Tuesday, March 29, 2016

The Third Bridge NEPA Process has seemed Resistant to Fact

Over at N3B one of our our Electeds was cited as having recently said of the Third Bridge:
[T]he best way to have a meaningful, citywide conversation not confined to websites and private meetings is through the NEPA process. An Environmental Impact Statement will give us a common basis of facts to work with and bounce off of. I'm just not clear why that isn't the best way to resolve this. It would be a shame to try to just stop talking about it. It clearly isn't an issue that goes away. It's been around at least since the late 60's.
Since this is probably a fairly mainstream, even widely held notion, it's not important to ascribe it to anyone in particular. (And it is not interesting to speculate on motives, so here anyway let's not spend any time on identity or motives.)

Adding lanes doesn't work (CalDOT)
Alas, the notion that the NEPA process "will give us a common basis of facts" is dubious and even perhaps outright false. It's a polite fiction, really. And it has been one of the ways bridge apologists have tried to lull skeptics and reduce opposition.

The process has stacked the deck already for a pre-determined outcome that floats freely, untethered by fact.

2006 Purpose and Need Statement
We've seen this in the "purpose and need," which assumes what was to be proven.
Need Statement #1. Based on available data, the existing river crossing facilities and local bridge system in Salem are inadequate for current and future traffic demand, resulting in a need to improve traffic operations in the study area over the No Build Alternative conditions.
The data says no such thing! There were reasons to doubt it in 2006, and even more reason for doubt in 2016.

And a genuine process "based on [best] available data" would contain a feedback or iteration mechanism so better choices could follow from better data.

But from the start, the process enacts as a priori commitment the certainty that the "local bridge system in Salem [is] inadequate."

It is an article of faith here, not a conclusion that has been proved. The whole SRC may be, in fact, an argument in bad faith.

At a presentation on Federal traffic modeling last year, we saw our old friend, the graph of Federal traffic projections and the actual.  

Here's our old friend, the crazy mismatches
between projection and actual
The error isn't just an error in the "error bars." The model uses a linear growth rate that bears no relation to reality! It was wrong 61 times out of 61!

And even the highway-happy Feds are finally coming round to a revision. They have basically whacked the linear growth rate in half.

The difference between ODOT's 2005 projections
and the new FHWA 2014 projections
Other places like the State of Washington have whacked it down even more. California and other state and city departments of transportation are concluding "increasing highway capacity unlikely to relieve traffic congestion." This stance may not quite yet be mainstream or a new conventional wisdom, but there is a substantial body of evidence and data behind it. It's not a fringey assertion.

Our own modeling and argument in the Salem River Crossing process hasn't caught up with this.

But wait, there's more!

Using the SRC's own internal assumptions (including the older linear growth rate), their own modeling shows that as soon as we toll the Marion and Center Street bridges, all our problems go away. Poof!

Just tolling solves all our congestion problems!
(This chart uses data from the SRC,
but was not created by the SRC)
If we start tolling the bridges for revenue for a new bridge, there is no longer any need for that new bridge.

Finally, the Salem Area Comprehensive Plan calls for a range of mobility solutions before widening on a corridor.

In it Salemites have said that
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.
The City of Salem routinely ignores this 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."

It is not unicorns and rainbows to point out the blind eye to fact here. There is a deeply wrought pattern through the whole SRC and NEPA process. Time and time again there are facts or strong evidence that runs counter to the narrative that "We need a Third Bridge," and the process steamrolls over them.

The refusal of fact and refusal to consider strong evidence in the official NEPA process has made it exceedingly difficult to have "a meaningful, citywide conversation."

Politicians who want to contribute to "a meaningful, citywide conversation," should press the SRC and the NEPA process for a greater and more sincere commitment to fact, a stronger commitment to best available evidence, and a stronger commitment to open debate. There's too much at stake in a billion-dollar project.

(Comments are open, but please let's keep this to policy, no personal comments or politicking about candidates.)


Mike said...

The NEPA process MAY gather all of the facts. But that still doesn't prevent the deciders from making a bad decision. They just have to prove that they looked at the facts. Stupid, I know.

Where they can be sued is if it can be proven that their purpose and need is too narrow and if they didn't use the latest available data during the decision-making process.

Susann Kaltwasser said...

Two questions:

1) has it been proven that the new bridge would survive The Big One when it is in a liquefaction zone?

2) how was it determined that the current bridges are not adequate? Is there a standard that is set by either the State or Federal government.

I travel the area pretty regularly and can't seem to find the kind of congestion that some people complain about. It is never as bad on Wallace or the bridge as it is on South Commercial, Lancaster, or Kuebler. I little stop and go for 10 minutes is not what I would consider congestion.

Will the federal government allow use of 2006 data as the basis of a decision or do they have to gather new data?

I guess that was 3 questions, sorry....

I really appreciate the observation that if they were to toll the bridges the use would go way down. Do we assume that means people would cross somewhere else? If so, how can we encourage that now without the toll?

Salem Breakfast on Bikes said...

#1 has an easy answer, I think: No. The NEPA process has totally elided the fact that the Salem Alternative is proposed for a less stable site than the current bridges.

#2 has been the source of puzzlement for a while. I am not certain on this, but I think that one of the cultural triumphs of hydraulic autoism is that it has managed to avoid specifying a legal threshold or standard for road congestion.

There are engineering standards of "levels of service" and "volume/capacity" ratio, and these have become deeply entrenched convention, and the insurance industry may have even adopted them in underwriting for transportation agencies or evaluating fault in collisions, but I don't believe there's actual a Federal or State level regulatory apparatus behind them. Their power has become invisible! It's all about guild preferences and the way those became widespread convention.

Salem Breakfast on Bikes said...


Maybe it will be time to revisit this, but the Oregon Highway Plan (1999 and revised multiple times since) has "volume to capacity ratio targets" (see table on p. 84), but they are not legally binding.

"achieving v/c targets will not necessarily be the determinant of the transportation solution(s). Policy 1F recognizes and emphasizes opportunities for developing alternative mobility targets (including measures that are not v/c-based) that provide a more effective tool to identify transportation needs and solutions and better balance state and local community needs and objectives. Through this policy, the state acknowledges that achieving important community goals may impact mobility performance and that higher levels of congestion may result in certain areas." (p. 69)

So it's clearly in the domain of politics: If enough people are willing to tolerate auto congestion in an area, there is wiggle room here. But until that tolerance arises and is popular, the governing approach will be through the autoist v/c targets.

But the legal and regulatory framework itself doesn't require widening at certain congestion thresholds.

Walker said...

If the sprawl lobby attempts to get a record of decision out of that absurd pile of random guesses and predetermined "outcomes" the decision in Wisconsin has given us a great roadmap to follow.

Ultimately NEPA is pretty toothless, a procedural checklist, but there comes a point where the data can be so bad that it would be arbitrary and capricious to rely on it.

That's the territory where the Bridgasaurus Boondogglus is. Any honest environmental assessment would destroy the whole scheme; thus, we won't have an honest assessment as long as the sprawl lobby has anything to say about it.

So it's just corporate welfare at this point -- shoveling money at contractors to keep the notion alive, the same "never say die" that propped up the zombie "Columbia River Crossing" corpse for so long ($190 million wasted).