Thursday, January 21st, 2010
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.
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.
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.