The Portland region’s metropolitan planning organization has poked more holes in the I-5 Rose Quarter project. Big ones.
In a 7-page letter dated today and sent to Oregon Department of Transportation Project Manager Megan Channell and Federal Highway Administration Environmental Specialist Emily Cline, Metro’s Director of Planning Elissa Gertler tallied a long list of serious concerns with the project’s environmental assessment (EA).
Gertler, speaking on behalf of Metro staff, doesn’t directly call for completion of a full environmental impact statement (EIS, a more rigorous analysis as per the National Environmental Policy Act process); but her detailed takedown makes it clear that Metro is not comfortable with ODOT moving forward into the design phase without more comprehensive, detailed analysis of several key components of the project.
Metro’s concerns come amid a flurry of bad news for ODOT as numerous organizations — and at least one state legislator (more on that below) — file official comments just before the deadline. Last week we shared the news that The Street Trust, Oregon Walks and Albina Vision Trust have joined the Portland Public School Board, the City of Portland’s bicycle and pedestrian advisory committees and several other organizations in airing serious concerns and calling for a full EIS.
Metro has based their response to the EA on several factors including: a lack of analysis of safety impacts, a request to study more design concepts for the freeway lids and other elements of the proposal, a lack of time to fully analyze all available documentation, and concerns about construction impacts.
Below are key excerpts from Gertler’s letter (emphases mine).
Metro staff believes the EA is inadequate in its evaluation of serious crashes, including documentation of existing conditions and an analysis of how the alternatives compare on reducing serious crashes. This inadequacy means that project designs that can reduce deaths and life changing injuries are not being evaluated, despite direction from federal, state and regional policies.
… Metro staff is not aware that the project area is an area of concern for serious crashes when compared to statewide averages.
… Not evaluating the relationship of congestion to overall crash rates and serious crash rates raises questions about the design solutions identified to address crashes, which are described as addressing congestion and safety simultaneously.
Behavior is cited as a primary factor in all of the serious crashes – following too close, not paying attention, aggressive driving, speeding and alcohol. It is not clear how the design solutions in the Build Alternative will address behavior…
On the proposed freeway caps:
Metro staff also recommends development and evaluation of new design concepts for the highway caps and a segment of Broadway, and has requests and recommendations related to transportation including clarification of analysis, evaluation of different design concepts, and consideration of additional mitigation measures.
… There is insufficient information about how well the proposed highway caps will functionally meet the City of Portland’s adopted land use plans. Metro staff believes ODOT and FHWA should better document how the proposed design will provide public open space that offers genuine opportunities for “recreation, relaxation and respite” including details on management and maintenance of these spaces and air quality and noise levels on the caps.
There are reasonably foreseeable options to the proposed highway caps that were not explored in the design concept screening process, such as reinforced caps or a tunnel-type structure that could support some forms of development. With more robust construction, capped areas could potentially support low-density construction that could activate what might otherwise be vacant, underutilized spaces; a tunnel-style treatment could potentially support more intensive development that would have a more transformative effect on the district. Further exploration of these design concepts in the environmental process is recommended.
On “agency coordination”:
The process for releasing the full documentation and analysis within a 45-day review period without any prior review opportunities of technical work did not allow for a full review of the analysis by Metro staff. As the designated Metropolitan Planning Organization for the Portland region and the administrator of the region’s urban growth boundary, Metro staff believes our agency should have been afforded the same opportunity as the City of Portland for prior review of technical reports on land use and transportation. Metro staff’s comments are therefore based on a high level review rather than a complete understanding of the work.
The analysis should clearly define any changes in emissions including diesel and greenhouse gases to neighborhoods along the I-5 corridor from North Portland to the South Waterfront/Lair Hill area.
On “no new capacity” claims:
The EA states (section 3.2.2) that the project does not create new capacity or add substantial capacity to I-5. This statement is not objectively true and is potentially misleading; auxiliary lanes clearly add capacity, which can be calculated using Highway Capacity Manual procedures and other traffic analysis tools.
On surface street proposals:
The width of Broadway between Williams and 1st is shown as five (5) one-way motor vehicle lanes, which is incompatible with a multimodal, mixed-use environment, and may increase in poor driver behavior. Metro staff requests alternatives to this configuration be developed and further evaluated.
The EA does not document whether the project considered the feasibility and cost of retaining both Hancock and Flint as overcrossings. Metro staff requests this scenario be evaluated for consideration.
Metro staff recommends the final Clackamas and Hancock bridge designs include direct connections without switchbacks on both sides, as well as consideration of stairway connecting Clackamas to Wheeler to allow more direct non-ADA pedestrian access.
Metro staff recommends the project include a southbound bike lane on Williams between Broadway and Wheeler, to best connect with the Rose Quarter Transit Center
and Moda Center.
Metro staff requests clarification on how the signalization at Williams and Hancock would move bike riders from the right side to the left side, and how bike riders on Vancouver would transition from the right side of the street to the left side prior to Hancock.
The EA indicates that bus and streetcar performance will be slowed due to signal phasing changes. Metro staff requests FHWA and ODOT consider additional ways to mitigate this impact, including the consideration of BAT lanes, transit only lanes, and signal modifications (including TSP) on Broadway and Weidler.
On construction impacts:
Metro staff requests the project document how construction-period access will be addressed.
Read the full letter here.
Metro Council President Lynn Peterson also sent a letter to ODOT and the FHWA. Her tone was diplomatic. Peterson is playing it safe as she tries to build broad support for a major transportation bond measure Metro plans to bring to voters in 2020. If Peterson were to directly oppose this “congestion relief” project it would hurt her credibility in some parts of the region and make it more difficult to get mayors and other electeds on board.
In related news, House Representative Karin Power (D-Milwaukie/Sellwood) has become the first state legislator to call for a full EIS.
In a letter sent to ODOT today, Rep. Power (who voted against the 2017 bill that green-lighted the project) said she wants ODOT to analyze more alternatives and take a more proactive approach to reducing greenhouse gas emissions. “As a state legislator, the youngest legislator mom, and a suburban resident, I am acutely aware of Portland’s high levels of diesel pollution and the disproportionate effects that unhealthy air has on our most vulnerable citizens,” states the letter. “… I am daily reminded that our planet has 12 years to halt emissions and curb the worst of the coming effects of climate change.”
In stark contrast to State Senator Lew Frederick, Rep. Power sees a direct connection between climate change and this plan to expand a freeway and add driving in our central city. “If 121,400 vehicles travel through this section each day, what is an estimated reduced number of vehicles post-project, and benchmarks for success in meeting GHG reductions and reducing air quality impacts to adjacent schools and sensitive populations?” she asks. And then, referring to ODOT’s plans to build a wall between new freeway lanes and Tubman Middle School, Rep. Power says, “A wall mitigating noise impacts is surely insufficient.”
“For a project of this size, scope, and cost in such a centrally-located neighborhood, Portland deserves to get it right,” Rep. Power added.
The EA comment period end today (4/1) at 5:00 pm.
UPDATE, 2:45 pm: Sierra Club, Oregon League of Conservation Voters, Center for Sustainable Economy, and Climate Solutions have all signed onto a letter requesting a full EIS based on the EA’s lack of analysis and consideration of congestion pricing. Read the letter here.
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