that their organizations alter outputs manually based on “engineering judgment” or “long-range trends” as part of their post-processing. Similar reports come from former employees of highway agencies elsewhere. The pattern is clear: IBR officials misled the public by claiming their numbers came directly from Metro’s model, while secretly altering those numbers without proper documentation or justification. These undisclosed changes conveniently support their preferred narrative about traffic patterns and project needs.

Three Areas of Comment: 1. The congestion problem is this. During the evening rush hour I-5 going north is 3 lanes jam packed with traffic coming from the inner east side, downtown Portland, and the west from the Sunset Highway (Beaverton, Hillsboro, etc). Then a little under a mile from the Columbia river there are 5 major surface streets all merging onto an already packed I-5. These are 1) Marine Drive from the west, 2) Marine Drive from the east, 3) MLK(99E) from the south, 4) Vancouver Ave(via Delta Park) from the southeast, and 5) Interstate/Denver Ave from the south. Essentially this is trying to merge 8 lanes into a 3 lane bridge This is a traffic nightmare and it is folly to think that tearing down one 3 lane bridge and replacing it with another 3 lane bridge will fix this problem. The only real solution is a third bridge across the Columbia River. 2. Mitigation. As near as I could tell there are no local Hayden Island mitigation measures specified for dust, noise and vibration during the 10 years of construction. 3. Locally Preferred Alternative. The so-called LPA (Locally Preferred Alternative) was not preferred by the locals on Hayden Island. This is simply provided by the IBR team. Thank you.

Attached are the presentation materials from the October 1st, 2024 joint meeting of the Oregon and Washington Transportation Commissions. I would call particular attention to slide 29 which shows the toll scenarios that were approved for analysis in the Level 3 Traffic and Revenue analysis. None of the scenarios show a low income discount from the inception of pre-completion tolling. Starting this discount from the first day of tolling is essential for equity.

Attached are the recommendations that ODOT's Equitable Mobility Advisory Committee (EMAC) made to the Oregon Transportation Commission. A key result for IBR from this process was the recommendation to provide a 50% toll discount to households up to 200% of the Federal poverty level. This recommendation should be honored from the inception of pre-completion tolling.

Please reject the Environmental Impact Statement: any EIS that ignores induced demand and suggests that additional lanes will reduce greenhouse gases by reducing congestion is worthless. Let's fix the bridge and incorporate light rail - but let's not move forward with a dramatic expansion of highway capacity.

How will pedestrians and cyclists be shielded from the car noise?

A lot of people go to Hayden Island to buy liquor. Some of them do not drive. Some of them barely walk and instead use a motorized wheelchair. Some of them live in the tower that we call the beer can downtown. I don’t think the battery would last long enough. Do you see a way to shorten or flatten the approach?

My husband is 200 pounds. His wheelchair is 75 pounds. He grew up in Portland. He would love to be on the bridge, but I don’t think I could handle a ramp that long and steep. Do you see a solution for people with our needs?

Why is there no elevator to the bike/ped path on the Vancouver side to help with those that are unable to use the corkscrew (for example, people that would need to push a wheelchair up or down a half-mile long corkscrew path)?

Is the combination of vertical and horizontal distance in the corkscrew path to the bike/ped lane legally allowable per ADA requirements and Washington State 'out of the way' distance?

How does the design of the active transportation facility take into account different forms of micromobility that operate at significantly different speeds (such as different classes of e-bikes and regular bikes)? How will it ensure smooth traffic flow and safety with micromobility devices operating at different speeds in close proximity?

How was induced demand with 1 vs 2 auxiliary lanes factored into the GHG emission projections?

Why is the express bus from Vancouver to Portland in the morning expected to see increased travel times vs the no build scenario?

Why is there no difference in VMT between the options with one and two auxiliary lanes when the concept of induced demand would suggest that adding additional road capacity induces additional driving?

Was the concept of induced demand considered with the addition of the auxiliary lanes and collector/distributor ramps?

Will you have elevators that accommodate bicycles? The Gideon Crossing elevator works quite well. I also like the stairs with the trough to push your bike up or down in case the elevator is broken. Could you also install them?