Thursday, January 21st, 2010

You Can’t Fight the State DOT – Or Can You?

It seems to be remarkably difficult for citizens to influence the decisions of major transportation agencies. I use the example of a state DOT here, but it could be a transit agency. How might one go about doing this effectively? There are two major parts: political and technical.

Political Organizing

The political side is about basic organizing and making sure that the state, the public, and the press perceive you as representing an important public constituency. If you don’t represent a constituency, even if it is just a group of angry neighbors, you won’t be taken seriously no matter how good your argument.

Back in the 1990′s I used to frequently submit feedback during public comment periods for proposed highway projects. Never once did the state DOT ever include more than a boilerplate response. And never once did they change a single aspect of the project. If you are just a lone campaigner for change, save yourself some grief and forget about tackling the agency until you first do some organizing.

Political organizing has been written about extensively. Since I won’t profess to be an expert on it, I’ll leave that as a research project for you. It’s all about making it painful for the politicians and agencies to ignore your demands.

Technical Analysis

The other side is being able to technically analyze and critique DOT plans. This is frankly quite difficult for the novice. Highway planning and design is carried out by professional engineers who are trained, experienced, and licensed to practice their field. Their recommendations come from computer models, standards, and professional expertise that the layman is not always able to understand, much less counter.

I have found most engineers to be very competent in their trade. I’ve never met one I thought was stupid. On the other hand, there are a few things to keep in mind. Most of these engineers are junior people, either civil servants or consultants, who are at the mercy of direction from their bosses. While they would not design an unsafe bridge to please a political appointee, they clearly know which way the wind is blowing. Most highway projects have some sort of powerful political backing or else they’d never have made it to the top of list, so why would these people stick their low paid necks out?

Also, there is never just one solution. The wide variety of bridge designs in use provides ample visual evidence. And, engineers are very likely to weigh the considerations most relevant to them ahead of broader community concerns that are often not their area of expertise.

I happen to think there is plenty of scope to disagree with engineering led recommendations that don’t involve questioning the professional judgment, motives, or intelligence of the engineer. All it takes is a willingness to read some overly-long, dry documents with a skeptical eye. I will share some of techniques I use to analyze these plans in the hopes that you find them useful.

Some things are just obvious. If there aren’t sidewalks, it doesn’t take a genius to figure that out. But other times the project just doesn’t seem right for some reason. I operate on the principle of where there’s smoke, there’s fire. Here are some techniques to find out if that’s the case.

A: Question the Assumptions

The first thing I do is look at the assumptions of the project. The first one is the set of goals for the project. As I noted before, especially for major environmental studies, the purpose and need statement is of vital importance. Defining the problem lets you to a great extent define the solution. And the problems to be solved can definitely be questioned. Ask yourself if the problems only relate to cars, for example? Are there other potential considerations or community goals that should be taken into account?

B: Look for Obviously Incorrect Data and Trends

Capacity of roads is driven by demand. Demand is typically based on demographic and employment forecasts and some shockingly simple assumptions, such as that volumes will grow x% per year.

The first thing to do is plot out the population, job growth, and traffic growth forecasts and compare them to the previous years’ actual figures. I usually go back a decade. If the future forecast is materially different from the past, that’s a red flag. Then you’ve got the right to ask them to defend that. Even if it came from a computer program, remember the fundamental rule: garbage in, garbage out.

The last decade actually saw limited traffic growth. For example, opponents of a second downtown bridge and major interchange complex on the Louisville riverfront there have said that traffic didn’t increase at all on the existing bridge in the last ten years. Why do they think the next ten will be different? Consultants might mention two recessions and an oil price spike. But do we think this is the last recession we’ll ever have? Or that oil will never spike again? Seems dubious.

I also like to compare future forecasts against standard sources like the Census Bureau. What does the study say about population and what does the Census Bureau say?

In Indiana, I’ve long noticed that transportation planners use population forecast that are often materially in error.

Here’s one example. Consider the Indianapolis Regional 2030 Transportation Plan. If you go to page 45, you’ll see that they estimate the 2010 population of Hamilton County at 238,200. But if you click over the Census Bureau, you’ll see that in 2008 the estimated population of Hamilton County was already 269,800. Oops.

I picked this example to be charitable since they admit in the text of the document that their forecasts materially deviate from the Census Bureau. So they relied on an old 2005 forecast – which is still dubious since according to the Census Bureau, Hamilton County had already passed that estimated 2010 population in 2005.

If you look at the document you’ll find many impressive graphs and tables about population. But that doesn’t mean they are right.

Demographic and employment forecasts are the most import input into future projections. If this baseline data is wrong, then everything that comes after it is more or less invalid.

If you want employment data, you should visit the Bureau of Labor Statistics. Or conveniently the University of Georgia has this handy web site for querying jobs by county.

C: Look for Conflicting Data

Sometimes engineers let the most interesting information slip when it doesn’t affect their own project. So I like to get studies from multiple adjacent projects and compare their data to see if they foot.

I’ll use as the example for this one I-465 in the northeast corridor of Indianapolis. I’ll probably take some flack for this from some people because I actually want to make a road wider. INDOT’s preferred cross-section for I-465 is four lanes each direction with an auxiliary lane between interchanges. This is often presented as “ten lanes” which I think is a bit misleading since the existing interstate is six lanes – three each direction w/o an auxiliary lane. This implies a 66% percentage increase in capacity when the reality is that mainline capacity is only increasing 33% – the absolute minimum possible amount of widening.

My simple logic here is that since six lanes is not enough today, why would anyone believe that eight lanes will be enough 20-30 years from now? Particularly after the interchanges are all upgraded to channel traffic onto the road faster. I think that in the high growth northeast corridor, five through lanes in each direction is more appropriate.

INDOT apparently disagrees. However, their own data contradicts backs me up. First, the a recent northeast corridor study they did shows that six lanes (five through lanes plus an auxiliary) are needed south of I-69, on one end of the project. But since INDOT thoughtfully constructed an overhead bridge with only four lanes of clearance (56th St) in a newly reconstructed interchange just south of here that would cost in excess of $100 million to replace, this isn’t possible to build. Makes me wonder why they didn’t know the number of lanes that would be needed when that segment to the south was widened just a short time ago in a separate project…

Also, those traffic figures in a separate study of US 31 on the other end of the project show that five through lanes are needed on that side of the project as well. Again, it makes me wonder why this wasn’t the case in the project documents for I-465 itself?

There is enormous pressure exerted to keep these projects on budget and conform to preferred design typologies. Given that all the numbers are produced from various estimated input parameters and assumptions, it isn’t hard to imagine that data might be tweaked to tilt the outcome one way or another, particularly when there is no one precise “right” answer.

This example might not be your cup of tea, but this technique of comparing studies to see how they match each other is very useful.

D: Don’t Accept a Handwave For an Answer

The handwave technique is when officials use the logical fallacy of an appeal to authority to dismiss a suggestion. My favorite version is “Standards say…” or the “Feds require us….” Few of these stand up under scrutiny in and of themselves.

There are standards and requirements that exist for good reason. However, these aren’t always right in the context of a particular design solution, thus there is a design exception process you can go through when appropriate. There are criteria around this, but there’s a great deal of judgment involved too.

What I like to do in these situations is find examples, preferably by the same agency, where they have made an exception to the standard. Here are some examples:

1. Can’t build below the water table. During the US 31 EIS in Hamilton County, Indiana, local governments wanted to depress US 31 under cross streets rather than use overpasses to minimize the barrier of the freeway. At a report of a public hearing, I was very curious to see that an FHWA official said that depressing the road below the water table wouldn’t be allowed.

Now, I don’t think doing so would be a good idea for many reasons, but is it really against the rules? The Big Dig in Boston includes tunnels that are literally under water. How did they get approval for that? The Ohio River Bridges project in Louisville also includes a tunnel approach in close proximity to the Ohio River that I strongly suggest is below the water table.

2. Interchange Spacing. There are rules that say you need to have a minimum of one mile interchange spacing on freeways in urban areas and three miles in rural areas. Engineers prefer fewer interchanges since merging traffic impedes traffic flow. This can lead to cases where the interstate basically doesn’t serve the neighborhoods it passes through.

One example was again an article I read some years back about the proposed long range transportation plan for the Lafayette area. Some people wanted an additional I-65 interchange, but were told it wouldn’t be allowed for spacing concerns. But shortly before that hearing, INDOT opened a new interchange on I-65 at County Line Rd. in Indianapolis that failed to meet the spacing rule.

3. Lane Widths. Again, lanes are supposed to be 12 feet wide to accommodate heavy trucks. But exceptions can be made. I don’t know what the final design ended up as, but preliminary designs for Pendleton Pike in Indianapolis included outside lanes of 12 feet but inside lanes of 11 feet. Sounds like a good compromise to me.

I won’t suggest that standards are always wrong. There may be very good reasons why the designers want to do things they way they do. But they need to defend their decisions on the merits, not on an appeal to standards that are not absolute and which they themselves would seek an exception from if they thought it appropriate to do so.

E: Look for Laziness

Sometimes you notice things indicate a lack of attention to detail. Let’s face it, we’re all guilty of this from time to time.

Here’s one of my favorites. The Supplemental Environmental Impact Statement for the US 31 Hamilton County project is available online. If you scroll down to Appendix B, you’ll see that they only include the odd numbered pages in the capacity analysis! Obviously not many people read this far.

F: Find Examples of What You Want

If there is a particular solution you would like to see implemented, it is always helpful to find examples of where it has been done elsewhere. This can help cut the legs out from underneath objections. Engineers prefer the tried and true. There’s nothing per se wrong with this, but it can make it difficult to gain acceptance for new ideas in a particular jurisdiction.

Just one example. When Carmel, Indiana wanted to build roundabout interchanges on a highway they were taking over from the state, they researched where similar interchanges had been used successfully in Europe. They even hired a engineer from the UK to consult with the onshore engineering team to give them confidence they were going the right direction. The result has been a collection of the best interchanges ever built in Indiana.

Engineers Are People Too

Remember that planners and engineers are people too. They’ve got jobs with the same sort of pressures we do, and have to do a balancing act between conflicting demands like everybody else. I’m confident no engineer would ever deliberately certify an unsafe design. But beyond that, there is plenty of room for judgment. Theirs should certainly be respected, but that doesn’t mean a different perspective isn’t valid as well.

Also remember that the people at public hearings are often not the top dog decision makers. Sort of like airline ticket counter personnel and gate agents, they are there to deal with an often unhappy public. Try to remember that and treat them like you would want to be treated in the same situation. While they might not always agree with us, let’s make sure we take the high road in our personal dealings with them.

To see one example of how I analyzed a transportation study, see my post on that US 31 Supplemental Draft Environmental Impact Statement.

Topics: Transportation

21 Responses to “You Can’t Fight the State DOT – Or Can You?”

  1. Curt says:

    Nice post Aaron. I feel like I learn something new every day when I browse your page. Some of your points seem like they should be common sense to the detail oriented people but as you point out, sometimes questioning the answers is needed.


  2. cdc guy says:

    I’m qualified to pick on exactly one of your embedded points, regarding the water table.

    Technical point: below water table and under water bodies are two different kinds of “underwater” construction. I’ll deal with only “below water table” here.

    In your specific examples, going below the water table in a flat plain (such as Carmel) doesn’t allow any natural drainage of seeping water. The only ways to deal with that kind of groundwater infiltration: (1) drain to something deeper, and then (2) pump the water to a natural drain (i.e. storm sewer).

    Ethically, I have a problem with that approach, as it treats potential drinking water as waste instead of resource. (I’ve said that before.)

    From an engineering point of view, it’s costly in several ways: (1) higher first cost (of excavation, sump creation, and wall-sealing), and (2) higher ongoing cost of pumping.
    Here cost and proper treatment of groundwater align.

    Now let’s examine tunnelling through the Ohio River bank/escarpment. The tunnel would in all likelihood be a downhill one toward the river bridge. It would end into the Ohio River drainage. Thus, any groundwater infiltration would be channelled into gutters along the roadway and drained naturally into the river. (There’s an example of this in Wheeling, WV on I-70: tunnel, then bridge over the Ohio.)

    The ethical objection is still there, but the engineering costs associated with disposal are much lower since the water flows downhill without pumping. The incremental cost of dealing with groundwater infiltration is minimal, so this solution makes wasting groundwater a good economical decision as long as water is plentiful and cheap.

    And at the risk of being Johnny one-note (or maybe three-chord), water isn’t really plentiful and cheap…that’s an illusion. In the Carmel case, they did the right thing for their long-term water supply by trading down to a less-than-perfect road design.

  3. cdc, as I noted myself, there are many reasons not to build below the water table. I’d rather see people address it the way you did rather than trot out an FWHA official to say it’s not allowed. (Admittedly, I’m relying on a press report of an event I did not attend).

  4. Alon Levy says:

    Thanks for the list. I’m more interested in transit projects than in highway projects, but often the boilerplate responses and the insistence that certain things that are common abroad just can’t be done are just as frustrating.

  5. carphobe says:

    Whatever your arguments, no matter how good, INDOT can and will blow you off. Their only obligation is to respond to your comment.

    I must admit, I am generally surprised at your desire for more highways, when you are so well educated on urban transit (Chicago, for example). Do you believe we should make Indianapolis even more car-friendly…more highway dependent? Given the social inequities in Indy and when spending limited transportation dollars, do you really think Indy needs the balance to go toward more roads?

    Your bit on Barcelona shows a dense city with great transit and without the disbenefits of surface lots, for example. Should we not be moving toward that?

    Are you being inconsistent yourself when you state that VMT growth has been flat and future oil prices could be high, but yet claim that 8 lanes won’t be enough in 20-30 years? Are you also a denier of peak oil projections and/or future Carbon emission limits?

    Do you really prefer cities that have focused on making things good for cars over cities that have attempted to make it good for people (walk/bike/transit)? Which is your preferred urban form? I can’t imagine you prefer LA, Atlanta, or Houston to San Francisco, Portland or Barcelona?

  6. thundermutt says:

    carphobe, poor people in Indy aspire to the suburban dream (own cars, houses, big-screen TVs and get out of the city).

    In my experience, most of the people clamoring for extensive investment in transit could be categorized as “white, above median income creative-class people.”

    There are a lot of minds to change, and preachy screeds about the European example and peak oil won’t do it. Space around us…lack of density…is part of the American DNA. So is “show me”. Meaningful change in living style won’t come from master plans and planning, but a little at a time in response to significant economic change.

    How many people moved back into town from Fishers when $4 gas happened in 2008? How many rode the bus?

  7. carphobe, I don’t consider transit and highways good substitutes. A city like Indianapolis that is adding population at a rate of 250,000 per decade or so needs to expand its highway infrastructure. Remember, most of the freeways are unchanged since they were designed over 40 years ago.

    I also support transit and densification in the urban core. I think it is very important. But that’s only a portion of the metro area.

  8. Eric says:

    What would we do without the Urbanophile?

    Thanks for that wisdom, Aaron!

  9. carphobe says:

    If you are ok with 250K more people moving to Hamilton CO in the next decade in the usual low-density, single-use fashion, and supporting their SOV and commute preferences by building to meeting those [apparent] preferences (since driving is the only option we give them), then I suggest that you are also a suburbanophile.

    Unfortunately, highways have been substituted for transit. This is fairly well documented in LA and in Indiana. I believe there is a study that looks at what kind of highway investment would be needed if Chicago’s transit were dismantled. The land and cost investment was so extreme it was impossible to keep the building space and bring in the people (and their cars).

    At some point, just as INDOT and Daniels will have to, a limit resource prospective will need to be incorporated into our infrastructure plans. However, I love your blog. Pardon the criticism.

    Thundermutt: The people that clamer for anything are white and wealthy. They are the connected, and to them is where the money goes. Portland has an emperically proven job accessibility index than Indy for the non-wealthy. City leaders that decide to look for, listen, and concern themselves with the needs of the have-nots, have less have-nots. Let’s not use aspirations as an excuse to throw our dollars at the haves….because eventually, that’s where the have-nots want to be. Trickle down theory has not worked.

    Thank you all for everything you do.

  10. Stephen Gross says:

    Quick note: This is an EXCELLENT guide for having influence over any service provider’s technical decisions. All of the above tactics are applicable in any scenario where a customer seeks influence/input into a servicer’s decision. Thanks!

  11. JG says:

    Carphobe has good intentions but is flawed in assuming people of the northern Indianapolis area suburbs in Hamilton County will choose public transportation over their cars (even if that means driving on over capacity roads.) The roads will only continue to get more congested as long as population grows. Better to employ measures to slow rates of suburban spread, encouraging central city investments. Central cities, often that were built around now defunct street cars, are the best place to roll out transit oriented redevelopment.

  12. cdc guy says:

    Agreed JG: you attract more flies with honey than with vinegar.

    For those of us so inclined, I believe that if we focus on making urban living more attractive for the 50-70% of every metro area’s residents that DON’T choose the city, we’ll get there faster.

    We can’t force people to live the way we choose to, but we can make it look good enough for them to want to try.

  13. Alon Levy says:

    Calgary is growing much faster than Indianapolis, and manages to make do without investment in multi-lane highways. In fact, it touts its parking restrictions and limited freeway construction as two of the reasons its light rail system is so successful.

    For suburb to suburb travel, small cities don’t really need highways – urban arterials and boulevards have enough capacity. And for travel to the urban core, public transit is a good substitute, as long as it’s done well. Small new metro areas even without dense cores regularly achieve transit shares of 15% or higher outside the US.

    By the way: Los Angeles and Portland have the same metro area transit mode shares…

  14. TLP says:

    This is great reading for us engineers in consulting too. I’m pretty new to the game, but I can already see how easy it is to make assertions without fully backing them up, or even to just follow the political decision that’s already been made for you and make answers fit that. It’s easy for me to say now before I’ve faced this situation, but we need to be willing to say to those who hire us “Our design is technically sound, but your assumptions and goals that we’re building towards are bullshit.”

  15. Thanks for the comments. TLP, I particularly appreciate your anecdote from the inside.

  16. Nathanael says:

    “carphobe, I don’t consider transit and highways good substitutes. A city like Indianapolis that is adding population at a rate of 250,000 per decade or so needs to expand its highway infrastructure.”

    Quite right, but you are using highways for the wrong purpose.

    Once an expressway has filled up two lanes in each direction, additional lanes simply provide terrible return on investment. You have so much volume at this point that you will do much better putting mass transit in on the corridor.

    Highway widening is rarely useful. New expressways to *different places* do provide a decent return on investment, but the NIMBYs will give you trouble there.

  17. Nathanael says:

    FYI, mass transit connecting to dispersed suburbs implies
    (1) large park-and-rides for housing;
    (2) distributor buses for (the highly undesirable situation of) spread-out employment locations.

  18. Nathanael says:

    “Carphobe has good intentions but is flawed in assuming people of the northern Indianapolis area suburbs in Hamilton County will choose public transportation over their cars (even if that means driving on over capacity roads.)”

    Wow. Well, if the people in those areas are simply car fanatics, then of course you’re right.

    In most of the country this simply isn’t the case, and I seriously doubt it’s really true even in the home of the Indy 500. The car lovers of suburban Los Angeles, the distant outskirts of New York City and Philadelphia, and the distant exurbs of Chicago — all are happy to take commuter rail to their jobs, even if they use their cars for typical pleasure trips. Car-loving Atlanta is quite happy with MARTA.

    The real question is what the nature of all those trips on the highway actually is. If it’s suburban traffic heading downtown, then commuter rail with park-and-rides is suitable.

    If it’s suburban traffic heading to a widely dispersed number of different suburbs, then you should build *different* roads in order to separate different sorts of trips onto different roads, rather than widening the existing highways.

  19. cdc guy says:

    Nathanael, the highest transit ridership outside the urban northeast is well under 20%. That’s a small minority of workers. Whether such folks are “happy” with transit is beside the point.

    Philadelphia and New York, whose growth followed rail lines, have “transit cultures”. But even there, (speaking from personal experience with the Philadelphia Main Line area), suburban garages have two, three, or four cars and most people drive everywhere; there are huge exurban employment clusters well off the urban transit grid.

    It’s possible to favor transit without romanticizing or fantasizing TOD, and certainly without saying “no more roads–ever”. Anywhere that 80-95% of workers commute by car (and that is almost everywhere), managing growth will require some new roads and increased freeway capacity.

  20. Alon Levy says:

    CDC Guy, it’s not “well under 20%.” Cities in Canada, even those that grew around the automobile, have a transit share a little under 20% and growing. And, yes, not building freeways was part of the formula for getting people to ride light rail.

  21. Another excellent post, Aaron!

    To Thundermutt’s comment that “In my experience, most of the people clamoring for extensive investment in transit could be categorized as ‘white, above median income creative-class people,’” I can say that our experience in the Transportation Equity Network — 350+ organizations in 41 states and DC — is quite different.

    Hundreds of our members in every corner of the country are low-income people of color who are taking their fight to their MPOs, state DOTs, and Capitol Hill because inadequate transit or service cuts are jeopardizing their jobs, their health, and their families. There’s nothing academic about highway-transit funding ratios for them — in fact few things hit closer to home.

The Urban State of Mind: Meditations on the City is the first Urbanophile e-book, featuring provocative essays on the key issues facing our cities, including innovation, talent attraction and brain drain, global soft power, sustainability, economic development, and localism. Included are 28 carefully curated essays out of nearly 1,200 posts in the first seven years of the Urbanophile, plus 9 original pieces. It's great for anyone who cares about our cities.

Telestrian Data Terminal


A production of the Urbanophile, Telestrian is the fastest, easiest, and best way to access public data about cities and regions, with totally unique features like the ability to create thematic maps with no technical knowledge and easy to use place to place migration data. It's a great way to support the Urbanophile, but more importantly it can save you tons of time and deliver huge value and capabilities to you and your organization.

Try It For 30 Days Free!

About the Urbanophile


Aaron M. Renn is an opinion-leading urban analyst, consultant, speaker, and writer on a mission to help America’s cities thrive and find sustainable success in the 21st century.

Full Bio


Please email before connecting with me on LinkedIn if we don't already know each other.


Copyright © 2006-2014 Urbanophile, LLC, All Rights Reserved - Copyright Information