Sometimes this might be warranted, but it also serves to insulate parts from any criticism at all. Looking at the entirely of the way this argument is deployed on several occasions, it seems clear it is a strategy to deflect reasonable criticism of the parts.
In a systematic way, too often on the SRC values don't scale, and the overall shape of the argument exploits discontinuities between the big picture and the details.
This is a bike blog. So we give the bikey parts extra scrutiny!
|Supplemental Findings, p36|
|Findings Report, p174|
demonstrate[s] that the bicycle system improvements integrated in the Preferred Alternative will result in improvements to the overall bicycle element of the transportation system. This criterion is not intended to be used to judge the overall adequacy of the system in evaluating a single project.But there is no such demonstration in Section 188.8.131.52 of the Findings Report. It simply asserts
The TSP Amendments supporting the Preferred Alternative are consistent with the goal for the bicycle system element. The new bridge crossing will include bicycle facilities on the bridge and connections to bicycle facilities in the bridgehead areas on both sides of the river and will enhance the overall connectivity of the bicycle system in support of the goals listed above. Amendments to the Bicycle Network Maps (7.1, 7-2, and 7-5) will show bicycle facilities on the new bridge and on ramps connecting Marine Drive to Edgewater Street. These facilities will be identified as high priority associated with the Preferred Alternative. Map 7-10 will also be amended to change the priority for the multi-use path along Marine Drive from Tier 2 to Tier 1.There's no argument developed here. It just a bald-faced assertion that these new facilities "will enhance the overall connectivity."
|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.
By saying "This criterion is not intended to be used to judge the overall adequacy of the system in evaluating a single project" the SRC team dodges the need to engage the specifics of any criticism about the ways the particular proposal harms overall urban bike connectivity. It also enables the scholasticism of the approach where first-order analysis is insulated from critique, and then second-order conclusions can appeal to the first-order analysis as if it had "proved" something already! There must be a better name for this - but mostly it seems like a sophisticated form of begging the question. Basically, the SRC team can say anything in the first-order analysis, and then use those assertions as "already proved" to make further deductions.
A similar pattern occurs with climate change.
|Supplemental Findings, p60|
concerns regarding climate change impacts are not sufficient in themselves to remove roadway and highway improvements as reasonable and often necessary transportation options.And then it claims that hydraulic autoism chartered by Goal 12 always supersedes concerns about climate change.
That's an interesting claim. Maybe it is true that in our current regulatory scheme, there is no provision for climate change concerns to halt or modify a project. We saw in the situation at the Blind School that unless TSP and Comprehensive Plan policies are translated into statute, they frequently have no binding force, are advisory only, and the City is free to ignore them.
Much of our Climate Change policy is like this: We have lots of high-level policy language about reducing greenhouse gases, but little in the way of required actions or criteria that have made the translation into statute or administrative rule.
|Oregon Statewide Transportation Strategy, p23|
|Our greenhouse gases are supposed to go down,|
but the SRC causes a 16% increase in energy use
(Comment in red added;
DLCD Greenhouse Gas Target Rule Presentation)
|Oregon Statewide Transportation Strategy, Policy 6, p74|
Oregon Highway Plan Policy 1G
|Supplemental Findings, p39|
|Supplemental Findings, p11|
Together, these summaries demonstrate that the City has made progress towards improving transportation choices.But it is possible to read "these summaries" very differently. Here is commentary on part of the "presentation by the Mid-Willamette Valley Council of Governments to the Salem City Club dated February 8, 2013," referenced in the Supplemental Findings, p11 above.
|Only the Union St. RR Bridge is an Unambiguous Improvement|
(and getting across Wallace and Commercial is still difficult)
February 2013 City Club Presentation
The summary of implementation of the SRC Alternative Mode Study Recommendations is similarly thin. (See full discussion here and here.)
The passage in the Supplemental Findings on page 11 is argument by fiat! Because a memo exists, it is good and authoritative. Reasons the memo and its underlying analysis might be defective are never engaged. But if the parts are incomplete or defective, how can the whole be sound?
Overall Misuse of Part-Whole Relations
Overall, there are at least two part-whole problems here:
- Faulty parts (technical memos we'll call them, the first-order analyses) of the Salem River Crossing process are held immune from critique, and then are assumed to be true as later moments of analysis appeal to them as "proof." That's like publishing a document claiming 2+2=5, and then later using that new math elsewhere, with an appeal to the published "proof." Garbage in - garbage out! This is that Medieval scholasticism with too much deductive argument from faulty first premises and first-order analysis.
- Claims about the whole system, like about multi-modalism in Salem, are made without the parts being necessarily true. If there aren't really very many multi-modal parts in Salem, how can the whole be multi-modal? The argument here is that in most things pattern and value must scale from small to big, and the parts must have a quality in order for the whole also to have that quality.
It also might point to ways that in all Salem planning processes, early stage technical memos might need more searching critique so that later conclusions based on them aren't faulty in the way we see on the SRC.