|
Click Here for FHWA Planning and Environmental Linkages Approach
Highway Expansion - Creating Tomorrows Problems Today
A Note about the I-70 West Draft PEIS under the Owens/Norton Regime
OR
The I-70 Draft PEIS is a highly biased document favoring highway widening alternatives over rail transit alternatives based solely on poorly estimated capital costs. Six Lane Highway costs were grossly underestimated because they did not incorporate Context Sensitive Design (Glenwood Canyon style design).
In addition, the Draft PEIS process did not incorporate the Context Sensitive Solutions process which requires that an interdisciplinary team of stakeholders be created and have active input to decision making throughout the PEIS process.
Instead, CDOT retained unilateral control of the Draft PEIS decision making process, shutting down all corridor stakeholders (far left of the chart above and below).
The prevailing CDOT culture over the past 8 years regarding transportation alternative selection has been strictly "Inform" and then at times, somewhat less than "Inform". This culture may vary somewhat between Planning Regions, but in general, the vested power to make transportation study decisions is held only by CDOT officials, regardless of the opinions of local jurisdictions and the general public.
In fact, in some cases, CDOT officials have determined the outcome of the study, even before the study was initiated. In this case (I-70 PEIS) over the course of the study, CDOT officials continually steered the study through their influence over the study contractor towards their desired and predetermined outcome of highway expansion. All study decision making is kept within the CDOT organization and virtually no stakeholder input is used in the alternative selection process.
Predetermined outcomes and excessive influence of study contractors by CDOT officials, not only results in the selection of poor transportation solutions, but adds significant cost and delays to the studies and opens the door to litigation.
The preference of highway alternatives in the Draft PEIS fulfills an Owens Administration mandate demonstrating the explicit direction of the the Colorado Governor and the CDOT Executive Director. Both have had a heavy hand in the direction of the study for over 7 years.
The Owens/Norton team priced highway projects ignoring their environmental, community and economic impacts as well as ignoring the appropriate mitigation measures necessary. They believed they could just force their way through the NEPA process and implement the highway solutions that they deemed to be right for the State.
After many years of contested study outcomes, conflict and costly delays in the Environmental study process, at least the FHWA may be finally realizing that they need to account for some mitigation measures and some context sensitive design in their projects which ultimately makes them more expensive than rail transit.
Had Norton and company been smart enough to actually partner with local jurisdictions and truly collaborate with all stakeholders up front at the beginning of the Environmental process, they could have saved millions of taxpayer dollars and reached outcomes that would appease a broad group of stakeholders. But this is not the Owens/Norton way, since they knew what was best for us and didn't need any of us to get in the way.
The Draft PEIS document discounts the findings of the Major Investment Study completed in the late 1990’s which found by consensus among stakeholders, an elevated high speed rail transit system to be the “Preferred” alternative.
Most rail alternatives were screened out early in the PEIS process back in 2000 and 2001. More appropriate and cost effective rail technologies such as the Stadler FLIRT EMU were not evaluated at all in the Draft PEIS. In addition, there are better alignments in the corridor that could deviate from the highway Right of Way where necessary, either to increase speed and ridership or reduce cost to produce a feasible rail alternative.
I-70 PEIS Questionable Practices
1. The selection a small firm (J.F. Sato) and excluded all other competition to conduct a major Programmatic Environmental Study that is fifty times greater in magnitude than that firm’s prior experience.
To what degree was this PEIS manipulated to promote a highway widening outcome based on the client-consultant relationship?
2. Intentionally fragmenting the distances of the study alternatives to provide a lower estimated cost for incremental highway alternatives to favor them over longer distance and more comprehensive transit solutions.
3. Making the Draft PEIS preferred alternative selection based on an overall cost using a comparison of 48 miles of highway widening (Clear Creek County – mp 247 to 213, Eagle County – mp 190 to 180 and mp 173 to 169) that does not meet the stated purpose and need for the PEIS versus 117 miles of high speed rail (mp 260 to mp 143 - C-470 to Eagle County Airport) that does meet the purpose and need.
4. Not considering high speed rail funding using a public purpose corporation, nor considering its commercialization potential, and other emerging funding sources.
5. The arbitrarily and capriciously selection of a $4 Billion ceiling on affordability when considering systems and modes with very different design lives, life-cycle cost factors and fundability profiles.
6. The suppression of specific data on the social and economic impacts in comparative analyses of transportation modes involving an extended construction period, especially regarding the highway alternatives that have a huge mobility disruption potential during the construction period.
Owen's Administration
"Preferred" Solution for the I-70 Corridor
7. The suppression of known historical and cultural impacts from the highway alternatives from public view by postponing the appropriate comparative analysis until tier II, thus biasing this analysis toward incremental highway widening.
8. The failure to alert the public to known environmental hazards that exist in the I-70 right of way (e.g. mercury, arsenic, lead, cadmium and other amalgam residuals left over from ore processing at 24 historic mill sites) that can be mobilized during highway construction activities.
9. Not disclosing to the public that the highway widening alternatives present a 47 times greater chance of uncovering and mobilizing these hazardous amalgam materials than is presented by the construction of elevated rail stanchions.
10. Failure to identify the potential water quality impacts and treatment costs, and business impacts on downstream communities and industries dependent on Rocky Mountain spring water, by the substantial increase in traction sand and chemical de-icer applications associated with the highway widening alternatives.
11. Failure to examine the continued availability and cost of asphalt and petroleum based fuels over the 75 year life cycle of the highway system being proposed, and the potential for reaching peak oil production well prior to the 75 year life cycle.
12. Failure to examine the Greenhouse gas emissions from the highway alternatives and their contributions to Global Warming.
13. Failure to examine the cumulative impact of I-70 highway widening on asphalt and petroleum based fuel use on other HUTF needs in the State for other highways and county and local, when a viable high speed transit option to asphalt is available for the I-70 mountain corridor.
14. Failure to make a true actuarial analysis of the costs of safety in terms of saving lives between incremental highway widening and high speed rail.
15. Failure to be responsive to the public or to build a consensus for an alternative that meets the stated purpose and need for this PEIS when such a consensus existed in 1999 at the conclusion of the I-70 MIS.
16. Continuing to arrogantly push forward a biased environmental impact statement that frustrates the intent of the National Environmental Protection Act in order to move to a Record of Decision for a highway project that fulfills a campaign promise made to the highway lobby.
17. Failure to address Traveler Safety in the Mountain Corridor, especially during periods of heavy snowfall, when many Front Range Residents and Visitors attempt to get to the Mountain Resorts.
-
When it snows at 1 to 2 inches or more per hour (which is common in the corridor, especially from Silver Plume to the EJMT), there is no way CDOT can keep up with snow removal operations on four lanes, let alone six lanes.
-
All a six lane I-70 will do in winter weather conditions, is allow more unprepared motorists to crash and be injured, allow more trucks to jack-knife and wreck, allow more horrific traffic backups and strand more motorists throughout the corridor when the inevitable highway closure occurs.
-
A six lane I-70 will not only jeopardize the safety of more motorists, but will place additional burdons on the corridor communities for Law Enforcement, Emergency Management, Fire Protection Service, Ambulance Service and the Care and Sheltering of stranded motorists.
18. Failure to provide a Travel Mode Choice in order to allow an option to driving in winter weather conditions, which is when many Front Range residents want to get to the Resorts.
More CDOT Highway Bias
Courtesy of the Victoria Transport Policy Institute:
Research Document Evaluation Guidelines
The guidelines below are intended to help evaluate the quality of research reports and articles.
Desirable Practices
1. Attempts to fairly present all perspectives.
2. Provides context information suitable for the intended audience. This can be done with a literature review that summarizes current knowledge, or by referencing relevant documents or websites that offer a comprehensive and balanced overview.
3. Carefully defines research questions and their links to broader issues.
4. Provides accurate data and analysis in a format that can be accessed and replicated by others. Quantitative data should be presented in tables and graphs, and available in database or spreadsheet form on request.
5. Discusses critical assumptions made in the analysis, such as why a particular data set or analysis method is used. Indicates how results change with different data and analysis. Identifies contrary findings.
6. Presents results in ways that highlight critical findings. Graphs and examples are particularly helpful for this.
7. Discusses the logical links between research results, conclusions and implications. Discusses alternative interpretations, including those with which the researcher disagrees.
8. Describes analysis limitations and cautions. Does not exaggerate implications.
9. Is respectful to people with other perspectives.
10. Provides adequate references.
11. Indicates funding sources, particularly any that may benefit from research results.
Undesirable Practices
1. Issues are defined in ideological terms. “Straw men” reflecting exaggerated or extreme perspectives are use to characterize a debate.
2. Research questions are designed to reach a particular conclusion.
3. Alternative perspectives or contrary findings are ignored or suppressed.
4. Data and analysis methods are biased.
5. Conclusions are based on faulty logic.
6. Limitations of analysis are ignored and the implications of results are exaggerated.
7. Key data and analysis details are unavailable for review by others.
8. Researchers are unqualified and unfamiliar with specialized issues.
9. People with differing perspectives are insulted and ridiculed.
10. Citations are primarily from special interest groups or popular media, rather than from peer reviewed professional and academic organizations.
Guidelines For Living With Information (Harris, 1997)
These general guidelines are designed to help readers critically evaluate information,particularly from the Internet.
- Challenge - Challenge information and demand accountability. Stand right up to the information and ask questions. Who says so? Why do they say so? Why was this information created? Why should I believe it? Why should I trust this source? How is it known to be true? Is it the whole truth? Is the argument reasonable? Who supports it?
- Adapt - Adapt your skepticism and requirements for quality to fit the importance of the information and what is being claimed. Require more credibility and evidence for stronger claims. You are right to be a little skeptical of dramatic information or information that conflicts with commonly accepted ideas. The new information may be true, but you should require a robust amount of evidence from highly credible sources.
- File - File new information in your mind rather than immediately believing or disbelieving it. Do not jump to a conclusion or come to a decision too quickly. It is fine simply to remember that someone claims XYZ to be the case. Wait until more information comes in, you have time to think about the issue, and you gain more general knowledge.
- Evaluate - Evaluate and re-evaluate regularly. New information or changing circumstances will affect the accuracy and hence your evaluation of previous information. Recognize the dynamic, fluid nature of information. The saying, “Change is the only constant,” applies to much information, especially in technology, science, medicine, and business.
Courtesy of the Victoria Transport Policy Institute:
How You Can Help:
|
Being a Change Agent
Mobility management often involves changing current practices, so proponents must be Change Agents, that is, people within an organization who provide leadership for change and anticipate and address objections.
Change Agents must:
· Expand the range of solutions that are considered in decision-making.
· Question assumptions used for evaluation.
· Look at the big picture. Pay attention to context and indirect impacts.
· Ask, “Are current trends desirable?” “Will they result in an optimal future?”
· Use comprehensive evaluation techniques that consider all benefits and costs.
· Make change more attractive than current practices.
· Use positive statements. Emphasize the benefits of change.
· Focus on appropriate niches. Don’t try to be everything to everybody.
· Don’t be afraid to say “no” to bad ideas, but try to offer an alternative which better balances overall objectives.
· Listen to and educate stakeholders. Develop communication with stakeholders in order to clearly understand the basis of their concerns and how they can be addressed.
· Don’t give up! Most change requires several efforts before success. Be prepared for obstacles and setbacks.
Innovation often faces resistance and criticism from people who fear change.
But if new ideas are fundamentally sound and advocates are persistent, they will often succeed and the same people who previously opposed the change will embrace it and claim it as their own! |
People often assume that what is considered normal must be good. For example, efforts to encourage use of alternative transport modes often face resistance from people who are accustomed to automobile travel and so cannot believe that alternatives could be better. “I just want to be able to drive where I want,” they might argue, implying that such behavior is quite reasonable, even if factors such as population growth, land prices and travel demand are increasing the costs of accommodating additional vehicle traffic and making alternatives more cost effective.
Change tends to be difficult because it requires “psychic effort,” that is, it makes people to think about situations that they otherwise can take for granted. For example, a shift from free to Cashed Out parking requires people to think about the value of teach trip and consider use of alternative modes. Similarly, it may seem stressful to try cycling or riding public transit. The first few times people face such a decision it may seem stressful. But over time people become accustomed to new options and conditions, and will often admit that they are better off overall, despite initial opposition.
The psychic effort can be reduced by making changes:
- Convenient
- Desirable
- “Normal”
Consider the first generation of trains, cars and airplanes. To modern eyes they look awkward, and their performance was poor. The first cars were horseless carriages, steered by a tiller rather than a wheel. The first Wright Flyer had various wings, stabilizers, steering panels and reinforcements that seem unnecessarily complex and inefficient; it could only carry one passenger lying on their stomach. But these modest beginnings evolved into modern cars and planes. Similarly, new transportation management programs and policies often seem awkward and inefficient when first introduced, in part because people are unfamiliar with them, and in part because important details may still need to be adjusted to improve performance. Do not let a program be judged too soon, do not be afraid to adjust programs and policies when needed, and continue to maintain a vision of what the program should achieve in the long term.
Organizations often require change management to reform standard practices and resources. For example, a planning agency may need to change its zoning codes, development standards, staff training, funding formulas and decision-making processes to effectively implement TDM.
|
Real Versus Token Change
Organizations often try to avoid real, fundamental change by implementing token reforms. An important Change Management skill is therefore being able to discern between token and real changes. Here are some indicators of real change.
· Although it may start small, it is the beginning rather than the end of organizational change.
· Leaders give it real respect and support.
· It is integrated into strategic plans and activities.
· It can grow to have a significant effect on organizational activities.
|
Rocky Mountain Rail Authority Establishing Contract (Word)
Contact your Colorado State Representative and Senator to Request their Support for:
The Rocky Mountain Rail Authority Rail Program
A Rail Transit First Solution for the I-70 Mountain Corridor
http://www.leg.state.co.us/
To Locate your Colorado Legislative District:
http://www.state.co.us/gov_dir/leg_dir/lcsstaff/REAP/Default.htm
Contact your Colorado County Board of Commissioners:
County Contact Document (Word)
http://www.ccionline.org/links.htm or http://www.ccionline.org/counties_map.htm
And Request their Support for:
Participation in the Rocky Mountain Rail Authority (formerly Front Range Commuter Rail)
A Rail Transit First Solution for the I-70 Mountain Corridor
|
