ODOT Memo on Highway Plan Policy 1G seems Shallow

Now that the initial comment period has closed, the SRC team is posting a flurry of responses and documents. One of the interesting ones is titled "Salem River Crossing - Oregon Highway Plan Policy 1G - Major Improvements." In it, ODOT claims that

Based on the attached information, it is ODOT's opinion that the Salem River Crossing Project has met the requirements of, and is consistent with, the OHP Major Improvements Policy and Action 1G.1.

So let's look at their case. (The memo is italicized and indented here: Bold italics are in original, regular italics are added. Roman type is commentary and not in the memo.)

As part of the introductory material they write:

Action 1G.1
Use the following priorities for developing corridor plans, transportation system plans, the Statewide Transportation Improvement Program, and project plans to respond to highway needs. Implement higher priority measures first unless a lower priority measures is clearly more cost effective or unless it clearly better supports safety, growth management, or other livability and economic viability considerations. Plans must document the findings which support using lower priority measures before higher priority measures.

It seems to me that analysis ODOT offers to support these claims is generally weak and largely not supported:

• There is no argument developed about ways that the SRC as a lower priority measure is actually more cost-effective than "higher priority measures." (Whatever has happened to "least cost planning," by the way?)
• There is no argument developed about ways that the SRC and Preferred Alternative better supports safety or livability. (In fact, if more people walk, and fewer drive, the system will be safer!)
• There is still the question about what "implement" actually means. As we drill into the bullet points in the memo, we will find several of the actions the memo appeals to as having been implemented are theoretical only, having no position in an adopted plan with a funding plan in place, not to speak of already being constructed or funded with actual FTEs. They are hopes and wishes. This is not an ordinary, plain English interpretation of "implement."

The first and highest priority in Policy 1G:

1. Protect the existing system - The highest priority is to preserve the functionality of the existing highway system by means such as access management, local comprehensive plans, transportation demand management, improved traffic operations, and alternative modes of transportation.

• ODOT implemented access management on Wallace Road with the Salemtowne to Orchard Heights project described in priority 3 below and as redevelopment of commercial properties has occured on Wallace Road south of Orchard Heights Road
• Relocation of a traffic signal on Wallace Road from 7th Street to Taggart Street with that street was extended.
• Illustrating the proposed location for Marine Drive in the city's comprehensive plan and TSP consistent with the recommendation of the 'Wallace Road Local Access and Circulation Study.'
• Added video cameras to Wallace Road and other intersections in order to better manage and adjust traffic signal timing.
• Continued funding of the Regional Travel Demand Management and Regional Rideshare Program.
• Expansion of transit services to Polk County, including a new park and ride lot at the Polk County Fairgrounds in Rickreall and Route 2X serving trips between downtown Salem, west Salem, and Grand Ronde.
• Completion of the Salem River Crossing Alternate Modes Study which evaluated measures that could be implemented to reduce single occupant vehicle traffic on the Marion and Center Street Bridges. Measures identified in that study will be implemented as part of the Salem River Crossing Project.

So let's consider what is missing here:

• The biggest preservation omission is of course the seismic retrofit of the existing bridges. It is just insane that we have this fully developed bureaucratic discourse and analysis from ODOT that just slides right over this essential preservation measure. 
• What does "illustrating the proposed location for Marine Drive" have to do with "implementing" anything? That is a theoretical and preliminary gesture only.
• We need to talk more about Rideshare's funding levels. It has averaged something like $200,000 a year and is getting bumped up to $300,000. In what world does this funding level constitute a serious attempt to implement TDM measures? That's basically a whisper of vermouth, passing the bottle over the martini glass without pouring anything into it! It's a winky, knowing gesture that pretends to fund a regional TDM program.
• Just completing the Alternate Modes Study doesn't actually implement anything, and as we have seen, very little of the Study has actually been implemented (part 1, part 2). And again, what does "implement" actually mean? Do you have to do something first? Or can you just "promise" to do something at some indeterminate future moment?

The next priority for efficiency:

2. Improve efficiency and capacity for existing highway facilities - The second priority is to make minor improvements to existing highway facilities such as widening highway shoulders or adding auxiliary lanes, providing better access for alternative modes (e.g., bike lanes, sidewalks, bus shelters), extending or connecting local streets, and making other off-system improvements.

• Implementation of the following recommendations of the Bridgehead Engineering Study:
  • Provide two exclusive right-turn lanes from Commercial Street to the Marion Street Bridge (there is currently one exclusive right-turn lane and a right/through option lane)
  • Construct a pedestrian underpass on Front Street at Court Street (after additional consideration, the City constructed a staged, at-grade pedestrian crossing at this location rather than an underpass and widened the Center Street Bridge exit ramp to southbound Front Street reducing delays and queuing on the Center Street Bridge)
  • Widen the westbound approach from the Marion Street Bridge to provide two right-turn lanes onto northbound Wallace Road
  • Remove the eastbound left-turn from Edgewater Street to Wallace Road
  • Provide a free-flow exit ramp from the Center Street Bridge to northbound Front Street (the city has installed a traffic signal at this location which was the identified minimum build solution)
• Installation of sidewalks and bike lanes on Wallace Road as part of the Salemtowne to Orchard Heights project described in priority 3 below.
• Construction of the West Salem Transit Center
• Construction of the Union Street Bicycle/Pedestrian Bridge and associated improvements.
• Addition of paved bicycle path connection (through Wallace Marine Park) between Glen Creek Road and Union Street Bridge.
• Extension of Taggart Street from Wallace Road to 7th Street which has removed some traffic from Wallace Road by providing an alternate access to properties east and west of Wallace Road.

Again, let's look at what's missing.

• "Two exclusive right turn lanes from Commercial Street" have not yet been implemented.
• "a pedestrian underpass on Front Street at Court Street" was not implemented, and a partial substitute constructed instead
• A pedestrian underpass on Wallace Road at Second Street should be implemented, but is not on this list
• "a free-flow exit ramp from the Center Street Bridge to northbound Front Street" has not been implemented
• "associated improvements" on the Union Street Railroad bridge are quite vague. Just above we noted the need for a crossing on Wallace Road, which in the West Salem Business District Action Plan has been formulated as an undercrossing. The Wallace@Glen Creek widening did not offer much improvement for people on bike to cross Wallace Road, and it remains forbidding for many. Green paint alone does not mitigate for the intense volume of zoomy auto traffic. The concept of a rail-to-trail conversion along Second Street, which was discussed in the Alternate Modes Study, was abandoned.
• As we saw with Rideshare funding, an analysis or awareness of "proportionality" or "quality" is elided here: The "paved bicycle path connection...between Glen Creek Road and Union Street Bridge" solves or mends no gap. It's a very tiny piece that was more "stimulus funding" make-work than critical infrastructure. It is an internal park amenity more than a transportation corridor or solution to a key gap. Bare bike lanes on Wallace Road also satisfy a requirement that they be present, but they are not very attractive to most people who might like to bike, and so they are not very effective. Just because a facility exists doesn't make it a useful facility. It's a box to tick, not a meaningful solution. There should be more of a qualitative analysis if we are serious about alternatives to drive-alone capacity.
• Basically the entire suite of recommendations from the Alternate Modes Study is missing. You'd think also that Cherriots would weigh in on this with a formal analysis as well as part of the memo assessing Policy 1G.

So we come back down, I guess, to norms and the way you parse "implement." It may be that there is a set of norms and a settled interpretation for "implement" that accepts a proleptic sense for "implement" and does not require that implementation be actually carried out first. Hopes and wishes and vague plans may be sufficient to demonstrate "implementation." But it is the claim here that this violates the ordinary sense of the word "implement," and that we should want to change the way it is customarily interpreted if it is allowed to have this meaning.

Like we should really, really try very hard to do stuff, real stuff, before widening and constructing new highways!

Not just give a courtesy wave and bulldoze merrily along with new highway infrastructure.

Why is it not obvious that we should throw $50 million at Cherriots and Rideshare and walking and biking before we propose to spend $500 million on a new bridge and highway? In what world is this not a more reasonable and thrifty and sustainable approach? (Why, our world of course!) The SRC team will appeal to the TSM/TDM and 8% memos. "But weee studeeed it and it wonnn't work."

The difference between ODOT's 2005 projections,
the new FHWA 2014 projections, and reality:
We have a busted model.
(PSU/NITC Transportation Talk)

We know no such thing! The modeling for car traffic was totally busted for the past decade, and also failed to predict the sudden uptick of the last year or two. It's broken; it doesn't work. Beyond those failures there are many reasons to think that we lack a very precise model for transportation choices other than drive-alone trips. Between the levels of uncertainty and the high cost of a new bridge and highway, we should experiment rigorously for options other than drive-alone trips. Expansion with new auto facilities should be the "last resort." That's what Policy 1G seems to say.

As for "implementation," it may be that we need to crystallize a new set of norms around what it means to implement alternatives to drive-alone trips first and to implement them seriously. Apparently our current interpretive norms don't require taking the word "implement" very seriously. But even in a system of interpretation with a severe autoist bias, there is a plain meaning of the word "implement" that should support the interpretation here.

The remaining two priorities in the memo,"Add capacity to the existing system" and "Add new facilities to the system," are immediately not relevant here. Fans of the Wallace Road Local Access and Circulation Study and the Bridgehead Engineering Study may have more to say on specific auto capacity measures that are being overlooked at the ends of the bridges. (This is potentially relevant to the question whether facilities within the UGB can accommodate the transportation need. I just want to focus on things other than drive-alone car trips right at this moment. That's the part of 1G I think is being badly neglected.)