Oregon Department of Transportation Director Matt Garrett has written a letter and an Oct. 9 op-ed printed in this newspaper that responds to some of the points in my report “CRC Tolls Will Produce Gridlock on I-205.” Here is my response:

1. Garrett doesn’t deny the accuracy of the CDM Smith Interstate 5 and Interstate 205 data I cite. They show that traffic levels on I-5 will drop precipitously when it is tolled, and that traffic levels on I-205 will increase by about 50,000 vehicles per day.

ODOT and CRC officials did not release this information to the public, and but for my public information request, no one would know about it today. ODOT has not released information — necessarily assembled to build the CDM Smith estimates — on how this diversion would increase travel times on I-205 and other routes in the region.

Garrett doesn’t deny any of the points I raise about the inaccuracy of the FEIS forecasts.

2. The CDM Smith projections completely contradict FEIS traffic projections.

The CRC FEIS claims that in 2030, traffic on a tolled I-5 will be 178,000 vehicles per day. CDM Smith says: In 2030, traffic on a tolled I-5 will be between 87,100 and 129,400 vehicles per day.

Garrett claims that because CDM Smith hasn’t settled on a final number (a “base case”), and is still working with a range, that somehow you can’t compare these estimates. Well, 178,000 is not a number between 87,100 and 129,400. It doesn’t matter where in its range CDM Smith ends up, the number is nowhere near the number published in the FEIS.

What this comparison really shows is that the figure in the FEIS is far beyond the wildest imaginings of CDM Smith. For the record, note that the high estimate of 129,400 vehicles per day in CDM Smith is lower than the number of vehicles that the FEIS claims are traveling on I-5 today (FEIS says 134,000 — in fact, it’s never been that high).

CRC has never corrected the factual errors in the FEIS, never added any pos-2005 traffic data, and never has updated its projections to reflect actual conditions. Also, ODOT has repeated the sophistry that they have two different forecasts “for different purposes.”

The falsehood here is that the federal government (or good practices or something) requires them to use a “high estimate” to measure environmental impacts. Actually, there is no such federal regulation or policy: The forecasts are supposed to be accurate, not high.

Moreover, the high travel forecast has the effect of misleadingly making the impacts of the CRC look smaller than they really would be — that is, the FEIS says that 184,000 cars will drive across the existing six-lane I-5 bridge in 2030 if nothing is done, but if we build the 12-lane CRC, the combination of tolls and transit will lower that (ever so slightly) to 178,000 vehicles per day.

This fictitiously high baseline allows CRC to claim that the giant CRC bridge will have smaller environmental impacts than doing nothing (which is on its face absurd).

CRC’s fictitiously high FEIS forecast hides the project’s environmental effects — it doesn’t reveal them. Also, FTA regulations require that the CRC officials certify that they are using one consistent set of travel projections to justify the project — which they clearly aren’t doing. And if CDM Smith’s forecasts of I-5 and I-205 traffic are significantly accurate as Garrett claims, then the environmental impacts of building the CRC are very, very different from those portrayed in the FEIS.

3. Garrett contradicts himself. If CDM Smith is “accurate” the FEIS is wrong.

Also, note what Garret claims about CDM Smith: He regards their forecasts as having “a significant degree of accuracy.” Not low, not high, in his own words, accurate. You can’t claim that CDM Smith is accurate and also claim that the FEIS forecasts are accurate. If the CDM Smith forecasts are, per Garrett, significantly accurate (usually within 5 percent and as likely to be under as over, then the numbers of the FEIS are simply wrong.

4. Garrett apparently does not understand what his agency hired CDM Smith to do.

Garrett is profoundly incorrect when he claims that CDM Smith work “is not designed to estimate traffic diversion to I-205.”

As a practical matter, there is no way for CDM Smith to estimate traffic levels and toll revenues on I-5 unless it estimated how much cross-Columbia River traffic would use the I-205 bridge. This specific task was arguably the entire reason that CDM Smith was hired.

Smith was asked to prepare a “Stated Preference Survey” to compute the value travelers attach to travel time savings, and use that information to compute how many travelers would pay the toll vs. choose alternative routes or destinations.

The “value add” that Smith brought to the project was its proprietary knowledge and model for computing toll-related diversion. But please don’t take my word for it. CDM Smith said as much in the report that Garrett’s ODOT provided to the Legislature in February.

Smith folks point out that their “value add” in the traffic modeling process consists of a “CDM Smith” model of “route diversion.” They use a four-step modeling process; three steps are cribbed from the Metro model, and CDM Smith uses its own model for “trip assignment” — i.e., deciding what route travelers use to travel between origins and destinations.

5. CDM Smith regularly overestimates traffic and toll levels

CDM Smith has an uncanny knack for overestimating traffic. CDM Smith (in its previous incarnation as Wilbur Smith & Associates), has either prepared or endorsed toll and traffic projections that have turned out to be massively overstated, and which have preceded bankruptcy or financial disaster for the projects involved.

This is so bad that two of the major rating agencies (Fitch and Moody’s) have called out the inadequacy of toll forecasts in the past year.

Fitch’s report highlights as deeply problematic a series of U.S. toll projects, most of them based on toll revenue forecasts either prepared or endorsed by Wilbur Smith & Associates.

Joe Cortright is an economist based in Portland.

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