|Detail of Alternative 2A, from the DEIS, Chapter 2|
(N.B. not from the Land Use Addendum)
The second major step [in the UGB expansion process] requires that Salem prove that the need cannot reasonably be accommodated (language in both Goal 14 and in 660-024 implementing rules) inside the existing Salem-Keizer UGB. This is probably the most important and difficult step in the analysis. For example, the findings will have to show that the alternatives that involve widening the existing bridges only, or adding a new bridge next to the existing bridges in the urban growth boundary, do not reasonably accommodate the need.Section 4.4.2 of the Land Use Addendum is devoted to this question in general, and subsection 188.8.131.52 "Can Alternative 2A Reasonably Accommodate the Transportation Need?" directly looks at it.
Finally untethered from all the expository material in the report, this is one of the principal analytical moments in the memo.
Its conclusion is negative, that
the evidence and findings for the UGB amendment will support the conclusion that Alternative 2A cannot reasonably accommodate the transportation need...This is summarized in table 4.4-3.
- Does the Build alternative reduce congestion levels at the existing bridgeheads (measured by v/c ratios at Tier 1 intersections), when compared with the No Build Alternative in 2035? Fails
- Does the Build alternative reduce vehicle hours of delay (VHD) on the surrounding state and local street system, when compared with the No Build Alternative in 2035?
- No bridge crossing of the Willamette River shall exceed a total of 4 travel lanes in a single direction. Fails
- Does the Build alternative result in a “net” increase in the number of connections (for all modes) across the Willamette River? Fails
- Is the Build alternative consistent with objectives outlined in adopted urban renewal plans for the Downtown and Edgewater/Second Street areas? Would it support and reinforce substantial public investments that have already been made to enhance the viability and livability of these urban renewal areas?
- Is the Build alternative consistent with Policy 1.8 of the Salem TSP? Fails
- Does the Build alternative have a significant adverse impact on Section 4(f) park resources that cannot be avoided or reduced to a “de minimis” impact?
You might disagree, but one of the things that seems to stand out about them together is that they mostly don't organically arise directly from the DEIS and its ancillary materials, but instead are developed as novel claims arising from other, external sources. It is an exaggeration to say they are fabricated out of whole cloth, but there is a distinct element of grasping in them. Except for the first one, they treat "transportation need" more indirectly than not. In this I do not find them very persuasive. (Your mileage may vary!)
Does the Build alternative reduce congestion levels at the existing bridgeheads (measured by v/c ratios at Tier 1 intersections), when compared with the No Build Alternative in 2035?
From the Land Use memo:
For the purpose of the UGB amendment, it is reasonable to establish the following thresholds for operational feasibility that compare the performance of Build alternatives with the performance of the No Build Alternative in 2035. The concept is relatively simple. It is not reasonable to spend millions of dollars on a transportation project if the alternative would not perform better than the No Build Alternative in addressing the purpose and need for the project.This seems promising. There's an implied notion here of cost/benefit ratio.
Here's the analysis:
The intersection analysis results document that Alternative 2A performs worse than the No Build Alternative in 2035 at the Center Street Off-Ramp to northbound Front Street in both the AM and PM peak. Therefore, Alternative 2A does not meet Threshold #1. By comparison, the preferred alternative performs better than the No Build Alternative in 2035 for all 1st tier intersections in both the AM and PM peak and meets Threshold #1.But the notion of proportion in cost/benefit is not continued - that is, if 2A costs $150 million and the Preferred Alternative costs $500 million, is the fact that 2A is worse "at the Center Street Off-Ramp to northbound Front Street" - and apparently no other place! - is that worth $350 million more? (These costs are round figures mostly from 2012; they aren't meant to be precise.)
Considering the regional measure of VHD, Alternative 2A does reduce VHD when compared to the No Build Alternative in 2035. Therefore, Alternative 2A does meet Threshold #2. The preferred alternative also performs better than the No Build Alternative in 2035 on VHD and meets Threshold #2.
This analysis resolves things to a simple binary value and engages in no consideration of proportion and opportunity cost. Is the Preferred Alternative truly $350 million better? If we build 2A, could we ameliorate other problems with that additional $350 million?
If an analysis for expanding the UGB is helpless to deal with even this basic level of nuance, then we are truly screwed.
No bridge crossing of the Willamette River shall exceed a total of 4 travel lanes in a single direction.
Does the Build alternative result in a “net” increase in the number of connections (for all modes) across the Willamette River?
These two are weird. I think they're just making stuff up. These characteristics are related only peripherally to the central question about meeting "transportation need."
From the Land Use memo:
Salem’s acknowledged TSP addresses the issue of how much pavement is acceptable before it significantly impacts the character and livability of the community (Chapter 16, Long- Range Transportation Strategy). The following provision specifically addresses arterials:So what is the authority for these two tests? As I read them, these two tests don't arise from the TSP or any other adopted policy document, but are notions and interpretations that arise from the minds of the memo's authors and are only loosely chartered in the TSP. And the TSP even allows an exception, and says:
4. The City shall limit its arterial streets to a total cross section of no more than five lanes wide. Some intersections may need to exceed the five-lane standard. State facilities and those roads classified as Freeways and Parkways may also need to exceed this standard. Travel demand that would require the exceedance of five-lane arterial cross sections should be accommodated through increased transit service, demand management techniques, and alternative travel modes. Applications of technology and access control should be used to maximize the capacity of the existing and planned street system.Based on the provision in Salem’s TSP, and taking the characteristics of Willamette River bridge crossings in other metropolitan areas into account, the following thresholds are established under the heading of operational feasibility to address the factor of improved connectivity for all modes and redundancy.
Threshold #3: No bridge crossing of the Willamette River shall exceed a total of 4 travel lanes in a single direction.
Threshold #4: Does the Build alternative result in a “net” increase in the number of connections (for all modes) across the Willamette River?
State facilities and those roads classified as Freeways and Parkways may also need to exceed this standard.As I read the passage cited from the TSP, I zero in a very different part:
Travel demand that would require the exceedance of five-lane arterial cross sections should be accommodated through increased transit service, demand management techniques, and alternative travel modes. Applications of technology and access control should be used to maximize the capacity of the existing and planned street system.That is consistent with the mysterious Policy 12 from the Comprehensive Plan (see previous discussion):
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.So how about this "threshold"?:No new bridge crossing shall be built until increased transit service, demand management techniques, and alternative travel modes have been tried in good faith and have failed.
This third test about lane counts on arterials just seems weak all around, and doesn't develop an analysis about "transportation need" and meeting that "need."
In any case, the fourth test is just bridge envy. It is a trivial observation that other cities have more bridge crossings. Of course they do. There are two important reasons for this. First, they built them years ago, often in the streetcar era, when it was cheaper and easier to do so.
|The Preferred Alternative is still in a liquefaction zone|
(via N3B, adapted from chapt 3.18 of the DEIS)
|Center St. Bridge washout in the flood of 1890;|
it made no sense to build where the flood plain was even wider
As with the previous matter, the cost/benefit proportion is ignored here. Sure it would be nice to have a numerically larger number of bridge crossings in Salem, but if an n+1 bridge requires building in a known liquefaction zone and will cost at least $350 million more than widening the existing bridges, and substantially more if the Preferred Alternative is seismically reinforced to the megaquake standard, is that benefit worth all the costs? (The answer here, of course, is negative.)
Finally, the Land Use memo again uses bicycling instrumentally. It correctly points out that 2A eliminates a sidepath on the existing bridges, but fails to account for the system-wide destruction - notwithstanding the obfuscation of "fit" and "scale" - created by the Preferred Alternative's footprint.
From a transportation and urban form perspective, having multiple river crossings (with no more than 4 lanes in each direction of travel) addresses the need to:I just don't see how adding to the numerical count of bridge crossings at all substantively addresses the core question whether the transportation need can be met inside the UGB with additional lanes and other mobility. The "transportation need" is about moving people, not about counting bridges.
Adding travel lanes to the existing bridges would displace existing bicycle and pedestrian facilities from the Marion and Center Street Bridges to the Union Street Bicycle/Pedestrian Bridge located about 400 feet to the north. The opening of the new bicycle/pedestrian bridge in 2009 provided an important new opportunity for bicycle and pedestrian connectivity across the river that is heavily used. Alternative 2A would provide one new vehicle connection from the Marion Street Bridge to Marine Drive, but would eliminate two bicycle and pedestrian connections across the river relative to exiting [sic] conditions. Therefore, Alternative 2A would result in a “net” decrease in the number of connections (for all modes) across the Willamette River and would not meet Threshold #4. By comparison, the preferred alternative would retain the bicycle and pedestrian facilities on the existing bridges and would add bicycle and pedestrian facilities at the new bridge crossing location. Therefore, the preferred alternative would result in a “net” increase in the number of connections (for all modes) across the river and would meet Threshold #4.
- Provide multi-modal connectivity and accessibility to jobs, housing, services, and park and recreational areas (for the entire community);
- Broadly distribute traffic over a larger geographic area to minimize bottlenecks at a single location; and
- “Fit” the scale of the bridge(s) to the scale of the land uses and connecting streets in the bridgehead areas.
Even our MPO recognizes this:
A performance measure that focuses solely on the reliability of vehicular travel time in such a setting is potentially directing investment that could damage the urban fabric of the area and diminish the livability along the corridor.Is the Build alternative consistent with Policy 1.8 of the Salem TSP?
Citing our TSP, from the Land Use memo:
Policy 1.8 Transportation System RedundancyMostly I just wish the City were this zealous about providing redundancy in bike lanes and sidewalks!
The City’s street system shall be planned and constructed to provide multiple routes between locations, including making reasonable efforts to eliminate existing, and prevent creation of new, transportation chokepoints, both natural and man-made.
But again, the "transportation need" is about moving people, not about adding redundancy. I'm not sure this is a substantive argument either.
And it doesn't address the cost/benefit of redundancy. Cheap redundancy is a terrific thing; tremendously expensive redundancy might just be redundant and superfluous.
As I read it, there's only one substantive claim here:
Alternative 2A performs worse than the No Build Alternative in 2035 at the Center Street Off-Ramp to northbound Front Street in both the AM and PM peak.That's it. Every last bit of it. (And of course that doesn't even take into account any criticism of the basis for the 2035 modeling.)
That's not a very strong case for expanding the UGB.
It will be very interesting to read and hear about the ways other people are framing up their criticism and what might actually constitute the basis for a successful denial of the UGB expansion. It seems unlikely that any effective or majority combination of County Commissioners and City Councilors will want to slow or halt the UGB expansion. So then the questions are how assertively DLCD will step in and how an appeal to LUBA might shake out. What we might find persuasive here is not necessarily going to be legally effective. The City's materials on initiating the UGB expansion aren't very informative, but the City of Bend says:
Before LCDC can approve an expansion to a UGB, they need to determine, with DLCD, whether such a proposal satisfies all required element of state law. If not, LCDC issues what's called a "remand" and outlines what the City has to do to obtain final approval (a.k.a. acknowledgement) of the UGB expansion. The remand identifies those tasks and products that LCDC believes satisfies state law, those that require better explanation or findings, and those that require additional work and analysis.Update - It turns out that the proposed UGB expansion is less than 50 acres in size. This means that the LCDC/DLCD does NOT review the expansion and that there is no "remand" action unless a formal appeal is filed and argued with LUBA and LUBA sends it back on a remand decision. Since the political winds favor the UGB expansion, it should be regarded as a done deal and all argument be framed for LUBA.
|Latest schedule revision|
|According to the Traffic Addendum,|
in 2040 close-in the Bridge significantly helps 5 intersections
and makes 4 of them much worse during the morning rush.
(We'll probably look at this in more detail later.)
For more, see the 2016 addenda (memos without links might also be interesting, but have not been published except internally):
- Land Use Final Technical Report Addendum
- Traffic and Transportation Technical Report Addendum
- Geological Resources Final Technical Report Addendum
- Hydraulics Final Technical Report Addendum
- Energy Final Technical Report Addendum
- Archaeological Resources Final Technical Report Addendum
- Salem River Crossing – Project Construction Activities and Impacts