Sunday, June 15th, 2008

Review: US 31 Supplemental Draft Environmental Impact Statement

The study team evaluating the US 31 corridor in Hamilton County has unveiled their supplemental draft environmental impact statement. This document includes the preferred alternative, and updated background and environmental impact statement.

Looking at this, it is hard to argue with the proposed alternative from a transportation engineering perspective. It basically accomplishes all of the goals that were laid out, and will address the needs of the motoring public well into the future. While I’ve got a few suggested design tweaks, the proposed six lane freeway is a very good solution to the transportation challenges in the area. On that basis alone I would give it an A-.

But something is missing. I was a bit troubled in reading the document to see just how highway oriented it was. The purpose of an environmental impact statement is to understand how to solve major problems in a way that provides the best mix of benefits and costs, dollars and otherwise, considering the community in its totality, not just one dimension of the equation. This document takes a highway centric approach, treating the various federally mandated environmental impacts as a checklist to proceed through rather than as an opportunity to truly consider what could be done in this corridor.

I’m not a fan of lots of regulations. Nor are many of the government agencies that are responsible for implementing road projects. When you read this document and see just how many impacts you are legally required to consider – ranging from noise to wetlands to farmland to parks impacts to environmental justice – you can’t help but wonder if we are putting ourselves at a disadvantage globally by burying our communities in red tape. And of course it is very clear that many of these were put forward by anti-highway groups who were able to have much greater success at the federal level than at the state or local. The raison d’etre of federal highway funding is to a great extent adding red tape. They give you back your own money – well, in Indiana’s case, some of it – with many encumbrances added.

But then you see a study like this, where it is clear that the consultants intended merely to stick to the letter of the law, and it is obvious where increased federal regulation comes from. I’ll go through the details momentarily, but to cite one example, the SDEIS basically punts on pedestrian and bicycle access, saying, in effect, we’ll figure that one out later. When such a core component of a project is simply not acted on, it should come as no surprise that there is a movement afoot in Congress to mandate “Complete Streets” for all federally funded projects. Perhaps to some extent we end up with the regulation we deserve.

The basic proposal is a good one: US 31 would be upgraded on more or less its currently alignment to a six lane freeway with fully controlled access. There would be interchanges at I-465, 106th St, 116th St., Old Meridian (NB offramp only), 131st St, 136th St., Keystone/146th St/151st St., 161st St., SR 32, 191st St., and SR 38. Major cross streets such as 111th will cross over or under US 31. Others such as 103rd St. will be closed and cul-de-saced. The projected price tag is $483 million, of which $353 million is for construction and $130 million is for land acquisition. There is no breakdown as to where the money goes by segment.

Any way you slice it, this is a major investment in Hamilton County’s transportation infrastructure and will do wonders for the entire corridor.

I’ll review some aspects of the report in detail, then go through the various interchange proposals.

1. Purpose and Need Statement. One of those things that every EIS starts out with is something called the “Purpose and Need Statement.” This is basically the problem statement. What are you trying to do and why do you want to do it. This can seem like a minor point and usually these documents don’t raise any kind of a splash. But nothing can be further from the truth. The purpose and need statement is truly the heart and soul of the EIS process and is arguably the most important document produced. Why? Because all of the evaluated alternatives are judged by how well they satisfy this statement. In effect, by defining the problem, you are also implicitly defining the solution.

The purpose and need statement for this study is very weak. It is a simple three fold statement:

“Based on the transportation needs identified the purpose of the US 31 Improvement Project is to:
• Reduce congestion for the US 31 corridor by improving to LOS D or better;
• Improve the level of safety for motorists using the US 31 corridor; and
• Provide for the reliable and efficient movement of commerce and regional travel.”

That’s it. Now this might, on its surface, seem unobjectionable. After all, clearly the reason this study is being undertaken is to deal with the traffic congestion on US 31. But if you read it closely you see two problems.

The first is that it effectively mandates a major highway expansion by framing the problem solely in terms of moving cars. LOS on US 31 must be reduced to Level D or better, for example. If your purpose and need statement says something like, “Driving nails” don’t be surprised if the preferred alternative is something like “Buy a hammer”. If the purpose and need statement were “Provide housing and shelter to family”, an entirely different analysis would be undertaken.

That highlights the second deficiency and the most serious. By framing the problem entirely in terms of auto travel, it misses the broader context, which is really what these communities want that corridor to be like in the future. What goals and objective do they have that US 31 can help or hinder. Consider, for example, one of the stated purposes of the Keystone Ave. project, which is to help bridge the communities on either side of that road and better connect eastern and central Carmel. US 31 is arguably a greater barrier between western Carmel and central Carmel, and US 31 also bisects Westfield, but dealing with that is no where mentioned in the purpose and need statement.

With the Meridian corridor as the second largest office concentration in the state, perhaps one problem might be how to ensure the attractiveness of that corridor to businesses and workers. Or how to use US 31 to position Indianapolis, Carmel, and Westfield for the emerging 21st century globalized economy. But that’s missing too. And oddly so given that stimulating economic growth is typically touted by public officials when announcing new highways. The I-69 Indy to Evansville link has as one of its purpose items, “support local economic development initiatives”. It also includes, interestingly, “Increase personal accessibility for area residents”.

I suspect the purpose and need was framed the way it was because the freeway upgrade option is such a slam dunk and the need so obvious. But that treats the EIS as a hoop to be jumped through rather than an opportunity to engage in a discussion around what the future of the community should be. The overly narrowly focused purpose and need here also makes it extremely easy to reject items proposed by the local governments to enhance their communities because none of those are related to the purpose and need of the project. That’s why this document is so important.

If I were the EPA commissioner, I would consider rejecting this EIS because of its deficient purpose and need statement.

2. Demographics. There is no indication that the consulting team updated demographic forecasts when doing their modeling. INDOT has historically used very low population growth estimates for its studies. This can lead to underestimating traffic demand because the principal drivers of traffic growth are growth in population and employment.

The year 2025 was the planning year in the original DEIS. This included a population projection for Hamilton County of 308,300. The 2007 estimated population of Hamilton County is 261,661 people, up from 182,740 in 2000. In other words, the DEIS would have us believe that Hamilton County added 78,921 people in the seven years from 2000-2007, but is only going to add 46,639 people in the 18 years from 2007 to 2025. How likely is that? Not very.

The estimates for Washington Township are even more laughable. The DEIS says that the population of Washington Township in 2025 will be 32,500. But the Census Bureau says the population in 2006 was already 29,361. And there are north of ten thousand approved residential lots there waiting for development.

Clearly, the demographic forecast from the original DEIS was an embarrassment. Before any traffic volumetrics can be relied upon, it is critical that the consultants go back and create a real population growth forecast. Now I happen to believe that it is reasonable to assume growth will tail off in the out years as the area builds out, but any forecast that assumes that growth is going to fall off a cliff is simply not credible.

As an editorial point, I have yet to see an INDOT study that included what I would consider a good population growth forecast. This is one of the most important areas for that agency to address in order to make sure that their studies are underpinned by reliable data.

3. Safety. US 31 is considered to be in need of improvement because it has a crash rate that is above the statewide average. This is a nationally widespread way to look at safety needs, but I find it flawed. The problem is that about half of all roads are going to perpetually be above the statewide average. That’s the nature of having an average calculation. So no matter how many safety improvements are made in our roads, half of them will perpetually be deemed in need of still more improvements.

A better way is to set some sort of safety benchmark that is periodically reviewed in light of current vehicle trends, etc. as to what is deemed the target crash rate or rates. You then judge the safety need against a standard, not against a nebulous average target. Care should be taken not to let this morph into an EPA like tightening for the sake of tightening approach designed to perpetually maintain a sense among the public that our roads are unsafe.

4. ROW. The projected ROW required for the highway actually appears to be greater in this iteration than in the original DEIS. There are more relocations in almost every category. This was a big driver of claimed benefits by Carmel and Westfield as to why roundabout interchanges should be used. Yet while the number of relocations is up, and a good chunk of the commercial space in Westfield north of 146th is being taken out, none of the nightmare scenarios floated by local government regarding $750 million project price tags or the decimation of Westfield’s tax base is coming to pass. The ROW cost is clearly high, since this is just about the most expensive real estate in Indiana, but doesn’t seem to blow the budget. The cost estimates provided are not that radically different from previous iterations.

5. Roundabout interchanges. There are only roundabout interchanges proposed at two locations: 131st St. and 136th St. This will no doubt disappoint Westfield, especially as some of their interchanges such as 191st St. are supposed to be unsignalized diamonds that would appear to have no real barrier to using roundabouts.

I’m not sure roundabout interchanges were properly evaluated. There isn’t a lot of detail on the evaluation process, but if I go back to the CAC presentations, I note that the interchange type comparison grids contain a long and impressive looking list of criteria, but do not appear to include any of the criteria that would hit the sweet spot for roundabouts. Consider the case of 191st St. The consultants looked at items such as the volume of fill required, the commercial viability of the parcels, and adaptability to future widening of 191st St. They did not, however, consider any of the following as criteria, at least not that I have been able to determine:

  • Electricity utilization (roundabouts don’t use traffic signals)
  • Ability to fully function during power outages
  • Safety benefits from elimination of head on and right angle collisions. (The SDEIS cites “hundreds” of right angle collision in the corridor)
  • Environmental benefits of eliminating stops at off-peak periods

Supposedly the preferred alternative is not set in stone as to interchange types. A recent Indy Star article says INDOT is hiring an international expert in roundabout interchanges, and is looking at evaluating them for 106th and 116th St. at a minimum.

I do find it interesting that after significant local support for roundabout interchanges, only two made it to the preferred alternative.

6. Peak vs. Non-Peak Traffic. Again, this is widespread practice and isn’t limited to this study, but almost all of the traffic analysis and design is focused around peak periods. But designing for the peak of the peak is costly, and the resulting infrastructure goes underutilized most of the time. For example, a signalized intersection might operate most efficiently between 5:00 and 5:30 when offices let out. But the other 23:30 those traffic signals reduce efficiency versus a roundabout, wasting gas and time. Does the aggregate time and fuel saved at the peak outweigh that lost off-peak? I don’t know, but it would be an interesting analysis.

For toll roads, there is a clear path for how to address this: congestion pricing. By setting prices higher at the peak of the peak, you encourage traffic to spread out during rush periods, reducing congestion and the need for facilities. You slash prices to the bone over night and at lower traffic periods to try to encourage trips at those times to make best use of the facilities. It is harder on a free road, which is one reason that tolling fully controlled access roads makes sense because it enables more efficient infrastructure utilization.

7. Economic impacts. Again, I’ll note the shortcut that the consultants took by not fully examining the economic impacts of the new roadway. What I found very interesting is that while the typical highway study touts all the jobs that will be created, this one focused on how much taxable property will be removed from the local rolls as a result of the corridor. In effect, the SDEIS treats the upgraded roadways as having a negative economic impact. It basically says that the entire corridor is going to be built out with high quality uses regardless of the highway, so the highway itself can’t be seen as adding to the economic attractiveness of the area.

Again, I suspect that the user and safety benefits of the road are so high that there was no need to try to justify it on any other basis. It is where the road project itself is dubious that you so often see consultants engage in contortions to try to come up with impressive job creation figures. But it does show another example of short changing the analysis and treating the EIS process as a hoop to jump through. After all the time and money spent studying this corridor, I would have expected better.

8. Pedestrian and Bicycle Access. The study does not propose any specific pedestrian or bicycle accommodations. Rather, it talks about all the various plans, mostly, I get the impression, to leave the reader with the view that they are conflicting about what to do in order to justify punting the decision to later. The previous CAC documents all propose a sidewalk or path on only one side of each crossing of US 31. It is clear from the SDEIS that sidewalks or paths of some type will be included, but there are no details.

I think this perfectly illustrates how non-automobile modes of transportation get short shrift in highway EIS documents. There is enormous detail lavished on understanding the demand for road capacity and on exactly what types of interchange to construct, but almost no analysis of pedestrian or bicycle needs, nor any details on the specific facilities to be provided. INDOT would not consider calling a DEIS complete without the details of the interchange types worked out. There should be similar attention to the other aspects of the roadway. This was a major miss.

9. Missing Pages. The traffic analysis section was missing all of the odd pages. And the location capacity map attachments appear to be missing all the evens.

10. Preferred Alternative Summary. My previous comments might make it appear that I’m very down on the report. And in some respects I think it is not as good as it could be. However, I think the preferred alternative is more or less right on. A six lane freeway, with those interchanges and overpasses in those locations is the right answer. To restate, I believe a lot of the weaknesses of the DEIS come from the fact that the solution is so obvious, that the consultants were a bit going through the motions on some parts. Only the lack of pedestrian access specifications and the intent to provide only single-side pedestrian access appear to be major misses to me. Otherwise, build this thing as proposed and it would probably be pretty good. Adding additional roundabout interchanges, particularly at 161st and 191st. would be good as well.

11. Interchange Details. I’ll review each interchange in turn, reviewing the specific proposal with any comments I have.

I-465. The preferred alternative is the one that uses auxiliary lanes instead of braided ramps between I-465 and 106th. I think that’s probably appropriate. The cost of braided ramps is high, but I’m not sure the benefit is there. Particularly when I’ve got a suggestion that will effectively eliminate weaving. Namely, prevent access to and from 106th St. to Meridian St. south of I-465. A median barrier separating the mainline from the ramps could accomplish that.

I was very pleased to see the consultants include a slip ramp from WB I-465 directly to Pennsylvania St. This should reduce traffic exiting at 106th. There was also a discussion in the traffic analysis of building a slip ramp from EB I-465 directly to Duke’s Parkwood West development, but that isn’t shown on the maps. And for road geeks like me, there is a plan to implement a “Michigan left” setup at Meridian and 96th St.

I notice that the flyover from SB US 31 to EB I-465 is a single lane. I’m not convinced this is adequate. I also notice that it appears the Spring Mill Rd. overpass is being replaced with an underpass. (The diagrams weren’t too clear). I’d like to see the I-465 crossing on Spring Mill upgraded to four lanes between 96th St. and Illinois St. to facilitate local circulation without having to resort to using US 31.

Lastly, the traffic analysis appears to back up my contention that I-465 east of US 31 needs to have a ten lane mainline cross-section. The consultant could not achieve acceptable levels of service on an eight lane cross-section. INDOT needs to design I-465 between US 31 and I-69 as a 5+1 design, not a 4+1 or 4+2 design.

106th St. This is a diamond interchange with a bypass lane to southbound Pennsylvania at the roundabout there. The traffic analysis suggests this roundabout will not function well at peak periods.

The ramp tapers between 106th and 116th are so close together that they should be merged into a auxiliary lane.

116th St. This is a SPUI, with the intersection of 116th and Penn converted to a roundabout. However, the traffic analysis suggests this won’t function well at peak either.

Old Meridian St.. There is a slip ramp from NB US 31 to Old Meridian.

Carmel Drive. This road gets a four lane overpass, but no direct access to US 31

131 St. A roundabout interchange with the 131st. and Penn intersection converted to a roundabout.

136th St. This is an extremely confusing intersection today and it is being replaced with what is effectively a double-roundabout interchange. The main interchange is a roundabout, and the 136th/Old Meridian and 136th/Roher intersections are being converted to flanking roundabouts. It will still be confusing, no doubt, but that’s probably unavoidable in any solution.

Keytone/146th/Greyhound Pass/151st. St. This interchange is so complicated I won’t even try to explain it. But basically 146th gets full access to Keystone and US 31. There is access to Greyhound Pass and 151st. St. through a combination of direct access ramps and frontage roads. The development in this area is an unplanned disaster. There will be a large number of relocations. However, local government clearly favored greater access versus preserving structures. This accomplishes that admirably and I think it is a pretty clever design. The only movement that isn’t easily accomodated is Greyhound Pass to US 31 south, which requires a short detour of sorts.

There is an auxiliary lane between 151st and 161st.

161st St. is a traditional diamond interchange. I see no reason why this could not easily be changed to a roundabout.

SR 32 is a traditional diamond interchange with a surprisingly wide stance. US 31 is shifted slightly to west from its current alignment here.

191st St. is also a traditional diamond interchange. And US 31 is also shifted slightly west here. I see no reason this could not be easily changed to a roundabout.

SR 38 (Sheridan Rd) is a diamond interchange with the northbound onramp folded to the south side of an interchange to avoid a park. Unlike your house, properties owned by a municipality such as a park or a school are sacrosanct and can’t be relocated unless there is “no feasible alternative”. The third lane in each direction is added/dropped at each interchange.

INDOT still owes an accounting of the radical change in approach here, going from saying no interchange was needed because of low traffic volumes, to saying it would not only be an interchange, but be the first one built because of safety concerns. This is a completely reversal in only six months, so I think it would be very helpful to explain the change in thinking.

12. Mainline profile. The road is six lanes each direction, which is probably the right answer. However, there is a large grass median proposed. I believe this should be eliminated in favor a closed median with jersey barriers. There is simply no reason ever to include a grass median in an urban freeway. It wastes ROW and creates an unsafe condition in high traffic environments, even if cable barriers are installed. That narrow grass median on I-70 included as a part of the widening there by the airport is an accident waiting to happen, for example.

Full left shoulders are needed anyway, so why not just close in the median fully and save the extra ROW and resulting dollars? That’s what I would do. ROW efficiency does not appear to have been a primary motivator for the proposed design.

13. Construction staging. I have for some time advocated building the Carmel section of his highway as a two year hyperfix. Carmel built parallel, four lane collector/distributor roads on both sides of US 31. This allows those roads to handle traffic while US 31 is closed to through traffic. This can’t be done in Westfield, which lacks frontage roads. The plan goes something like this.

Pre-Construction Year Zero or earlier: Complete prep work necessary to implement project. This includes completing Illnois St. south to Spring Mill Rd., building temporary ramps, etc.

Main Construction Year One:
– Divert all traffic to Illinois St. and Pennsylanvia/Old Meridian from north of I-465 to south of 146th St. using temporary ramps
– Start I-465 interchange reconstruction
– Start Keystone/146th St./151st St. interchange reconstruction
– Reconstruct 111th St., 116th St., and 131st St.
– Rebuild portion of mainline
– 106th, 126th, and 136th remain open through construction as cross streets with no access to US 31

Main Construction Year Two:
– Complete I-465 interchange reconstruction
– Complete Keystone/146th St./151st St. reconstruction
– Reconstruct 106th St., 126th St., 136th St.
– Rebuild portion of mainline
– 111th, 116th, and 131st remain open through construction as cross streets with no access to US 31.

Post-Construction Year:
– No mainline or interchange restrictions
– Cleanup, landscaping, retaining walls, remove temporary ramps, install sidewalks and lighting, etc.

This gets a big piece of the entire project is done in only two mainline construction seasons. US 31 could re-open for the winter, or remain closed. Trucks would be re-routed to Keystone during the project apart from local deliveries. If desired, each bridge/interchange could be contracted separately, allowing Indiana contractors to compete. The project is sped up, with associated cost and motorist benefits. I even gave two years to complete the more complex interchanges.

This might be unworkable, but it’s the sort of thing I’d hope the consultants are looking at. The current lengthy construction timeline is not ideal if it can be avoided.

14. Conclusion. While I think that the SDEIS could have been better, I think on the whole this a very good design that, with some tweaks and full sidewalks on both sides of every cross street, would be a huge positive addition to Hamilton County and the entire metro region. It is a critical project needed to help position Central Indiana competitively for the decades ahead. I’ll give it an overall grade of B-.

8 Comments
Topics: Transportation
Cities: Indianapolis

8 Responses to “Review: US 31 Supplemental Draft Environmental Impact Statement”

  1. jimgrey says:

    There’s a lot here to digest, but I’d like to comment on two items that affect me, since I work at 31/Carmel Dr. and drive Spring Mill Rd. to work every day.

    While normally I decry the loss of access to a major road from a well-used intersection, in this case I’ll make an exception and say, “Hooray!” to the idea of closing access to 31 from Carmel Dr. I think my co-workers would feel similarly. That intersection is badly clogged at the usual times of day, so much that the roundabout at Illinois St. is backed up. 90% of the time, if I must take Carmel Dr., I am going into Carmel proper. The rest of the time, I avoid the intersection by following Illinois to 116th or 136th to get onto NB 31. Dropping access to 31 at Carmel Dr. will speed access to and from Carmel, and will not hinder access to 31.

    It pains me to hear you suggest a 4-lane Spring Mill Road over I-465, but I suppose it is inevitable. Spring Mill Road’s charm is that it feels like a country road. The redbud was spectacular along the stretch from just over the overpass north to about 111th this year. (I took a couple photos for my blog.)

    Spring Mill is an old road, there long before Meridian St. extended north over the canal. I’ve seen an 1855 plat map that showed it. There’s enough of a preservationist in me to say that its country charm should not be further disturbed. But I can also foresee a time when, charming or not, it will carry sufficient volume to warrant 4 lanes.

  2. The Urbanophile says:

    Jim, I only propose four-laning Spring Mill from 96th St. to the southern terminus of Illinois St. That’s just south of 103rd. So it’s a very short distance.

  3. mordant says:

    A highway-centric proposal from INDOT? Say it ain’t so! Thanks for the very thorough analysis – you provide a wonderful public service. One thing I wondered about – is the wide ROW (grassy median) really just room to install more lanes in the future?

  4. The Urbanophile says:

    Mordant, thanks for the kind words.

    A grass median is often a source of ROW for future lane expansions. However, if that is a concern here, it would be easy enough to leave the room on the outside. I do not like grass medians in urban areas because I don’t consider them as safe as an enclosed median.

  5. Crocodileguy says:

    Personally, I feel there is a lot of improvement to be done to this project, especially the southernmost limit.

    I think the interfacing of Meridian, I-465, US-31, 96th, and 106th needs to be radically re-examined. I do like the idea of a “Michigan Left” here, but I also wonder about lateral access possibilities. What if the Spring Mill overpass were a 5-lane SPUI or 4-lane roundabout teardrop, and that provided the access to 96th St., Spring Mill, Meridian St., and Illinois St.? That would ease congestion/weaving at 96th and Meridian, and 96th is already 4-lane between Spring Mill and Meridian. Spring Mill/103rd I believe is planned as a roundabout, constructed to divert traffic to Illinois/103rd. Coupled with a Pennsylvania Pkwy. slip ramp, this seems like a fairly equitable solution to the traffic problem presented by the configuration of the present roadways.

    I also feel that since the US31 routing follows 465, southbound Meridian should be treated as an exit, with the mainlines continuing to 465.

    Another possible solution would be to pull a Keystone at 96th St. and do a grade-separated roundabout interchange here.

    Overall, though, I agree that this project receives an overall grade of B-, maybe a C+. That isn’t bad for INDOT, because I usually give them low Cs to Ds in overall execution.

  6. Anonymous says:

    Very good analysis once again, urbanophile. I agree that INDOT should complete this project using a “hyperfix” schedule. Drawing this project out over 5-6 years, which is how INDOT is proceeding with the West Side 465 project, is an absolute waste of time and money.

    What irks me is how it seems as if INDOT is doing just the absolute minimum for this project. I would have liked a higher capacity interchange at I-465 and US 31.

    And there are many roads in Hamilton and northern Marion Counties that need to be widened but since they aren’t state or federal highways, there is no money for their upgrade.

  7. The Urbanophile says:

    Firstly, while I agree that there need to be dual lane directional ramps to and from I-465 to the US 31 freeway segment, I’m not sure how much the ROW would permit, say, a design like the I-69/I-465 interchange. There are some office buildings pretty darn close to the roadway.

    The Spring Mill idea is very similar to what I had in mind.

    Anon, in fact it has been the local roads in Hamilton County that have received the most improvements: Old Meridian, 116th St. 146th St., Hazeldell Parkway, etc, etc. etc. Those communities have used their own money to quickly get projects done while the state frankly did little. Marion County, which is nearly broke, is a different county. Major Moves is really changing the game from an INDOT perspective, of course, but this represents the first significant investment by the state in Indiana’s fastest growing region in 15-20 years.

  8. Anonymous says:

    I realize Hamilton County has funded several road upgrades in recent years, but they still have a long way to go to have a road network that adequately meets the ever increasing traffic.

    Yes this project is important and it is good that it is being done but remember, it won’t start for THREE years. This is a project that needed to be finished last year, not 10 years in the future.

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