Gallagher Says APA I-70 Concerns are Valid
American Planning Association Raises Numerous Concerns with CDOT Plan
Out-Dated Travel Model For I-70 Just One Problem
For Immediate Release For More Information
10/29/2014 Denis Berckefeldt
(Denver) Auditor Dennis Gallagher says an American Planning Association (APA) White Paper’s concerns regarding the Colorado Department of Transportation (CDOT) I-70 reconstruction proposal are valid and troubling. The White Paper was released October 15 by the APA.
“This respected planning group confirms everything I have been saying about the numerous flaws in CDOT’s billion dollar boondoggle. Everything from the out-dated and flawed traffic model CDOT used to justify tripling the size of the freeway with Lexus Lanes to the serious lack of attention to social and economic justice issues in the affected neighborhoods,” Gallagher said.
The paper, produced by the Transportation Division of the APA, is the product of a site visit by transportation planning experts who visited Denver in mid-September. The experts met with staff from CDOT, City and County of Denver, Denver Regional Council of Governments, local elected-officials, members of APA’s Colorado Chapter, and residents of the Elyria and Swansea neighborhoods.
The paper makes particular note of the lack of confidence in the accuracy of the travel forecast based on the model used. It also cites confusion and inconsistency in determining which entity actually did the modeling. CDOT says the Denver Regional Council of Governments (DRCOG) did the modeling and DRCOG says CDOT. This made it difficult to assess the viability of the modeling process.
The paper does state that it was an old, out-dated travel demand model and an old future land use forecast; that the latest and best modeling practices were not used including DRCOG’s newest state-of-the-art travel demand model called ‘Focus’. Nor did they use DRCOG’s new UrbanSim model, rather they relied on out-of-date travel demand software that cannot factor in highway-induced development.
“This is outrageous. CDOT plans to spend a billion dollars to expand a freeway and disrupt hundreds of lives without using the most up-to-date information and modeling tools available. As I have said before, they would be better off using a Ouija board,” Gallagher said.
The paper also notes that the neighborhoods, Elyria and Swansea are ‘settled urban environments’ and that the highway project needs to adapt to that context, not the other way around: the neighborhoods should not have to adapt to and expanded highway. This is where the issue of economic, social and environmental justice come into play.
“These neighborhoods have suffered for the last fifty years from the original decision to route I-70 through the heart of their neighborhoods. This reconstruction cannot add to that suffering and destruction. Widening this highway will do just that and cannot be allowed to happen. We already know from Denver’s Department of Environmental Health Assessment of these neighborhoods the serious health consequences these people are suffering as a result to I-70. CDOT’s proposal will make that worse. If it goes forward as planned, I guarantee you there will be lawsuits and CDOT can spend even more of the taxpayer’s money, unnecessarily.” Gallagher said.
Below are eight key points from the White Paper. A link to the paper itself.
EIGHT KEY POINTS
# 1: Transportation System Planning
- Lack of a common understanding of the Denver region’s transportation system as a whole, and the specific role of I-70 within that system.
- Lack of a system planning approach; not comprehensive or integrated. Does not address relationship to non-interstate part of the network, such as (a) parallel and connecting roadway network (including I-270 and I-76), (b) existing and emerging transit network, (c) the local street network, and (d) non-automobile transportation modes.
- Transit is virtually missing and other aspects of mobility and accessibility that would not require additional lanes – thus enabling a narrower interstate footprint in the environmental justice neighborhoods.
- Lack of a system-wide and corridor level strategy for reducing vehicle miles traveled. No goals set to create a better mode share to reduce driving alone, and again resulting in not needing to provide additional lanes.
- Lack of application of transportation demand management programs (including ridesharing, shuttle circulators, and parking management).
- Lack of evaluation of evolving land uses over the next 30-years; does not address more compact urban development and transit-oriented that is less reliant on automobile travel
- Unclear whether the I-70 alternative is fully consistent with the DRCOG Regional Plan; these need to be reconnected and considered within the system as a whole
- What is needed is a system understanding of the entire regional network with all modes, and how the I-70 corridor, with its tandem facilities, functions as part of that system.
# 2: Travel Demand Modeling
- Lack of confidence that the model provides reasonably accurate forecast. CDOT refers to DRCOG. DRCOG refers to CDOT.
- CDOT and Atkins have been using an old travel demand model and an old future land use forecast.
- CDOT and Atkins have not kept pace with best modeling practices. They are not using DRCOG’s newest state-of-the- art travel demand model called “Focus.” Nor are they using DRCOG’s new UrbanSim model. Instead Atkins is using an out-of-date travel demand model software that cannot factor in highway-induced development.
- Did not test a full range of highway project alternatives. Did not test an alternative going from the current 6-lanes to 8-lanes. Did not test an alternative with frontage roads not immediately adjacent. (8-lane alternative would have sufficient capacity and eliminate some of the severe impacts on the community.) Given location in environmental justice neighborhoods, the cross-section needs to aspire to absolute “minimum widths” to minimize impacts.
- The result is an alternative that is wider than a football field is long. CDOT’s alternative maximizes impacts on the environmental justice neighborhoods of Elyria and Swansea rather than minimizing impacts.
# 3: Managed Lanes
- CDOT is considering a pricing concept for I-70 – managed lanes – which is one among the many possible concepts for addressing user fees.
- The managed lanes aspect ofCDOT’s proposal is not well understood by elected-officials or members of the community. CDOT needs to explain how its particular managed lanes concept would function in the I-70 corridor.
- Again, CDOT and its partners need to address pricing for the entire system in metro Denver, connected with regional and local transit, to enable better-informed decisions regarding lane configurations, termination points, and access along the I-70 East segment.
# 4: Community and Economic Development
- Efforts are in place to develop community and economic development plans along with the I-70 East Project, particularly through the North Denver Cornerstone Collaborative.
- The neighborhoods of Elyria and Swansea have stated a need to establish and re-establish connectivity. These investments should be decided upon in advance of any I-70 constructing.
- To minimize disruption in Elyria and Swansea, it may make sense to make invest in the I-270 project first, prior to construction any construction in the I-70 corridor.
- Recommend a “good-neighbor compact” with local businesses and trucking companies to clamp down on “cut-through” travel on residential streets.
# 5: Constructability and Construction Impacts
- Impacts during construction on the current alignment – regardless of final alternative – will include dust, noise, vibration, disruption of circulation, diversion of traffic.
- Permanent impacts include removal of families and major adjustments at Swansea School
# 5: Vasquez/Steele Street
- Relocating the partial Vasquez interchange a half a mile to the east at Colorado Boulevard.
- The property currently used for the interchange is a significant area for redevelopment – including mixed-income housing, neighborhood serving retail (perhaps the grocery store the neighborhood desires), and community and/or civic uses. The area may also accommodate a relocated elementary school.
- Recommendation that an integrated context-sensitive freight system plan be developed – that would address routing of truck traffic out of adjacent residential areas. An area wide freight system plan would be the appropriate mechanism for addressing mobility and routing issues of neighboring jurisdictions, including Commerce City.
# 7: Mobility During Construction
- CDOT needs to develop an advance comprehensive package of mobility-related projects. Improvements to I-270 first make sense in advance of any construction on I-70. The package should include neighborhood circulation issues as well, including multimodal accessibility and connectivity enhancements within and between the environmental justice neighborhoods of Elyria and Swansea.
# 8: Community Engagement
- Community leaders criticize CDOT’s community engagement process. A more robust process is possible where everyone hears both questions and responses – in order to build consensus within the community.
- Example of the I-15/SR-15 (40th Street) in San Diego. A preferred option was selected that minimized community impacts, while improving function on that component of the regional transportation system. Specific community improvements were agreed to – including s covers at several key locations along the alignment. The project included linkages to regional transit (existing and planned)and access to transit stations within the highway at major boulevards.
The American Planning Association is an independent, not-for-profit educational organization that provides leadership in the development of vital communities. We measure our success by the successes of our members and the communities they serve. Information on APA is available at: https://www.planning.org/aboutapa/