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Highway expansion will induce traffic demand, will not solve congestion concerns in the long term, and is the antithesis of stewardship for our planet in a climate crisis. By all means update the bridge for earthquake proofness, but do not waste tax monies needlessly expanding the highway.

The comparison of Salmon Creek to I-405 travel times by car, with downtown Vancouver to downtown Portland travel times by transit, seems dishonest and intended to obscure the slow travel times by transit due to low speeds on the existing street-running segments of the MAX Yellow Line. These are two very different lengths (almost 13 miles for cars, less than 9 miles for transit) and ignores the first- and last-mile travel times for cars, such as parking and local access. The unfairness of this comparison is plainly apparent on the Draft SEIS Summary Section 2: Vehicle Travel Times and Transit Travel Times. How can Transit travel times be 10 minutes faster than vehicular travel under the no-build scenario, if no dedicated transit-ways are built under the no-build scenario? This actually includes 10 minutes of access time and waiting, so is the IBR seriously saying transit rides will be 38 minutes downtown-downtown in the no-build scenario? This makes no sense to me. Google maps currently tells me that transit travel times from Pioneer Square to Expo Center are 2-3 times that of cars off of AM/PM peak (which would be served by express buses anyways, so off-peak is the best time to compare MAX to traffic). It is not enough to "provide alternatives"; those alternatives MUST be time-competitive with driving, or else no one who can afford will "make the choice" to take transit. Seattle knew this when it was designing Sound Transit 2; the Link Line 2 will take 30 minutes to travel from the Chinatown International District station to the Redmond Technology station, within a few minutes of a driving commute. This is a relatively similar distance and existing condition case. The slowness and undesirability of the planned MAX expansion is clearly understood by the project itself; if you look at Table 4-38 in the Draft SEIS, the project will only increase transit ridership by 12,500 trips. 8 Billion dollars for 12,500 new trips?? Thats a 0.09% increase over the no-build scenario! Thats as many riders as a very modest Trimet Bus Line, such as Line 71 or 35! We can do so, so much better for EIGHT BILLION DOLLARS. The transit elements of the project need to be reevaluated to provide a rapid and useful transit service which is actually time-competitive with driving, or else the "options" promised are purely symbolic and performative.

As one of the original members of the Columbia Crossing committee and a Hayden Island resident for 25 years, I have watched the I-5 traffic closely as this is the only access point for the island. The traffic has not increased as suggested, the predictive traffic numbers are inaccurate and a new bridge with additional lanes will not solve the bottlenecks of I-5 that occur throughout Portland and Vancouver, not just near the I-5 bridge. Additionally, the consensus of the CRC twenty years ago was that the cost could not be supported by OR or WA. Now the cost is nearly double and growing, with even less return. The impacts on housing, natural habitat, our communities and local budgets are excessive and will not be assuaged by a bigger bridge. Please reconsider this project and look at other options accordingly.

The DSEIS itself includes no discussion of induced demand (topic not found in index). The Transportation Technical report has some discussion of “induced development” (i.e., land use changes) increasing travel demand (based largely on a 14-year-old memo from Metro in Attachment G) but ultimately concludes that land use plans already anticipate completion of the project (p. 6-1). There are multiple mechanisms behind induced demand that are included nowhere in the DSEIS. The attached article from Vox 'The "fundamental rule" of traffic: building new roads just makes people drive more' documents this effect: "The main reason, Turner has found, is simple — adding road capacity spurs people to drive more miles, either by taking more trips by car or taking longer trips than they otherwise would have. ... If you really want to cut down on traffic, Turner says, there’s only one option: charge people to use roads when they’re crowded, a policy known as congestion pricing."

Table 3.19-4 makes the argument that a second auxiliary lane will reduce GHG emissions via congestion reduction. The attached paper summary (Congestion and emissions mitigation: A comparison of capacity, demand, and vehicle based strategies, Alexander Y. Bigazzi and Miguel A. Figliozzi) indicates that induced demand in the long run will overwhelm any GHG reduction from slow speeds by increasing traffic volumes. To quote: "In the long run, capacity-based congestion improvements within certain speed intervals can reasonably be expected to increase emissions of CO2e, CO, and NOx through increased vehicle travel volume."

I OWN A HOME with a yard and dock on E. Hayden Island in the LOTUS Isle homes .we have lived here 6 years. Just off Tomahawk Dr. Re TYPE of bridge: First of all , a TUNNEL under the river, by far makes MOST sense and NOT to have an above river new bridge in this day and age. It’s only a mile. The English Channel is 22 miles and they went under it years ago. A Tunnel under the river would be half the price and take half the amount of time! And most of the on & off ramps just remain the way they are. The greedy contractors who want to charge millions and billions would just have to accept a different tunnel company to go under the river. Canada will be doing it. Why not Oregon- Washington ? I have yet to see a report on this. leave existing bridge and add a tunnel. For those passing Hayden Island . And heading straight to Portland . Re Tolls: Any TOLLS on any I-5 interstate bridge or tunnel should only during the RUSH HOUR time of day ! As when the rush-hour occurs in each direction. It is unfair to charge all us Hayden Island folks during middle of the day to just run an errand from Hayden Island to Vancouver. Unless you give an exception for people living on the island. Tolls during rush hours and directional tolls based on rush hour times are fair. Those who create the traffic weekdays, pay the tolls, nnot everyone else. Fair is fair.

The attached excerpt from the book "City Limits" (Crown, 2024) discusses the history of induced demand in Robert Moses projects in New York in 1939. We have a well established history of induced demand that this project, like most highway projects, ignores.

The attached excerpt from the book "Killed by a Traffic Engineer" (Island Press, 2024) outlines the long history of induced demand and the equally long history of transportation project managers trying to ignore it. The DSEIS fails to adequately analyze induced demand.

I have seen models of a tunnel under the river. Why can't we investigate this cheaper option? How much money over the years have been spent on a bridge that never seems to get built? Stop wasting our money and build a tunnel!

I believe the tolling sensitivity analysis in the Transportation Technical Report is missing a scenario. The analysis has No Toll, LPA Toll and Higher Toll scenarios. But the Transportation Commissions subcommittee has also been discussing aspects of Washington State Law that suggest tolls should be reduced after bonds are retired. It seems like a "low toll" scenario would be useful to understand the impact of this possibility?

The DSEIS itself includes no discussion of induced demand (topic not found in index), the processes by which adding vehicle capacity leads to increased travel demand. The Transportation Technical report has some discussion of “induced development” (i.e., land use changes) increasing travel demand (based largely on a 14-year-old memo from Metro in Attachment G) but ultimately concludes that land use plans already anticipate completion of the project (p. 6-1). There are multiple mechanisms behind induced demand that are included nowhere in the DSEIS. The attached article from "Yale Climate Connections" discusses some of these mechanisms and documents that this has been understood at some level for almost 100 years. "So the biggest factor that people consider when deciding how to get around is cost. That’s a matter of dollars, but also time – time is a really, really important factor in how we travel. When a particular roadway is congested, traveling on it can take a long time, or an unpredictable amount of time, which discourages people from using it. Highway widening is kind of like putting travel on sale. It attempts to reduce congestion by expanding the amount of roadway supply, reducing the time cost of travel for travelers using it. So let’s say traffic kept me from going to a restaurant I really like that’s 20 miles away, but after the highway is widened, I can go there more frequently. Or I might choose a doctor in the next town over as opposed to the one in my neighborhood. We rearrange our travel patterns because of highway expansions, and the new driving that results is what we call induced travel. And research has shown that because of induced travel, congestion returns to previous levels about five to 10 years after the highway is widened."

The DSEIS itself includes no discussion of induced demand (topic not found in index), the processes by which adding vehicle capacity leads to increased travel demand. The Transportation Technical report has some discussion of “induced development” (i.e., land use changes) increasing travel demand (based largely on a 14-year-old memo from Metro in Attachment G) but ultimately concludes that land use plans already anticipate completion of the project (p. 6-1). There are multiple mechanisms behind induced demand that are included nowhere in the DSEIS. The attached journal article republished by NACTO (originally published in 1999) explains some of these mechanisms.

The DSEIS itself includes no discussion of induced demand (topic not found in index), the processes by which adding vehicle capacity leads to increased travel demand. The Transportation Technical report has some discussion of “induced development” (i.e., land use changes) increasing travel demand (based largely on a 14-year-old memo from Metro in Attachment G) but ultimately concludes that land use plans already anticipate completion of the project (p. 6-1). There are multiple mechanisms behind induced demand that are included nowhere in the DSEIS. The attached graphic illustrates how the cycle of induced demand leads to never-ending proposal for adding auto capacity.

Please see attached the press release with Just Crossing Alliance member reactions to problems with traffic modeling documented in our prior comment #134

Attached is the independent review of IBR Traffic Modeling conducted by Norman Marshall of Smart Mobility. Two critical findings: - No build traffic is grossly overestimated, beyond the physical capacity of the roadway (the same error is seen in the CRC modeling) - The actual critical bottlenecks in the corridor are south of the project area. While there are hints of this in the DSEIS (express bus delay for example), this is obscured by measure auto travel times between freeways rather than actual trip origins/destinations. IBR should re-do it's modeling, including using the 2023 RTP and the Regional Mobility Pricing Project and careful study of Induced Demand in order to accurately portray differences between the no-build and build scenarios.

The cumulative effects section fails to discuss the likelihood that IBR construction will overlap construction on the Rose Quarter project as well as Superfund cleanup projects in the Portland Harbor. The possibility of cumulative travel delays for travelers in the corridor is not analyzed nor is the possibility of excessive heavy vehicle activity in North Portland from the combined construction projects.

The IBR DSEIS uses the 2018 RTP as the basis for traffic modeling (p. 3.1-18). Given that the DSEIS was released more than 9 months after the adoption of the 2023 RTP this is an unsupportable choice, particularly egregious in that it means the Regional Mobility Pricing Project (RMPP), which was first adopted into the 2023 RTP, is not part of the modeling. RMPP has the potential to significantly change travel behavior through the corridor and should be factored into analysis of IBR.

In the CRC EIS (p. 3-3) congestion is defined as speeds below 30mph. In the IBR EIS congestion is defined as speeds below 45mph (p. 3.1-6). This is an egregious case of "moving the goal posts" and skews the analysis of the project benefits.

I am writing in opposition to the proposed Interstate Bridge Replacement (IBR) given the information in the EIS released last month. In a time when the focus should be on sustainable transportation, notably transit, walking and cycling, the IBR project will spend $7 billion dollars and in some cases actually increase traffic and congestion. 1) The whack-a-mole approach of planners, i.e., fixing a bottleneck in one spot thereby creating a new bottleneck just down the road, does not address the root causes of congestion. 2) The matter of induced demand is all but ignored. 3) Transit times for express buses would actually get worse under several scenarios in this proposal. 4) The climate impact of the IBR is barely offset by using green construction techniques. The SEIS acknowledges that 94% of the GHG footprint is from traffic. Given that transportation nationally is the fastest growing share of GHG emissions the IBR project takes us in the wrong direction.

Please see the attached article from the Urbanist documenting the failure to seriously analyze induced demand and the fact that this is incongruent with the public statements of leaders like Washington State Secretary of Transportation Roger Millar.

I'm writing today to express my concern over the planned reconstruction of the Interstate Bridge. At present, I believe the plan involves widening lanes under the guise of decreasing congestion. I ask what proof there is that this will happen? More lanes lead to more traffic, not less. Look at Los Angeles, look at Houston. Moreover, where you're planning to needlessly and dangerously expand the bridge is directly over my family's home. This design puts my mother and her husband at even greater health risks due to the exposure to the increased levels of pollution. What right do you have to do that? What right do you have to make them sick?

This is testimony on behalf of XRPDX, a 1500 member climate justice organization that is part of a global climate movement. We have no argument with the supplemental environmental impact statement (EIS) in terms of the importance of such a project for seismic resilience, upgrading public light rail transit (LRT), improvements for active transportation, and the additional express bus transit options on shoulder options during peak periods. We also agree with working on some sort of equitable variable congestion pricing designed with the expressed goal of reducing vehicle miles traveled (VMT) (not ONLY paying back the construction bonds). That said, this project should be a right-sized bridge replacement not a $7.5 billion proposal (possibly to be made worse given the draft geotechnical report). We also oppose significant widening for extra and auxiliary lanes. Having followed ODOT’s state transportation plan, we’re painfully aware of the numerous, critical needs for future-focused transportation systems and addressing transportation safety issues statewide AND the current crisis in funding. A right-sized bridge would help bring costs down. Relying on tolling for funding seems risky (the sad story of the SR99 tunnel), and thus along with other groups we would like to see an Investment Grade Analysis prior to a funding commitment by the State. Oregon’s share of this project is not funded and could take away critical monies for other state priorities as well as transportation plan priorities. We are greatly concerned that currently there is not funding for the LRT or express bus public transit which we view as key to supporting this project. ODOT has a problem with chronic cost overruns and we want to ensure that monies are prioritized for public transit. We are also concerned that the steep grades and height being proposed for the fixed bridge design could be a barrier to active transportation and want more work done on addressing that issue. As a climate justice organization, we are worried about the seemingly cavalier dismissal in this EIS of the likelihood of mitigation measures being able to contain warming to even 2 degrees centigrade and non-attention to how this project might contribute to that outcome. Furthermore, the whole way the issue of VMT is treated in this project by ODOT is unacceptable from it’s definition to not recognizing the growing body of research linking highway expansions to induced demand, to virtually ignoring the critical timeframe we have to reduce driving in the US by at least 15% as part of the strategy to cut greenhouse gases (GHGs) in half by 2030, and the fact that even 8 new lane miles will likely result in 41-62 million additional VMT annually along with those added emissions. Furthermore, we are concerned about the equity and climate justice issues given that 80% of commuters are Clark County residents, but North and NE Portland residents have disproportionately been affected by toxic air pollution, noise, and the neighborhood impacts of this freeway, not to mention its’ history of dividing Black neighborhoods and displacing residents. The displacement of residents and businesses is again on the table and a smaller footprint might lessen the need for as many as are being projected. We have concerns about some of the data presented in these models. We were surprised to see the 180K vehicles estimate for the no-build option for 2045 when that same estimate number was utilized in an earlier model for 2028. Does the forecast for 30K less vehicles than the bridge carries today come from transit and active transportation or what other factors go into that modeling? If it anticipates moving significant traffic counts of vehicles to I 205 crossing due to tolling, that is a problem (especially since the model without real evidence seems to minimize that possibility). Forecast modeling has been problematic, for example ODOT’s 2005 prediction of 1.3% growth whereas in reality there has been almost negligible (more like.3%) overall growth in traffic counts from that time to the near present, including some times of actual decline. Logically, the claim of having very little difference in VMT whether it is one or two auxiliary lanes does not make sense, but given what we are seeing in data presented on a number of fronts including GHG reductions, a second auxiliary lane should definitely not be included in any final plan. We were puzzled by the variable time toll rates increasing southbound peak hour bus travel in the mornings in 2045 compared to the no build model, but now realize that is because a significant part of congestion is actually from the I5/I405 split and with that not resolved this project will not reduce southbound morning congestion or reduce “stop and go” emissions with the backups still predicted to Mill Plain. It also seems like ODOT needs to work with PBOT and Trimet to address how LRT capacity is likely to be constrained at the Rose Quarter. Finally, we are concerned about mitigating the impacts of this project on the river ecosystem, endangered migratory fish species, and the life cycles of other fish and water species. The US Corps of Engineers places limits on various types of construction to a November-February timeframe, but this project is proposing Sept.15-April 15 for impact pile driving during the salmon migratory season. It also has a gigantic loophole exception for “diver-assisted removal of specific individual pieces of debris or large rip rap necessary to place a drilled shaft” being conducted at any time of the year. Similarly, there are no other restrictions on other activities such as vibratory hammers or oscillators from use in year-round construction. We are concerned by the lack of details or data on how these practices and their deviations from project norms could impact fish or other species. In short, we favor a right-sized, more affordable bridge replacement project focused not on lane expansions but on seismic upgrades, additional light rail and express bus public transit, active transportation and with congestion pricing to reduce VMTs.

I have been saying this for years, and continue to say it because it continues to be true. I live in SE, work in Lloyd, and am a daily all-season bike commuter. Lloyd's air equality is among the worst in the state, and there is no heavy industry in the area causing it - it's all from transportation, I-84 and I-5 are both within sight of my building. Adding lanes of any kind does not cure congestion, and congestion and idling are not the cause of the air pollution I breathe in my trips to work and back home: traffic volume is. Induced demand is real, and when driving becomes easier, there is more driving. When there is more driving, especially at higher speeds, driving becomes more dangerous. A DOT's goal should never be to make driving easier or more attractive. Congestion saves lives. If you consider it a problem, fund good alternatives to driving. Fund transit, because a well-used bus, even if it's is stinky diesel, still produces less pollution than if its riders all committed by SOV. Fund transit well enough to electrify those buses, run it frequently enough that we only need route maps and not schedules, and both pollution and congestion disappear. That should be our goal.

It's discouraging to see that ODOT uses and encourages flawed data to support the projects that they want to build, instead of what is actually needed. increasing capacity has been shown over and over to induce congestion, I have seen it first hand on the widening of Hwy 26 to Murray Blvd and past. People do change travel plans and may even carpool when traffic congestion is a barrier. Tolling hasn't even been tried yet. Let's right size the project with a earthquake resistant bridge and not induce people to get in their cars and increase the pollution that we already have. Thank you.

There is no reasoning that supports a mega bridge as a climate solution. More lanes encourages more drivers. More drivers make more exhaust and more noise. More lanes mean more spread for access. More lanes require more resources to build and maintain. Build instead light rail and fewer lanes. The planet is screaming and few hear. The Columbia Crossing diers must listen and act to pull back from bridge and freeway expansion that only accommodates cars.