This is testimony on behalf of XRPDX, a 1500 member climate justice organization that is part of a global climate movement. We have no argument with the supplemental environmental impact statement (EIS) in terms of the importance of such a project for seismic resilience, upgrading public light rail transit (LRT), improvements for active transportation, and the additional express bus transit options on shoulder options during peak periods. We also agree with working on some sort of equitable variable congestion pricing designed with the expressed goal of reducing vehicle miles traveled (VMT) (not ONLY paying back the construction bonds). That said, this project should be a right-sized bridge replacement not a $7.5 billion proposal (possibly to be made worse given the draft geotechnical report). We also oppose significant widening for extra and auxiliary lanes.
Having followed ODOT’s state transportation plan, we’re painfully aware of the numerous, critical needs for future-focused transportation systems and addressing transportation safety issues statewide AND the current crisis in funding. A right-sized bridge would help bring costs down. Relying on tolling for funding seems risky (the sad story of the SR99 tunnel), and thus along with other groups we would like to see an Investment Grade Analysis prior to a funding commitment by the State. Oregon’s share of this project is not funded and could take away critical monies for other state priorities as well as transportation plan priorities. We are greatly concerned that currently there is not funding for the LRT or express bus public transit which we view as key to supporting this project. ODOT has a problem with chronic cost overruns and we want to ensure that monies are prioritized for public transit. We are also concerned that the steep grades and height being proposed for the fixed bridge design could be a barrier to active transportation and want more work done on addressing that issue.
As a climate justice organization, we are worried about the seemingly cavalier dismissal in this EIS of the likelihood of mitigation measures being able to contain warming to even 2 degrees centigrade and non-attention to how this project might contribute to that outcome. Furthermore, the whole way the issue of VMT is treated in this project by ODOT is unacceptable from it’s definition to not recognizing the growing body of research linking highway expansions to induced demand, to virtually ignoring the critical timeframe we have to reduce driving in the US by at least 15% as part of the strategy to cut greenhouse gases (GHGs) in half by 2030, and the fact that even 8 new lane miles will likely result in 41-62 million additional VMT annually along with those added emissions. Furthermore, we are concerned about the equity and climate justice issues given that 80% of commuters are Clark County residents, but North and NE Portland residents have disproportionately been affected by toxic air pollution, noise, and the neighborhood impacts of this freeway, not to mention its’ history of dividing Black neighborhoods and displacing residents. The displacement of residents and businesses is again on the table and a smaller footprint might lessen the need for as many as are being projected.
We have concerns about some of the data presented in these models. We were surprised to see the 180K vehicles estimate for the no-build option for 2045 when that same estimate number was utilized in an earlier model for 2028. Does the forecast for 30K less vehicles than the bridge carries today come from transit and active transportation or what other factors go into that modeling? If it anticipates moving significant traffic counts of vehicles to I 205 crossing due to tolling, that is a problem (especially since the model without real evidence seems to minimize that possibility). Forecast modeling has been problematic, for example ODOT’s 2005 prediction of 1.3% growth whereas in reality there has been almost negligible (more like.3%) overall growth in traffic counts from that time to the near present, including some times of actual decline. Logically, the claim of having very little difference in VMT whether it is one or two auxiliary lanes does not make sense, but given what we are seeing in data presented on a number of fronts including GHG reductions, a second auxiliary lane should definitely not be included in any final plan. We were puzzled by the variable time toll rates increasing southbound peak hour bus travel in the mornings in 2045 compared to the no build model, but now realize that is because a significant part of congestion is actually from the I5/I405 split and with that not resolved this project will not reduce southbound morning congestion or reduce “stop and go” emissions with the backups still predicted to Mill Plain. It also seems like ODOT needs to work with PBOT and Trimet to address how LRT capacity is likely to be constrained at the Rose Quarter.
Finally, we are concerned about mitigating the impacts of this project on the river ecosystem, endangered migratory fish species, and the life cycles of other fish and water species. The US Corps of Engineers places limits on various types of construction to a November-February timeframe, but this project is proposing Sept.15-April 15 for impact pile driving during the salmon migratory season. It also has a gigantic loophole exception for “diver-assisted removal of specific individual pieces of debris or large rip rap necessary to place a drilled shaft” being conducted at any time of the year. Similarly, there are no other restrictions on other activities such as vibratory hammers or oscillators from use in year-round construction. We are concerned by the lack of details or data on how these practices and their deviations from project norms could impact fish or other species.
In short, we favor a right-sized, more affordable bridge replacement project focused not on lane expansions but on seismic upgrades, additional light rail and express bus public transit, active transportation and with congestion pricing to reduce VMTs.