Buried in the flurry of new materials posted by the SRC team after the Public Hearing is a memo that I don't think was ever published to the SRC website as something made public to the Task Force of the Oversight Team. It is the foundation for the argument that walk/bike/bus/carpool kinds of things won't make a dent in river crossing traffic. But it's not a very strong foundation, and is really a house of cards.
At that foundation is an explicit shift on, and misleading recharacterization of, a preliminary sketch of analysis that was transformed by rhetoric only, without any additional analysis, into a set of firm conclusions. It also begged the question. A truthy claim morphed into a truth claim! (Most of the memos discussed here are collected in the packet entered into the record as "Alternatives Considered but Dismissed (Revised 08-25-10).")
From "Preliminary" Conclusion to Certainty
Back in 2007 the SRC published a "preliminary" study on walk/bike/bus/carpool things. (Here's a note on it from 2008, and one from 2012.)
ConclusionsWanting to push for a more robust analysis, in an email formally entered into the record, one of the "Transit/TSM/TDM Expanded Subcommittee" members said that
The analysis described in this memo is preliminary and is intended to represent conceptual recommendations as to which TSM/TDM elements appear to have the most influence on travel behavior, to help inform the decision on range of alternatives for the project. The memo is not intended to make policy recommendations such as whether or not user fees, or what type, should be used. Also, while the travel model itself is a valid tool for planning purposes, the assumptions used in any given scenario are subject to discussion. Further refinement of the scenarios described in the memo will be required prior to detailed implementation of any of the concepts discussed. [italics added]
potential TDM/TSM and transit actions to be included in the DEIS need to be spelled out in more detail and more carefully analyzed than has been done thus far.The email goes on to enumerate quite a list of things that deserve more study and ways that our current analytical scheme is inadequate. Many of them made it into the Alt Modes Study - but always assumed as part of the 8%, not modeled or assessed independently of that assumption.
In looking through the Task Force notes - particularly those from last summer - ...there has been a clear expectation that the project team would be presenting a somewhat more comprehensive list of likely actions and supporting analysis. The 1-page chart we recieved at the July 24 meeting...presents only concepts for possible actions and the analysis is limited to one-line conclusions. In sum, the chart seems to say that only one action (transit signal priority) warrants any consideration in the DEIS. (The chart indicates tolling will be considered, but only as it relates to bridge funding.) These results seem to be at odds with available studies and experience in other urban areas which show TDM, TSM and transit improvements of the sort generally listed in the memo are cost effective ways to reduce congestion.
Additional analysis is important because the Task Force has clearly asked for it, because it is needed to address the Oregon Highway Plan and Oregon Transportation Plan, and because it makes good sense. Evaluation of TDM, TSM, transit and minor roadway improvements is directly [sic] by the Oregon Highway Plan major improvements policy (Policy 1G).
And somehow the TDM/TSM/transit things have never been framed up as "things we must do first" and instead are "things we assume we will do at some future time TBD while we go ahead and build a giant bridge and highway anyway."
By 2010, the SRC team had made a "preliminary"and "conceptual" sketch into a very specific set of policy recommendations against TDM/TSM measures and in favor of a set of high-build recommendations. But in 2007 they explicitly cautioned against this.
Here's the way in 2010 they characterize the assessment of walk/bike/bus/carpool after they made the decision to ditch it (this memo might be newly published, but as a summary document it's not so important):
1. Testing of Stand-Alone TSM/TDM AlternativeHere the SRC team is full of certainty that walk/bike/bus/carpool measures "did not address the project need fully" and was not "viable."
In 2007, early in the alternatives development process, a stand-alone Transportation System Management (TSM) and Transportation Demand Management (TDM) alternative concept was tested to determine whether a such an alternative could, by itself, meet the project Purpose and Need, avoiding the need to add general purpose system capacity (lanes) across the river. This analysis is documented in the memo “TSM/TDM (Transit and Roadway Efficiency) Concept – Analysis and Results (August 15, 2007)” included as Attachment 1. While the application of user fees (parking pricing) showed the ability to cause a significant reduction in peak hour trips across the river, this reduction alone did not address the project need fully (in particular, intersection congestion on the local street system) and was therefore not considered viable as a stand-alone option. Having this information, the Project Management Team recommended instead including discrete transit/TSM/TDM options as part of each alternative to be considered and ultimately studied in the DEIS. [italics added]
This does not seem like a sound reading of the 2007 "preliminary" memo, which was much more tentative in tone.
The Magic Moment
The magic and foundational moment for this reading happens in "Demand Reduction Assumptions Used For Travel Demand Analysis of EIS Alternatives" from February 6, 2009. (I'd never seen this before.*)
Again, that seems like an unwarranted and misleading shift from uncertainly to certainty.
From the memo:
ODOT policy supports strategies and programs to reduce traveler demand on State facilities. As part of the alternatives screening process, Transportation System Management (TSM) and Transportation Demand Management (TDM) measures were explicitly analyzed for their ability to reduce travel demand and minimize infrastructure needs to satisfy the project purpose and need. This previous analysis has been documented in the “TSM/TDM (Transit and Roadway Efficiency) Concept – Analysis and Results Memorandum” (August 2007). This analysis considered a wide range of system management measures to reduce river-crossing demand including land use, transit, and parking pricing policies. This analysis demonstrated that demand reduction strategies could lower travel demand. However, these reductions alone did not eliminate the need to add highway capacity to improve mobility consistent with the project purpose and need.The rhetoric also suggests the way that the SRC and NEPA process has been framed for a pre-determined conclusion: "to validate the need for additional highway capacity." Is it an overstatement to say it has been "rigged"? Not really!
In order to validate the need for additional highway capacity even with improved transit service and TSM/TDM options, the Salem River Crossing EIS alternative designs will be based on reduced travel demand forecasts that assume successful implementation of a more aggressive transit and TSM/TDM program than is reflected in the baseline SKATS model. The Draft EIS will document any difference in performance in the event this level of demand reduction is not realized. This approach is documented in the “Approach to Analysis of Transit/TSM/TDM Options Memorandum” (October 14, 2008).
And so in the conclusion we have the origin of our 8% reduction.
RecommendationThis memo and its conclusion is explicitly meant to satisfy multiple requirements in the State Highway Plan in the State Transportation Planning Rule the Salem Comprehensive Plan to "implement" certain kinds of measures before building new highway and road capacity.
Based on the analysis above, we will assume that travel to/from west Salem can be reduced by 10 percent, assuming additional transit/TSM/TDM measures could be put in place as suggested above. External trips, on the other hand, will be assumed to be reduced by only 5 percent, assuming less ability to directly impact these trips without quality fixed-route transit service to support the SOV demand reduction. Given the 60/40 split between internal and external trips described above, the total reduction in trips would be approximately 8 percent.
Does this memo and its assumptions, "Demand Reduction Assumptions Used For Travel Demand Analysis of EIS Alternatives," actually constitute implementing anything?
The position here is that reading the memo and its assumptions as implementing actions violates the normal, plain English sense of the word "implement" and therefore fails to satisfy multiple requirements in the State Highway Plan, Statewide Planning Goal 12, and the Salem Comprehensive Plan. It doesn't implement anything, and it is based on an unwarranted jump from preliminary conclusions in sketch or outline form to certainty.
The SRC's Justification - The Audacity of Nope
It turns out the SRC team was aware of at least some of these problems. In a memo from October 14th, 2008, "Approach to Analysis of Transit/TDM/TSM Options," the project team laid the groundwork for the wacky interpretation of "implement" we have been criticizing here.
taking this approach will enable us to (1) demonstrate fairly and conservatively the independent need for highway improvements even assuming a significant increase in the use of non-auto modes in the peak hours of operation; (2) ensure that the project is not “over-designed” and fully accounts for possible future changes in driving costs and habits; (3) make clear our commitment to support reducing reliance on SOV use through the design and implementation of major projects; and (4) provide the technical basis needed to demonstrate compliance with ODOT’s major improvement policy and justify Oregon Transportation Commission adoption of alternative mobility standards.
For purposes of developing the EIS, this approach assumes implementation of a transit/TDM/TSM program that significantly increases peak hour non-auto mode sh are. Taking this approach allows us to (1) illustrate the independent need for a certain level of highway improvements; (2) support implementation of alternative mode investments that could extend the effective life of the highway investments; and (3) allow the policy-makers/public to choose to make all or any of these investments in alternative modes without being tied to implementation of the needed highway improvements which are as yet unfunded. The proposal has also been reviewed by FHWA and DOJ staff who have concluded this is an appropriate and defensible way to proceed.One element that should be pointed out is that there is no real interest in actually implementing transit/TDM/TSM measures. While the SRC "assumes implementation of a transit/TDM/TSM program" it also says that it is intended to "allow the policy-makers/public to choose to make all or any of these investments...without being tied to implementation of the needed highway improvements." That is, they are optional and actually not assumed.
And by assuming the implementation of things that turn out to be very optional, we don't ever have to take them very seriously! They don't have to be implemented before building a highway, and they don't have to be implemented later. They don't have to be implemented at all, and the idea they might be implemented counts as implementation.
 |
| In July 2012, the decision for a bridge wasn't made yet and no-build was still an option (Evaluation Table, July 2012) |
But the whole draft EIS (published April 2012) was written from the 2009 commitment to "the independent need for highway improvements" and to skirt compliance with State Highway Plan Policy 1G on Major Improvements. This begged the question and assumed as a premise what needed to be proved as a conclusion.
It would be interesting to read the FHWA and DOJ memos that analyzed the proposal and found it "appropriate and defensible."
Anyway, what we have is a bad analysis, dumb conclusions, and then a tremendous path-dependence on it in the DEIS and subsequent documents that a) allows something tentative to slide into a certainty, b) assumes as given what needed to be proved, and c) depends in part on a strange interpretation of "implement." Fallacies abound!
It may be that ODOT has employed this kind of analysis before, and that, for "FHWA and DOJ staff" it is customary practice. But it's bad, and we need to develop new interpretive norms and expectations that when the State Highway Plan Policy 1G says we must
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 considerationsactually implementing things is the primary interpretation and mandate, and it does not get undermined by theoretical claims in plans that
document the findings which support using lower priority measures before higher priority measureswhich is what the SRC has tried to do here - even though "the findings" are very slender and shaky indeed!**
* The memo was not presented to the Oversight Team or Task Force in 2009 (or later). In that sense it was not published. But it is buried in the supporting materials under the Alternate Modes Study. The handy "wayback machine" of the internet archive shows it as far back as 2010 in the previous iteration of the SRC website (here are the two sets, one and two, of bot-crawling under the different urls). So it's not possible to say it was "secret," but it wasn't shared very widely or publicized.
** It feels like this only scratches the surface of ways the TDM/TSM assumptions-qua-"analysis" are dodgy and in bad faith, and there might be more to say in another post! There's a lot of circularity and incompleteness in "the findings," and it might be worth more detail on ways that a "preliminary" set of findings and assumptions should not constitute actual "findings which support using lower priority measures before higher priority measures." There also might be ways to structure the argument for even more clarity.
No comments:
Post a Comment