Sunday, December 20th, 2009
In order to implement any sort of major capital project that involves the use of federal funds, cities and states have to conduct an Environmental Impact Statement first. One of the things that is done as the first stage of this is to create something called a “Purpose and Need Statement”. Few people really know or care what an EIS is, and even fewer recognize the importance of the Purpose and Need Statement. Any alternatives that are proposed for the project are to be judged by how well they meet the purpose and need of the project. So if your Purpose and Need Statement only talks about, for example, reducing highway congestion, it is an almost sure bet that some sort of highway widening alternative will be proposed. In effect, you can telegraph the solution simply by correctly defining the Purpose and Need, which is why it is so important to make sure that broader community goals, objectives, and aspirations are included in it. They seldom are.
I want to highlight one particular EIS Purpose and Need for illustrative purposes. That is the one for the US 31 corridor in Hamilton County, Indiana. The purpose and need of the project was three fold:
- 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
- Provide for the reliable and efficient movement of commerce and regional travel
This is a pretty standard list. It should come as no surprise reading it that the EIS recommended widening and upgrading it to a freeway. If your purpose and need is “driving nails”, it’s no shock when the outcome is “buy a hammer”. Now, I happen to support this project since it is clearly needed. But the narrow scope of the EIS has important consequences. For example, US 31 is a huge barrier dividing the town in two. The project should have had as one of its purposes “Reducing physical barriers between communities”. Because it was not, unsurprisingly many of the things that would have done that were either not included or deemed not cost effective. For example, there are actually no specifics at all around pedestrian or bicycle facilities.
I don’t want to belabor this particular EIS since I already wrote an in depth review of it. Rather, I want to home in on this idea of safety.
Is US 31 dangerous? The EIS notes that “nine of ten segments along US 31 have had overall collision rates higher than the Statewide average rate for similar facilities.” Seems like there might be a problem. But is there?
Keeping in mind Garrison Keillor’s quip about Lake Wobegon being a place where “all the children are above average”, by definition 50% of all roads will have crash rates above the average. This will be true no matter how many road improvements we make. We could reduce crash rates across the board by 90% and half of road segments will still be more dangerous than average.
What this does is build in a bias for road improvements to address safety issues. This particular EIS did not even attempt to compare crash rates against a target level for this type of facility or any other type of metric of what should be expected apart from comparison to the average. For any road with a crash rate above the average (which is by definition half of them), “improving safety” is an all purpose rationale for highway investment. It’s a bogeyman that can be used to scare us into projects.
Of course it almost goes without saying that the only safety measure the EIS authors bother to discuss was that for motorists. The Purpose and Need Statement literally says that the only safety purpose is improving it “for motorists”. I copied those bullets directly from the document.
In fact, I doubt that there were many injuries or deaths among pedestrians or bicyclists. That’s because this 4-6 divided mega-highway is so manifestly unfriendly and unsafe to anyone not in a car, few others would dare to even try to so much as cross it. This condition, naturally, was not viewed as a deficiency in the Purpose and Need Statement. It shows the subtle ways that even generic, seemingly unobjectionable statements bias the outcomes.
Again, I support a healthy investment in highways and even the particular project in question (presuming they get the pedestrian/bicycle parts in during design). I just think we need to take a hard look at how these projects are justified. I’d be surprised if some standards on crash rates didn’t exist. If not, they could easily be created. Possibly they could be benchmarked to averages, with targeted declines over time. To justify a road improvement by using “safety” as a rationale would require a specific level of deviation from the target, not merely an appeal to being less safe than average.
Possibly there are some guidelines to this effect today, but if so, they would appear to be more honored in the breach. This notion that improvements in highways are justified due to merely being below average in safety and not with regards to some objective deficiency should be revisited.