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The DSEIS states on page S-53: “State-level legislation and policy in Oregon and Washington support reducing emissions from transportation to minimize contributions to climate change. There are no specific requirements for mitigation actions in federal, state, or local regulations.” I applaud that the DSEIS calls attention to the need to reduce transportation emissions and that the IBRP includes several design elements that contribute to that goal, but the overall effect of the project does not meet Oregon’s goals. Even if the emissions projections in the DSEIS are correct, this project would not meet Oregon’s emissions goals. ORS 468A.205 mandates 75% reduction of GHG vs 1990 by 2050. (in accordance with the 2013 STS).(https://www.oregon.gov/odot/climate/Documents/Oregon_Statewide_Transportation_Strategy.pdf) The Oregon Governor’s Executive Order 20-04 (on page 5) “calls for the State of Oregon to reduce its GHG emissions (1) at least 45% below 1990 emissions levels by 2035; and (2) at least 80% below 1990 emissions levels by 2050.” So these are directives to Oregon agencies including ODOT, rather than just “supporting” those goals. ODOT intends to comply with EO 20-04’s goal of reducing emissions by reducing VMT and by “cleaning up each mile” (ie increased efficiency of ICE vehicles and shifting to electric vehicles). (https://www.oregontransportationemissions.com/about-the-project) However, current state projections (in 2022) are only on track for a 60% reduction, rather than the goal of 80%, by 2050. So we are not meeting our goals for GHG reduction. On pages 3.19-1 and 3.19-10 of the DSEIS (1,2), the IBRP explains intended ways to reduce GHG emissions. These are effective design elements to reduce GHGs. However, the DSEIS’s projected reduction is minimal, and in actuality, if the width of the roadway is almost doubled as described in the MLPA, this will result in dramatic increases in vehicle crossings, thereby causing much more emissions. The current IBRP design will actually be an emissions disaster, rather than one that complies with Oregon’s emissions goals. We must eliminate auxiliary lanes, wisely use variable tolling to reduce peak traffic, and make mode-shift to alternatives (instead of driving) much more attractive and efficient. These design features would allow the new bridge to support Oregon’s climate goals. (1) “The IBR Program aims to accelerate the local reduction of GHG emissions by developing alternatives to driving, managing transportation demand, and minimizing emissions associated with construction. Through design, the IBR Program also intends to minimize the expected GHG associated with the long-term maintenance of the proposed new infrastructure.” (2) “Compared to the No-Build Alternative, the Modified LPA is expected to reduce GHG emissions by affecting travel choices and traffic operations in the following ways: • Encouraging mode shift to transit by providing an extension of TriMet’s Metropolitan Area Express (MAX) light-rail between Portland and Vancouver and three new stations, expanded express bus service, and park and rides. • Using demand management methods such as variable-rate tolling of the highway to reduce travel demand, promote mode shifts, and reduce travel during peak commuting periods. • Improving traffic operations with ramp metering, auxiliary lanes, and roadway shoulders, which reduce idling by reducing congestion and disruptions due to vehicle crashes and other incidents. • Encouraging mode shift from cars to active transportation (walking and bicycling) with facility improvements that provide a safe, comfortable, and direct path for walking, biking, and rolling.”

We support building a replacement Columbia River bridge that will still be functional after a Cascadia earthquake of magnitude 9+. Given the rapidly worsening damage we are seeing from severe weather emergencies like our worst-ever wildfire season (in 2024), our worst-ever heat wave in June 2021, our worst-ever drought (“Oregon and the western United States are in the worst megadrought on record.”(1)) and huge loss of biodiversity (2), any major public expenditures like this one must be shown to ameliorate, or at least not worsen, our environment. Prevention of worsening tailpipe pollution is essential to show that the MLPA will not worsen environmental harm. The DSEIS asserts that the MLPA will reduce emissions, i.e. on page 3.19-10: “Compared to the No-Build Alternative, the Modified LPA is expected to reduce GHG emissions….“). On page 3.19-1, “The IBR Program aims to accelerate the local reduction of GHG emissions by developing alternatives to driving, managing transportation demand, and minimizing emissions associated with construction.” On page 3.19-3, GHG reductions: “Less than 1% reduction from No Build in total CO2e emissions (MT CO2e/day) in 2045.” This projected reduction is based in part on reduced VMT. On page 3.19-16, “As shown in Table 3.19-5, the Modified LPA would reduce regional VMT, VHT, and VHD compared to the No-Build Alternative.” However, this assertion is based on the flawed assumption that the No-Build scenario will see continued growth of cross-bridge VMT over the next decades. Due to congestion, the bridge has reached its maximum carrying capacity, and continued growth is not plausible, as decreasing truck traffic demonstrates. Compared to the no-build scenario, the MLPA will undoubtedly increase VMT and GHG emissions, in line with all recent roadway widening projects, and lead to grave environmental harm. The IBRP should not be allowed to proceed with the MLPA in its current form with massive roadway widening over a 5-mile stretch, as this will worsen VMT and worsen emissions. Rather, the IBRP should design a more modest, more cost-efficient bridge with three travel lanes plus shoulders but without auxiliary lanes, to avoid adding to rising atmospheric CO2 levels. (1) Oregon and the western United States are in the worst megadrought on record. A megadrought is a period of extreme dryness that lasts for decades. Although there have been individual years of wet conditions over the past two decades, on average conditions have been drier than any other 22-year period in the past thousand years. Drought conditions impact water supplies, streamflow, agriculture productivity, wildfire danger, and ecosystem health. https://www.oregon.gov/owrd/programs/climate/droughtwatch/pages/default.aspx (2) In Oregon alone, 294 species are at an elevated risk of extinction, such as the wolverine, southern resident orca, and great gray owl. https://oregonwild.org/resource/combatting-biodiversity-loss-in-oregon/#:~:text=In%20Oregon%20alone%2C%20294%20species,orca%2C%20and%20great%20gray%20owl.

Various tables in the SDEIS (summary and ecosystems chapters)_ indicate that the project will add somewhere between 10 and 20 acres of elevated shading over the river. The ecosystems chapter explains that this has negative on salmon habitat and creates environments where salmon predators will lurk. This is a strong motivation to study a tunnel alternative.

The Purpose and Need for IBR is essentially the same 6 points initially developed for CRC starting around 2005. These are now hopelessly outdated and inappropriate for our current needs and current understanding of climate and equity (the 'lenses' added for these topics have made no difference in the project that I can see). A fresh purpose and need would likely surface new alternatives. Perhaps no indication of this failure is clearer than the development on the Vancouver waterfront since the CRC project. Understandably this has led to a desire for a waterfront transit station. Applying the old purpose and need and the design derived from it results in the transit station being 100 feet or more in the air. This is not the right answer and we should be developing a new purpose and need for our current needs.

Please 'right size' the scope of the IBR project. Will the extra lanes actually reduce traffic / improve transportation time? Will the coast guard waive their height requirements? Will this project as proposed reduce emissions? Will this project improve the lives of the people in this region? The answer to all of these questions is 'No'. The IBR team needs to right size this project and come up with a plan that isn't so ridiculously oversized to the needs of the region. I do think rail (heavy and light) to Vancouver improvements should be an extremely high priority to our region. And light rail probably still makes sense to be a part of the IBR project. Right sizing this project should also allow us to get this project done, fast. The current bridges are wholly outdated and at major risk for any earthquake so we need to replace them NOW.

We need a replacement bridge across the Columbia River that could withstand a Cascadia Subduction Zone earthquake of magnitude 9+. I was unable to find any specific standard for earthquake resilience in the DSEIS. On page S-50, there is this vague reference: Regulatory Requirements • Design structures to comply with federal, state, and city building seismic codes and standards and apply advancements in earthquake science and construction materials and updates in the conceptual model. Such statements are not convincing. This project will have profound environmental impacts to the region, affecting local communities, fish and other species, air pollution and GHG emissions, as well as burdening taxpayers and toll-payers for decades. To make such environmental impacts seem reasonable, we need more concrete assurance that the bridge design follows the best available science to assure integrity of the bridge after a devastating earthquake. I could not find any specifics that would provide that assurance despite a search of the document using the term “earthquake”. When I searched for “seismic standard”, the references were mostly about the fact that the current bridge does not meet current standards, but no specifics about the design for the new bridge. Knowing that this project will have huge environmental impacts, as attested to by the large scope of the DSEIS, we must have clear and precise documentation of meeting the most rigorous modern seismic standards.

We need a seismically resilient river crossing to replace the current aged structure. I applaud the years of work that has gone into developing this project. However, from an environmental impact standpoint, the current design would be a calamity. We live in a time of rapid worsening disasters. Fortune Magazine estimates that the total cost of Hurricanes Helene and Milton will exceed $50B.(1) Those are hardly the only climate catastrophes we are dealing with. It is clear that these events will continue to become more frequent and severe. For the common good, any megaprojects built today must reduce rather than worsen greenhouse emissions. The IBRP states several times in its DSEIS that they hope that the project will reduce emissions. However, the design contradicts this goal. The DSEIS describes going from today’s 6 lanes with minimal shoulders to 10 lanes with shoulders on each side, possibly with bus routes on the shoulders. This is clearly a huge increase in travel lanes. With any road project, when the road is widened by adding lanes, the amount of traffic increases, thereby increasing the amount of tailpipe emissions.(2-5) While the vehicle fleet is expected to slowly shift to electric vehicles over the study period, during most of this time the majority of car and truck traffic will be powered by internal-combustion engines with emissions that are a major cause of our deteriorating climate. The DSEIS states that in 2045, it projects 180,000 vehicle trips (26% more than current traffic) with No-Build, and 175,000 with MLPA. This projects 3% less vehicle traffic with MLPA than with the No-Build, presumably due to mode-shift and to deferred traffic due to tolling. On page S-21, the DSEIS states that VMT in the project area (MSAT study area) will increase by 66% by 2045 with No-Build, and increase 62% with MLPA. This is highly implausible. If the roadway is doubled in width, there will inevitably be much more vehicle traffic and more emissions. Also, more vehicle traffic means more crashes, more lung-damaging gasses, more particulate deposits (especially toxic tire particles) and more noise. We cannot afford to spend many billions of public dollars on a project that will worsen emissions and public health. We need a seismically resilient river crossing to replace the current aged structure. We should add shoulders for safety and for rapid bus transit. We should reduce congestion by actively encouraging mode-shift to transit and to active transportation by making those alternatives safe, efficient and inexpensive. We should reduce congestion by wise use of variable tolling. But we should not dramatically widen the roadway at the cost of much higher emissions. We need a modestly sized vehicle crossing that relieves congestion by facilitating mode-shifting to less environmentally damaging alternatives. Joseph Stenger MD 1) https://fortune.com/2024/10/17/hurricane-helene-milton-cost-50-billion-priciest-disasters/ 2) https://link.springer.com/article/10.1007/BF00166218 3) https://assets.publishing.service.gov.uk/media/5c0e5848e5274a0bf3cbe124/latest-evidence-on-induced-travel-demand-an-evidence-review.pdf 4) https://link.springer.com/chapter/10.5822/978-1-61091-899-2_27 5) https://www.sciencedirect.com/science/article/pii/S096585642200026X

With climate change's reach ever expanding in the world, this is the time to make the hard calls. The decisions made here with this bridge will have ever lasting impacts on the choices the residents of Oregon and Washington make going forward. Please consider prioritizing active and public transportation in this redesign more than cars. Adding lanes does not solve our problems, short or long term, we need systemic change to our transportation network.

The updated bridge plan needs to include light rail, bus and bike access, not more automobile lanes. Oregon and Washington citizens need to prioritize transportation options that reduce fossil fuel emissions. It has been documented that increased traffic lanes for private and business vehicles does not reduce congestion, but attracts additional use by these wasteful and largely unregulated pollution sources. Minimize costs on this project. Those dollars will be needed to transition to a sustainable economy and repair damage from climate changing activities.

I work for the State of Washington. Oregon and Washington can do better than more car traffic. I take the train to Olympia 1x a quarter from Portland and that's better than okay for me. I get wifi for much of my trip as well that I would not want in cars. Cars are increasingly a safety risk because of the use of cell phones. Why not put some of this money to schools?My PPS school does not have an assistant principal or arts staff to speak about. We have no Black teachers on staff. Why not recruit train and retain more teachers?

Building a massive bridge for automobile travel would encourage people to use our least energy-efficient ground transportation method to cross the Columbia, using funds that could be invested in infrastructure that encourages sustainability, through transportation or other means. A car-dependent bridge would run contrary to climate goals, and would be acting with disregard for our future. As a young person, I do not want to see the future be neglected in this way.

Tolling will cause issue with my employees on Hayden Island. Will an exit be made for residences and workers on the island?

Toll waiver bar code car sticker for Hayden Island Residents to wave tolls going North or South is mandatory. We have no medical/emergency services on the island.

I travel to Vancouver 5 to 6 times a week from Hayden Island. Currently 7-10 minutes each way. Bridge would add time and unaffordable expense. Trimer train is excessive - it can't run when it's freezing and can't run when its hot. Buses are more flexible. Loss of businesses would cause more residents to travel further for necessities. Additional bad air would be harmful to my health.

I live on Hayden Island and the side where the bridge is going to be. What about the impact of noise? As we already have so much noise from the airlines landing their planes @ PDX. Also, the toll for crossing the bridge, since we are going to the island, would we still have to pay for "not" crossing over the bridge?

It is crazy not to have a North Bound Exit for Hayden island Janzen Beach shopping or residents from Portland and to return to Portland. The extra "bridge" is not convenient for Portlanders to shop at Janzen Beach! Or to return home if a Hayden Island resident. Build a tunnel instead!

If a toll is necessary, Hayden Island residents should show proof and receive a pass that waves the fees! And dig a tunnel. No bridge! Vancouver residents cause the traffic to Portland and back, and if they are a commuter (hours in AM & PM), they should pay as they use the bridge twice daily. Get a commuter pass and pay for it!

Making the Active Transportation Path an Attractive and Usable Option As someone who relies on cycling for transportation, it is important to me and other cyclists that the new river crossing have a safe and attractive multiuse (or active transportation) path that does not impose undue burdens or require extremely high physical fitness for its use. Also, to meet the climate goals identified in the DSEIS, the IBRP projects an increase in people using active transportation to cross the river. This will only occur in adequate numbers if the multiuse path is easy to use, safe, attractive and efficient. See page 3.19-10: “Compared to the No-Build Alternative, the Modified LPA is expected to reduce GHG emissions by affecting travel choices and traffic operations in the following ways: ……..Encouraging mode shift from cars to active transportation (walking and bicycling) with facility improvements that provide a safe, comfortable, and direct path for walking, biking, and rolling.” On page 3.1-42, the active transportation path is said to be between 120-163 feet above the river (compared to 90 feet now). I have been unable to find detailed specifications in the DSEIS for the “vertical spiral ramp” mentioned on page 2-41, though on some maps, one can make out a ramp on Hayden Island and a spiral ramp on the Vancouver side. At the IBRP Open House on 10/17/24, I was told by IBRP staff that the ramp on Hayden Island would be 50-55 feet high and about ⅓ mile long, and that the ramp in Vancouver to access the Waterfront Renaissance Trail would be 90-100 feet high and almost 1/2 mile long. These would be significant disincentives for most people to using the multiuse path because of the strenuous activity needed to climb that long. I am glad to see that the IBRP plans to meet ADA requirements for the grade of the path. On the same page (3.1-42), “The maximum grade for the fixed-span configuration would be 1.5% on the Washington side and 3% on the Oregon side; for movable-span configuration, these grades would be 4% and 1%, respectively.” However, this does not specify how long this ramp would be at such grades. These are very long ramps even at an acceptable grade. Having the path on the east side of the bridge will enhance the views over the river toward Mt Hood, which is a pleasant feature. Belvederes that allow pausing to rest and enjoy the view would be a further enhancement. However, if the multiuse path were placed near the LRT route, then pedestrians, people using wheelchairs or skateboards, and cyclists could use the elevators planned for the LRT stations at Hayden Island and Evergreen (if the path were extended to Evergreen). This would be one method to offset the height and length of path access ramps. I am in favor of having the multiuse path situated on the lower deck of a stacked deck bridge configuration. This would shorten the climb to get up to the path from any access point and would somewhat protect users from tailpipe toxic exposure, debris and noise. It would make it easier to tie in to the LRT stations for elevator access. In view of rising summer temperatures, use of the path will be enhanced if it is shaded as it would be for some of the day if it is sited on the lower level. However, if the multiuse path is separate from the roadway, more attention needs to be placed on ensuring safety of multiuse path users, as there will not be even limited protection from having “eyes-on” by vehicle drivers to see someone having a medical or injury problem or to deter violent acts. I was unable to find anything in DSEIS specifying how the Program will ensure that the multiuse path is safe. That should include explanations of how emergency personnel will access the path for medical or criminal episodes, how the path will be kept free of debris (especially glass from motor vehicle crashes), how the path will be kept free of snow and ice, and how the path will be lighted. The Program needs to ensure that there are robust and efficient connections to existing multiuse paths throughout the program area. The multiuse path should be extended north beyond the Vancouver waterfront. This could allow the path to tie in to using the elevators at the Evergreen LRT station. It could allow cyclists or rollers to access or egress from the path at grade if extended until the roadway comes to ground level toward the north end of the project. I am pleased that the Program hopes that: “These changes would reduce many of the perceived barriers to bicycle and pedestrian travel and would improve the connectivity of the active transportation network in North Portland and Vancouver within the study area.”(page 3.1-42), yet it is clear that the height of the path would be a significant obstacle to adequate use of the path compared to the No-Build alternative. We need a multiuse path that is safe and attractive and that does not impose undue burdens or require extremely high physical fitness for its use. To achieve the mitigation of tailpipe pollution through mode-shift to active transportation that the IBRP states is their goal, this path must be designed with these features. Joe Stenger MD

The current bridge design is intended to bring more single-passenger cars from Washington into Portland. If those passengers are going to Portland, then they will clog up the freeway and interchanges, as well as arterials and city streets on the way to their destination, and they will need parking close by. Since this plan doesn't make any allowance for anything but the first two, everything else will result in worse conditions for humans in Portland: more traffic, more exhaust, more delayed buses, more crashes, more injured pedestrians and cyclists. We need more mobility, not more cars. This project would take away mobility from everyone: walking and biking and transit would be worse, and the people who choose to live in a city would be forced to use cars to move quickly, which then means more traffic (and all the ancillary problems) for everybody. Don't contribute to a vicious cycle. We need to use this money to invest in transportation for people, not for cars.

Moving the goalposts: Redefining traffic congestion By Joe Cortright 21.10.2024 IBR re-wrote the definition of congestion to make I-5 traffic look worse For decades, Oregon DOT has defined traffic congestion as freeway speeds below 35 MPH. Now, for the Interstate Bridge project, IBR has moved the goalposts: now any speed under 45 MPH is counted as “congested.” The definition of “congested” matters because its central to claims that in the future there will be more “hours of congestion” than there are today. But by changing the yardstick to count traffic traveling at up to 45 miles per hour as “congested,” IBR has artificially inflated the problem. The determination is based on an unpublished, incomplete ODOT study that was supposed to be finished a year ago. The new 45 MPH threshold contradicts WSDOT research showing freeways like I-5 maximize vehicle flow at 38.5 to 47 MPH. IBR moved the goal posts on what is counted as “congestion” One of the major problems the Interstate Bridge is supposed to fix is to reduce the number of hours of traffic congestion on I-5 between Portland and Vancouver. But the project’s just released Draft Supplemental Environmental Impact Statement (DSEIS) shows that the two state highway departments have inflated their estimates of current and future traffic congestion by re-defining the threshold for what constitutes congestion. In years past, Oregon has treated speeds of less than 35 miles per hour as “congested.” But now, the DSEIS raises that threshold to 45 miles per hour—automatically inflating present and predicted future congestion. The new definition is based on an incomplete, unpublished “White Paper.” The decision to move to a 45 mile per hour threshold is contained in obscure section of the the project’s DSEIS, and has a very questionable basis. The DSEIS says that the OregonDOT is “finalizing a white paper” to redefine congestion as speeds less than 45 MPH. Oddly, the DSEIS says the white paper was to be finished in fall winter 2023—a year before the issuance of the DSEIS itself. Plus, the DSEIS concedes that even that 45 MPH standard may be revised before the “white paper” is finalized. Nonetheless, even though the report isn’t final, and might be revised, and should have been done by now, the DSEIS proclaims “The IBR program has defined congestion as speeds below 45 mph. The Transportation Technical Report for the SDEIS offers this explanation of how they’ve changed the definition of what constitutes congestion. You have to dig deep, it’s on page 498 of the 1,121 page technical report. Congestion was speeds less than 35 MPH, now we’ve decided its lets than 45 MPH Washington State says speeds under 40 miles per hour are optimal for maximizing traffic flow. The new definition flatly contradicts the research and policy of the Washington State Department of Transportation. WSDOT points out that based on published transportation research, freeways carry the maximum amount of traffic when average speeds are between 70 percent and 85 percent of the posted speed limit. When cars travel faster, following distances increase, and the the road can actually carry fewer cars per hour than when speeds are slightly slower. According to WSDOT, these slightly slower speeds make better use of the public investment in expensive road capacity—enabling as many people and vehicles as possible to travel in a corridor. WSDOT research and policy say that freeway throughput is maximized when speeds are 70 to 85 percent of the posted speed limit. Most segments of I-5 in North Portland have a posted speed limit of 55 miles per hour. This means the optimal speed for the standpoint of maximizing traffic throughput on I-5 would be in the range of 38.5 to 47 miles per hour. And, unlike the incomplete, unpublished “white paper” referenced by IBR for its new 45 mile per hour standard, the WSDOT analysis is contained in a technical report, now in its second edition, published for the past six years, entitled “WSDOT’s Handbook for Corridor Capacity Evaluation.” Using a 45 mile per hour standard for evaluating congestion in the IBR project contradicts and violates the policies laid out in WSDOT’s handbook. (Unsurprisingly, there’s no mention of WSDOT’s Corridor Capacity Handbook in the DSEIS transportation technical report).

They’re digging in the wrong place By Joe Cortright6-8 minutes 10/23/2024 The Interstate Bridge Project proposes spending $7.5 billion to widen I-5, but misses the real bottleneck. A new, independent analysis by national traffic expert Norm Marshall of Smart Mobility, Inc., shows that the proposed IBR project fails to fix the real bottlenecks affecting I-5 traffic. Traffic problems on I-5 are caused by bottlenecks outside the project area, that aren’t affected by the IBR project. IBR will make traffic problems worse, especially in the morning peak hour, by funneling more traffic into these bottlenecks. The limited 3 lanes of I-5 in each direction between the Fremont Bridge and Lombard will continue to cause daily congestion. The Oregon and Washington highway departments are planning to widen the freeway to ten or more lanes on a stretch of I-5 between Portland and Vancouver, rebuilding seven intersections and five miles of highway. The community group Just Crossing Alliance retained national traffic modeling expert Norm Marshall of Smart Mobility, Inc., to conduct a detailed review of the IBR’s traffic modeling. But Marshall’s analysis shows this added capacity doesn’t address the real bottlenecks on I-5, which are actually further south of the actual project area. Far from fixing the congestion problem, Marshall’s analysis shows that this will actually make traffic much worse, especially in the morning rush hour. Essentially, the IBR project is building a large funnel to pour even more traffic into the morning southbound bottleneck at about North Lombard. The I-5 freeway narrows to just three lanes between Lombard and the Fremont Bridge, and this is the area where traffic backs up today. Adding even more capacity at and near the bridge simply funnels more cars, more quickly into this bottleneck–and will make traffic conditions even worse. Marshall’s analysis, using detailed hourly traffic speed data for I-5, shows that traffic actually moves more rapidly across the Interstate Bridge than it does in the area south of the project in both the morning and afternoon peak hours. In the morning, southbound traffic from Vancouver backs up from the Lombard Street exit. These speed maps confirm what regular commuters already know: the slow down doesn’t occur on the I-5 bridge—traffic moves at close to 40 miles per hour on the I-5 bridge and approaches. The real slow down is right at Lombard Street, where traffic slows to less than 20 miles per hour. (Between the purple triangles) In the afternoon, Marshall’s analysis shows the real bottleneck is at about Victory Boulevard (which is near the southern boundary of the I-5 widening project). Today, traffic accelerates once it gets past this bottleneck. Again–it is the limited capacity of I-5 between Victory Boulevard and the Fremont Bridge, not the width of the I-5 Columbia River Bridges—that is the real bottleneck. Again, these maps show what regular commuters already know, the big slowdowns on I-5 are well south of the I-5 bridge. For several miles between the Fremont Bridge and Victory Boulevard, traffic moves at 11-13 miles per hour. After Victory, traffic accelerates; and once one gets to the I-5 bridge, traffic steadily moves faster, and when exiting the bridge, traffic moves at 48 miles per hour—roughly the speed corresponding to maximum throughput. As Marshall points out this is a classic example of what traffic engineers call “queue discharge”–traffic speeds increase once you get past the bottleneck. In one of the most memorable scenes from Raiders of the Lost Arc, Indiana Jones and his partner Sallah decipher the instructions from a medallion that shows the location of the Arc of the Covenant, and in the process, see that the Nazi’s seeking the Arc have missed a vital piece of information, Jones and Sallah to exclaim “They’re digging in the wrong place.” In simple terms, that’s exactly what the flawed traffic models generated by the IBR have done. They’re pretending that the bottleneck limiting traffic flow on I-5 between Portland and Vancouver is the width of the I-5 bridge and its approaches. But Marshall’s analysis shows that the real bottlenecks are further south—and won’t be resolved by the added capacity. How can a sophisticated model get things so wrong? Despite the trappings of technical expertise, there’s a very clear reason why the models used by the IBR project are wrong. The models use something called “static traffic assignment” or STA, which break the freeway system into separate segments, and estimate the traffic flow on each segment separately and independently. If the STA model predicts traffic that exceeds the capacity of a roadway one one segment, it fails to address how that has the inevitable upstream and downstream effects. In the real world, if a road is jammed to capacity at one segment, traffic backs up onto preceding segments of roadway, and also no more than the maximum amount of traffic on a constrained segment can flow into the next segment. As a result, even though the capacity of the I-5 bridges is no more than about 5,000 vehicles per hour in the afternoon peak direction, the IBR model claims that more than 6,200 vehicles per hour are crossing the bridge. The STA model assumes that traffic doesn’t back up into preceding segments when flows exceed capacity, and also assumes that more traffic flows into succeeding segments than is possible. This kind of model assumption was necessary forty and more years ago when computer processing power made it hard to allow for these situations. But today, traffic modelers have developed more realistic methods, called “Dynamic Traffic Assignment” that allow conditions on one segment to affect upstream and downstream segments. But IBR modelers have clung to the out-dated, and demonstrably wrong “STA” methodology, even though dynamic traffic assessment models have begun to be developed for other projects in the Portland area, notably modeling traffic flows on I-205. The Marshall Report The Marshall Report, a detailed 32-page critique of the IBR’s traffic modeling, was commissioned by the community group Just Crossing Alliance. You can read the entire Marshall report here:

Inventing millions of phantom trucks to sell a wider bridge By Joe Cortright 28.10.2024 The $7.5 billion plan to widen the I-5 bridges across the Columbia River is being sold, in part, based on claims that it will be used by millions of phantom trucks. Metro’s biased truck modeling over-states current I-5 truck traffic by almost 70 percent: more than 2 million phantom trucks per year. Metro’s model says more than 17,000 trucks crossed the I-5 bridges each day in 2019; ODOT’s traffic data shows fewer than 10,000 truck crossings. Truck traffic on the I-5 bridges is going down, and has declined almost half since 2005 Previous truck growth predictions for the CRC proved to be wildly wrong; the project’s EIS predicted truck traffic would grow more than 2 percent per year between 2005 and 2030; instead, it has declined at an annual rate of nearly 5 percent. The decline isn’t an anomaly: statewide, Oregon truck freight volumes have declined 22 percent in the past 13 years, according to federal statistics Metro’s truck traffic forecast isn’t based on a model: It just appropriates a growth factor based on an unrealistic and inaccurate federal data series that US Department of Transportation officials concede is used for political purposes, not actual decision-making. In the ongoing debate surrounding the Interstate Bridge Replacement (IBR) project, a critical issue : the severe overestimation of truck traffic on the I-5 bridge. This commentary examines the flaws in current modeling practices and their potential impact on project planning and decision-making. IBR and Metro inflated truck counts to exaggerate the current importance of trucks, and built traffic models that grossly overestimate the growth in truck freight. In essence, these flawed traffic models mean that IBR is widening a freeway to accommodate that truck traffic that doesn’t now exist, and based on false predictions of future truck traffic growth–when in reality truck traffic has been declining. Millions of phantom trucks are being used to justify a multi-billion dollar freeway widening Metro’s forecast that grossly overstates current truck traffic The most basic test of a model’s accuracy is whether its predictions match actually observed current reality. Metro’s traffic model—the basis for the IBR traffic estimates and environmental analysis—claims that 17,373 medium and large trucks (Class 4-13) crossed the I-5 bridge daily in 2019. We obtained the Metro traffic forecast information via a public records request. Here’s an excerpt of a spreadsheet showing estimated 2019 truck traffic crossing the I-5 bridges: The figures for heavy and medium trucks in the northbound (nb) and southbound (sb) directions are highlighted. Together, these estimates total 17,373 trucks (6,861 + 6,813 + 1,853 + 1,845) daily. Actual traffic data show’s that’s simply not true: Oregon Department of Transportation (ODOT) traffic count data (full data below) reports just 10,260 such trucks per day. This discrepancy amounts to a staggering overestimation of 69 percent – or 7,113 phantom trucks every day. Metro’s model simply isn’t accurate. This isn’t a minor statistical error. It means planning for the I-5 bridges is somehow designed to accommodate more than than 2.6 million non-existent annual truck trips in the base year alone. The wild exaggeration of the scale of truck traffic shows that the Metro travel demand modeling is deeply flawed, and biased to support the sales pitch for bridge expansion. It’s hardly a reasonable basis for making a multi-billion dollar spending decision. Historical trends vs. Metro predictions Metro’s truck forecast doesn’t merely get current truck volumes wrong; it grossly misrepresents the historic trend. Metro claims truck traffic is up: Oregon Department of Transportation data show that truck traffic on the I-5 bridges has actually gone down. Here’s the data, downloaded from ODOT’s own website. – In 2005, ODOT reported 19,428 class 5-13 trucks crossing the I-5 bridge daily. – By 2019, this number had decreased to 9,809 trucks per day. – This represents an annual decline of almost 5 percent annually over 14 years. – Just prior to the pandemic, truck traffic on the I-5 bridges was down almost half compared to 2005 In spite of the historic trend in declining truck travel, the estimates developed by Metro and IBR make the startling claim that in the future, truck travel will increase dramatically. Metro predicts I-5 truck traffic will grow at 1.9 percent annually, projecting an increase from their (overestimated) 17,373 trucks in 2019 to 28,382 trucks in 2045 under the No Build scenario. The Interstate Bridge Project has falsely portrayed truck traffic levels on the I-5 bridges as increasing. In public presentations, the IBR has claimed that truck traffic increased from 11,000 vehicles per day in 2005 to 14,000 vehicles per day in 2019. While that’s lower than the 17,373 trucks claimed in the Metro model, its still much higher than the number of trucks actually recorded by ODOT traffic counting. IBR claims that I-5 bridge truck traffic rose by more than 25 percent between 2005 and 2019, when ODOT’s own traffic count data show that it declined by almost half over that same period. Another forecast prepared by for IBR by Stantec, a so-called Level 2 traffic study, specifically called out the error in the Metro travel demand model’s truck estimates: As shown before in Table 2-3, the heavy trucks constitute approximately 6.5% of total traffic on the I-5 Interstate Bridge. The [Metro] RTDM estimates heavy trucks to be about 9% of the total bridge traffic. As such, adjustments were necessary to reallocate the estimated truck trips to the proposed tolling classifications to be consistent with observed truck shares. Stantec Level 2 Study, page 4-8 Stantec has a more realistic baseline—11,638 trucks per day in 2015—but calls for an even faster annual growth rate of 2.7 percent, to as many as 25,500 trucks in 2045. A consistent pattern of exaggerating truck growth Exaggerating the level and future growth of truck traffic is a long-standing tactic of the highway widening crowd. The Environmental Impact Statement for the proposed Columbia River Crossing (CRC) project—the IBR’s predecessor—using a previous version of Metro’s model, claimed that truck traffic would increase in a “No Build” scenario from 10,855 trucks per day in 2005 to 19,405 trucks per day in 2030 – an annual growth rate of 2.3 percent. Reality has proven far different. Between 2005 and 2019, I-5 bridge truck traffic actually decreased at an annual rate of nearly 5 percent. Freight forecasts have been proven wrong: Truck freight is declining, not increasing Truck traffic levels are projected using a completely different “module” than the rest of the Metro regional travel demand model. The truck module is based on data which claims that truck traffic nationally (and locally) will increase steadily over time. The data source for this claim is highly suspect. Metro’s RTDM relies on the Federal Freight Analysis Framework 3 (FAF3), which is based on data from 2007 – now over 15 years out of date. Essentially, Metro just creates a “growth factor” from the FAF data and applies it to its (over-estimated) level of current truck traffic. Here’s an excerpt from Metro’s methodology explanation: The FAF3 data essentially assumed steadily increasing tonnage flow of truck freight, and Metro essentially “copied and pasted” these growth factors into its model. But the continuous and aggressive growth assumed in FAF 3 hasn’t occurred. More recent versions of this data series (FAF4 and FAF5) show much lower levels of truck freight activity and project slower growth. The 2011 Oregon Freight Plan, based on FAF2 data, projected an increase in truck freight from 294 million tons in 2010 to 508 million tons in 2035 – a 73% increase over 25 years (2.2% annual growth). In reality, FAF5 data shows truck freight volumes declined from 294 million tons in 2010 to 229 million tons in 2023 – a decrease of 22% over 13 years (-1.9% annually). In short, forecasts of future trucking activity in Oregon based on the Freight Analysis Framework have proven to be monumentally wrong: rather than increasing by more than 2 percent per year, statewide truck freight volumes have been declining at almost 2 percent per year. This updated FAF5 data—not mentioned in the Metro report or the DSEIS—confirm the pattern shown in ODOT traffic counts: truck traffic across the I-5 bridges is declining, not increasing. Yet the IBR is predicating on models that embrace outdated, and now completely discredited forecasts of ever-increasing truck volumes. Freight Forecasts are a politically driven talking point, not real data Not only that, but officials at the U.S. Department of Transportation concede that the truck forecasts in FAF are created for political purposes, and are not a valid basis for decision-making. The DOT’s chief economist wrote: Other federal modal administrations prepare forecasts, but it is done more out of curiosity, to provide talking points for their administrators’ speeches. The Federal Highway Administration’s Office of Freight Operations has for the last several years prepared the Freight Analysis Framework, which forecasts freight flows out 20 years – not just for trucking, but for all modes of freight transportation. But we don’t actually use the FAF forecasts for any real decision-making. The forecasts help to inform the political process in a general way, and provide ammunition for politicians who want to spend more on transportation infrastructure. The truck freight forecasts in the Freight Analysis Framework–especially the now out-dated FAF3 and FAF4 estimates aren’t a legitimate or sound basis for making transportation investments. The Port Traffic Myth Another misconception this analysis dispels is the oft-repeated claim that Port activity significantly impacts I-5 truck traffic. A 2013 study commissioned by ODOT found that only about 50 trucks per day from the Port of Portland’s Terminal 6 use the I-5 bridge. This amounts to roughly one truck every 30 minutes – hardly the flood of port-related traffic often cited to justify the project’s urgency. The Port of Vancouver averages about 330 truck trips total per day, with no clear data on how many actually cross the I-5 bridge. Bad Truck Estimates Undermine the IBR The consequences of these overestimations extend far beyond academic interest. Accurate truck traffic forecasts are crucial for several reasons: 1. Project Justification: Inflated truck traffic numbers may be used to overstate the need for capacity expansion. 2. Design Considerations: Overestimating truck volumes could lead to overbuilt infrastructure, wasting taxpayer money. 3. Toll Revenue Projections: Truck tolls are four times higher than those charged to cars, so getting the estimate to truck traffic right is essential to any financial analysis. As noted by transportation expert Robert Bain, unreliable truck forecasts can significantly impact projected toll revenues, potentially putting the financial viability of the project at risk. The Need for Accountability and Transparency Given the magnitude of the discrepancies identified, it’s crucial that Metro and other agencies involved in the IBR project address these issues openly. Oregon and Washington officials should: 1. Commission a thorough, independent review of the truck traffic modeling methodologies being used. 2. Understand why the models diverge so significantly from ODOT’s actual traffic count data. 3. Update forecasts using the most recent FAF5 data, with a critical examination of its applicability to real-world decision-making. 4. Right-size the project’s design in light of more accurate truck traffic data. Conclusion The phantom trucks populating Metro’s models represent more than just a statistical anomaly. They embody a broader pattern of biased forecasting that has plagued major infrastructure projects for decades. As we contemplate spending billions on the Interstate Bridge Replacement, it’s imperative that we base our decisions on robust, reality-based data rather than inflated projections. To summarize the key statistical discrepancies: – Current traffic: Metro claims 17,373 trucks/day vs. ODOT’s 10,260 trucks/day (69% overestimation) – Historical trend: 4-5% annual decline (2005-2019) vs. Metro’s projected 1.9% annual growth – Long-term forecast: Metro projects 28,382 trucks/day by 2045, while the historical trend would suggest fewer than 7,000 trucks/day if continued The citizens of Portland and Vancouver deserve infrastructure planning grounded in fact, not fiction. It’s time to exorcise these phantom trucks from our models and engage in a clear-eyed, data-driven discussion about the true needs of our regional transportation system.

While it's very important to me that the bridge gets replaced by a new, robust piece of critical infrastructure, the $8 billion cost of increased lanes and interchanges is absurd when the expansion won't help at all. Induced demand will make the congestion come right back, increase suburban sprawl into Washington, damage the environment further due to VMT, and leave us billions in the hole. This is obvious to anybody who takes the issue seriously and does not refuse to study the impact induced demand will have on this project. No money should be wasted on expansion that isn't focused on the most efficient and sustainable support for transit service to reduce VMT rather than increase it.

Many studies have already shown that adding more lanes does not decrease traffic congestion. Not only would expanding this not help, it actually makes traffic worse! I also object to the design of this expansion that would demolish homes and apartments for an ineffectual expansion. We already have a housing crisis, we should not be spending money on a project that will exacerbate it to no public benefit. Instead of spending $8B on a project that: - does not fix the problem it aims to address - worsens traffic - reduces available housing - Worsens Global Warming - Simply pushes the problem south a mile we should spend this money on improving the infrastructure that already exists! Make our current rail system faster and more reliable. Fix the Union Station Train Station in Portland. Update the MAX Orange and Red lines to have baby bullet versions like CalTrain- there should be fast public transportation between Portland and Beaverton. So much traffic flows between these two cities and we could do a lot with this money to get a ton of cars OFF the road. In summation, I heartily object to this project.

This ridiculous bridge won't solve traffic. It will just move the bottle neck. Cancel the lane expansions and build a tunnel instead. Light rail all the way to Vancouver