10 Reasons to Not Trust ODOT’s Environmental Claims


We know that transportation is the largest source of greenhouse gas emissions in the U.S., and that our car-dependent transportation system is the reason Americans drive so much more and consequently produce far more greenhouse gases per capita than residents of other wealthy countries. Scientists have shown that building more and wider roads stimulates more driving, longer trips, and more decentralized land use patterns, reinforcing car dependence.

With this entire vicious cycle well-documented, it’s hard to imagine anyone arguing that a widened urban freeway would be good for the environment, but for state DOTs and their paid apologists, it’s a frequent claim. They’ve created trumped-up projections that claim traffic and pollution will be greater if we don’t build freeways. These are false claims, and today we take a close look at how this plays out in one egregious, if typical, project.

For years at City Observatory, we’ve been following the Oregon Department of Transportation’s (ODOT’s) proposed I-5 Rose Quarter freeway widening project. The project would widen a mile-and-a-half long stretch of Interstate 5 in downtown Portland at that has recently ballooned to $1.2 billion.

A key part of the agency’s argument is that this freeway-widening project—exactly unlike every other one that has ever been undertaken—will have essentially no impact on air pollution or greenhouse gases. They make the fanciful claim in their Environmental Assessment that the not widening the freeway (the “no-build” option) will somehow produce more pollution than the eight- or 10-lane freeway their plans show they’re really intending to build. In this article, we’ll sketch out ODOT’s claims and present a 10-point rebuttal to them.

A Long List of False Environmental Claims from Oregon DOT

Recently, a Portlander interested in the project contacted us, asking us to comment on ODOT’s Environmental Assessment, which makes these claims:

Traffic operations would improve on I-5 in both the AM and PM time periods, . . . Conditions for pedestrians and bicyclists would improve from increased travel route options, improved ramp terminal intersections, physical separation from motorized users, and reduced complexity of intersections. Overall, the Regional Travel Demand Model results did not indicate trip increases on I-5 much beyond the Project limits (i.e., no induced demand). The 5 to 14 percent trip increase on I-5 within the Project Area is expected for an auxiliary lane project intended to improve flow between entrance ramps and exit ramps and is indicative of primarily local through-traffic. While consideration of greenhouse gas emissions and the effects of climate change has not been a NEPA requirement for EAs and EISs since the Council on Environmental Quality (CEQ) withdrew its previous guidance on April 5, 2017, ODOT included an analysis of climate change in the Project EA due to the high level of agency and stakeholder interest in these issues. As reported in Section 3.5 of the EA, the 2045 operational greenhouse gas emission total for the Build Alternative is projected to decrease by approximately 22 percent compared to the 2017 emission total due to federal, state, and local efforts to develop more stringent fuel economy standards and vehicle inspection and maintenance programs and the transition to cleaner low carbon fuels for motor vehicles. These trends are expected to continue over the life of the Build Alternative. The Build Alternative would contribute to this reduction due to higher speeds, less stop-and-go traffic, and less idling on I-5. Therefore, no mitigation is proposed.

Ten Reasons Not to Believe Oregon DOT’s False Claims

There is so much that is false and misleading about these claims about traffic, air pollution, and greenhouse gases that it’s difficult to know where to begin. We’ve written about all these phony claims at City Observatory. Here are 10 reasons why everyone should ignore ODOT’s environmental analysis of this project.

1. Traffic projections assume that a five-mile long, 12-lane wide freeway was built just north of this project in 2015. Hidden in the Rose Quarter’s traffic forecasting is an assumption that a massive, multibillion-dollar Columbia River Crossing was built as part of the “no build”—and finished five years ago. The project is still in limbo in 2021. This inflates traffic and increases congestion in the Rose Quarter in the “no build,” and makes the “build” look better than it is.

2. ODOT concealed plans that show it is widening the I-5 roadway enough to accommodate eight or 10 lanes of traffic. Two years after ODOT published the environmental assessment, we uncovered true plans for a 160-foot roadway. But its traffic modeling assumes that the freeway is expanded only from four to six lanes. Modeling an eight- or 10-lane road would show much more traffic and pollution.

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