New Land Use Memo for Salem River Crossing shows how Deeply Unserious We Are

As the Salem River Crossing team gears up for the Land Use approvals and proposed expansion of the Urban Growth Boundary in West Salem, they way they are managing public information is at the very least a little sneaky and underhanded. There's nothing like a commitment to sharing, full disclosure, and public-minded debate.

Fortunately, over at N3B critics have pried some information out of the team.

One of the reports is the Land Use Final Technical Report Addendum. In draft or final form it has not been published to the SRC website. 

In it is outlined the case for the Urban Growth Boundary expansion.

It's a real blizzard of information, and in order for the public to be able to engage it at the level of fact and interpretation of fact, it should be more widely shared with reasonable lead-time for non-specialists to be able to consider and digest it. It should be shared with reasonable lead-time for City Councilors and other Elected to consider and digest it. If the process is structured so that even City Councilors don't have enough time to read all of it, then the process is probably structured wrongly.

More generally even if, in withholding the memo, the SRC team has still been fulfilling the minimum of legal requirements for disclosure prior to a Public Hearing, as a statement of public-minded interest, it is a sham and a sign of disrespect. It is totally reflective of commitments to a pre-determined conclusion and to "public participation theatre."

Since there's so much to consider in it, we'll start with something small and, in the big scheme of things, a relatively minor detail: Bikes and mobility by means other than drive-alone trips. But we need a point of entry. I suspect there will be more to say in additional posts, and a logical second item is to look at its assessment of Alternative 2A, the concept to widen the existing bridges.

Section 4.3.4 on Bikes

From the Land Use Final Technical Report Addendum, on the next page immediately following table 4.3-4 just above:

4.3.4.2 Preferred Alternative Consistency [for Alternate Modes]

As described in the Traffic and Transportation Technical Report Addendum (CH2M HILL, 2016), the traffic modeling performed for the Salem River Crossing Project assumed that more aggressive transit and TSM/TDM programs would be implemented to increase the non-automobile mode split (the percent share of transit, bicycling, and walking trips) to about 8 percent. Therefore, the 2040 traffic forecasts for the preferred alternative assume that, by 2040, vehicular river crossing demand would be approximately 8 percent lower than the initial forecasts in the RTSP.

In addition, ODOT funded the Salem Willamette River Crossing Alternate Modes Study (CH2M HILL, 2010) on a related but parallel track to developing the DEIS. The Alternate Modes Study describes the recommendations that have the highest potential for removing peak-hour automobile trips from the Willamette River bridges in Salem. Priorities include TSM, TDM, transit, parking, and carpool/vanpool concepts, including but not limited to:

• Bicycle/pedestrian network recommendations
• Bicycle/pedestrian spot or program recommendations
• Bicycle/pedestrian educational, policy, or programmatic recommendations
• Transit infrastructure or operational concepts and transit-related educational, policy, or programmatic concepts
• Parking infrastructure concepts and parking-related educational, policy, or programmatic concepts
• Carpool/vanpool infrastructure and educational, policy, or programmatic concepts

The recommendations in the Alternate Modes Study have been presented to the community and area decision-makers. The City of Salem and Salem Keizer Transit have already moved forward with implementation of some priority recommendations as part of updates to transportation and transit system plans. Such efforts are consistent with state, regional, and local goals and policies that encourage and support the availability of a variety of transportation choices for moving people.

As described in the Traffic and Transportation Report Addendum (CH2M HILL, 2016), pedestrian and bicycle improvements for the preferred alternative would include, in each bridge direction, a 10-foot-wide raised sidewalk facility separated from the paved way by a barrier and 10-foot-wide bike lanes/shoulders (each an 8-foot lane plus 2 feet of shy distance) adjacent to the far right travel lane. The bicycle and pedestrian facilities on the new bridge would be linked to exiting and improved facilities on the east and west sides of the river and would enhance the overall connectivity of the transportation system to support and encourage increased levels of travel by alternative modes, consistent with goals and policies in adopted plans.

That's it. That's all it has to say about mobility by means other than drive-alone trips.

Mostly it's empty rhetoric and there is a lot missing. It trades on a lot of assumptions and elides a lot of significant detail.

"Bicycling" as Abstraction and Instrumentality

At the highest level, it uses "bicycling" as an abstract concept and chess piece in the maneuvering and argument for the Third Bridge. It is deductive:

The bicycle and pedestrian facilities on the new bridge would be linked to exiting [sic] and improved facilities on the east and west sides of the river and would enhance the overall connectivity of the transportation system

It assumes all bike lanes are ipso facto an "improvement"and has no interest in asking whether a giant new highway and bridge exacts other costs so great that the overall net effect is a diminishment in "overall connectivity."

It's not interested in an inductive, empirical approach that asks about effectiveness and about real people:

• What do people on bike really need? 
• What will actually "support and enhance increased levels of travel by alternative modes"?
• How would people on bike actually employ the new bike lanes on the Salem Alternative Third Bridge? 
• Are the bike lanes on and associated with the Salem Alternative actually likely to increase the number of people bicycling in Salem?

It's a highway bridge, for highway speeds and dust
not for pleasant walking

MassDOT Separated Bike Lane Guide

Already we have a body of evidence and of policy that suggests people on bike are not an undifferentiated, monolithic type, and that if we truly want to increase rates of bicycling, we need to design and build facilities that work for whole families, not just middle-aged men in spandex. We need to ask that our designs be effective for a range of people.

If our policy goal is this

There is strong and consistent policy support for development of an integrated transportation system with alternative mode choices for the movement of people and goods at the local, regional, and statewide levels

Then we cannot just build for the "experienced and confident" and the proposed Salem River Crossing broadly fails on this. Its construction, associated ramp spaghetti, road widening, and high-speed access roads, all together will multiply barriers along Wallace Road, Edgewater, and the Salem Parkway and will make internal Salem circulation more difficult for most people on foot and on bike. The only ones it will serve are those speedy, aggressive types with a "high stress tolerance."

A new bridge is a "solution" to no actual problems
for people who bike; instead, it creates
a bunch of new problems and exacerbates yet more.

The proposed SCR creates new lines on the map across the river, but does not create new effective connectivity that is broadly available to children, seniors, and families.

Instead, the proposed SCR is Potemkin connectivity for people on foot an on bike.

A Shifty Policy 12 in the Comprehensive Plan

While policies 11 and 12 from the Salem Area Comprehensive Plan are cited in the table 4.3-4, "Summary of Policies on Alternative Modes of Transportation in Adopted Plans," a at least one other is not, and it is an interesting omission.

Here's what is in the Land Use Memo (see table 4.3-4 above):

Transportation Policy 11:
Local governments within the Salem Urban Area shall develop multimodal plans, services, and programs that reduce reliance on the SOV as the dominant means of travel. Progress toward this objective shall be monitored through benchmarks.

Transportation Policy 12:
The Salem Transportation System Plan shall identify methods that citizens can use to commute to work and decrease overall traffic demand on the transportation system. Such methods include transit ridership, telecommuting, carpooling, vanpooling, flexible work schedules, walking, and bicycling.

Salem Comprehensive Plan

Here is what is in the the Salem Area Comprehensive Plan posted to the City website (p. 41):


The edition on the City website says "November 2015," but there is a different Policy 12:

transportation system and demand management measures, enhanced transit service, and provision for bicycle and pedestrian facilities shall be pursued as a first choice for accommodating travel demand and relieving congestion in a travel corridor, before widening projects are constructed. [italics added]

In the City's Comprehensive Plan, Policy 13 is identical to the Land Use memo's Policy 12, as if the old #12 was deleted and now skipped:

The Salem Transportation System Plan shall identify methods that citizens can use to commute to work and decrease overall traffic demand on the transportation system. Such methods include transit ridership, telecommuting, carpooling, vanpooling, flexible work schedules, walking, and bicycling.

Have we lost a policy? Has there been a secret update to the Comprehensive Plan? What is going on here? Is this fishy or innocent?

At any rate, for the last decade the City of Salem has routinely ignored the old Policy 12, which should have been binding, about "first choice for accommodating travel demand" and is doing so again on the Salem River Crossing project. There has been no serious attempt at a suite of actions to try "before widening projects are constructed."

Also, Policy 18 is omitted from the Land Use memo:

The Salem Transportation System Plan shall identify methods that employers can use to better facilitate the commute of their employees, encourage employees to use alternative travel modes other than the SOV, and decrease their needs for off-street parking.

If the spirit of the Comprehensive Plan's policies are to encourage "travel modes other than the SOV," the Salem River Crossing broadly fails this.

The Curious Status of the Alternate Modes Study and TSM/TDM Actions

From the Land Use memo again:

the traffic modeling performed for the Salem River Crossing Project assumed that more aggressive transit and TSM/TDM programs would be implemented to increase the non-automobile mode split (the percent share of transit, bicycling, and walking trips) to about 8 percent....

The recommendations in the Alternate Modes Study have been presented to the community and area decision-makers. The City of Salem and Salem Keizer Transit have already moved forward with implementation of some priority recommendations...[italics added]

The modeling assumes "aggressive" actions to promote mobility other than by drive-alone trip, but only "some" have been implemented.

This is another confusion of deductive logic for inductive, empirical reality. It is as if the idea alone of Transportation Demand Management was sufficient. We don't actually have to implement any of these ideas, we just have to show that we have a couple of studies that assumes we will have done them. Because we say we will do them, we can act as if we have already done them!

This is how your kindergardener reasons, right? This is the magical thinking of a young child!

It does not seem necessary or useful at the moment to dwell on the whole list of TSM/TDM actions, but it is sufficient to note that very few are being activity pursued. There is no serious attempt to take action on the TSM/TDM recommendations in any of the memos or reports. Right now, they are just "potential" and "out there" to implement at some indeterminate future moment.

Significantly, they might be more effective than even the original study authors considered, who limited themselves to modeling and assessing a very short list of actions.

Just tolling solves all our congestion problems!
(Chart not in any SRC memo, but uses SRC's own tables)

Even using the SRC's own internal assumptions (which on other grounds we believe are flawed), just tolling eliminates vast congestion, much more than an 8% in traffic!

The TSM/TDM approach here by the SRC already assumes the conclusion, assumes we are largely helpless and unable to reduce drive-alone trips, and makes no empirical attempt to investigate the truth of that assertion. This is not so much a confusion of deduction and induction but is rather more simply begging the question. It also trades on a path-dependency with a deeply flawed original study: Garbage in, garbage out.

I don't know what exactly the criteria LUBA would use here, but in a broadly reasonable world, you would think that at the very least an impartial referee would require the City to make a serious attempt at implementing TSM/TDM actions before concluding that they were insufficient as part of a strategy to "accommodate the transportation need" inside of the existing UGB. Until such a serious attempt is made, a conclusion that facilities inside the UGB cannot "reasonably accommodate the transportation need" is fantasy and is unfounded.

(Of course, the SRC process has not seemed to inhabit a "broadly reasonable world," and so to hope that it will may be equally fantastic.)

Conclusion

Greenwash - via
Portland Mercury

As we read more of the Land Use memo, maybe there will be observations and arguments here that we need to modify or expand. But at the moment on a first reading, in this part it doesn't appear to take a sincere look at how the SRC could help or would impact travel by bike, and instead looks at how bike lanes can help make the case for a bridge. It uses instrumentally an abstract notion of bike lanes as lines on a map as part of its argument for the bridge and UGB expansion, and does not look at how the bridge would actually impact bike trips and those who might be interested in them.

It might be too much to ask this project not to be so intensely autoist. That might be a naive expectation.

But as long as the official documentation pays lip-service to "an integrated transportation system with alternative mode choices," there is hope that a referee will read that as requiring real trip choices made by actual individuals, moms and kids and seniors, and find the SRC approach lacking in supporting and pursuing realistic options other than drive-alone trips.