Count the Holes in Colorado DOT’s Justification for the I-70 Widening

Photo: David Sachs

A lot of people don’t like Colorado DOT’s plan to widen I-70 in north Denver — and for good reason. Expanding I-70 will generate more traffic, noise pollution, and greenhouse gases while costing a bundle of money that could be spent on other things, like, say, better transit.

Opponents of the road widening told CDOT why they think it’s a bad idea, and CDOT is required by federal law to respond, but apparently those responses don’t have to make sense.

Streetsblog has been speaking to advocates about CDOT’s final environmental impact statement for the project, released last week. They say the agency dismissed their objections to the I-70 widening using justifications that were flimsy, misleading, or flat-out wrong.

This is a major infrastructure project with big implications for the future of the city, so we’ll be running a series where advocates expose how CDOT plays fast and loose with the facts. First up is Will Toor, transportation director for the Southwestern Energy Efficiency Project.

“The sense that I got from [CDOT’s] comments is that there was simply so much momentum behind the project from previous years that no significant changes were going to be considered at this point,” said Toor. Here are four bogus responses he spotted.

CDOT Claims Tolling Existing Lanes Is Illegal, But It’s Not

Toor wanted CDOT to consider converting existing lanes into high-occupancy/toll lanes that could be priced based on congestion levels. CDOT’s response? “Converting general-purpose lanes to managed lanes is not allowed in Colorado…”

“That’s simply incorrect,” says Toor. “There would have to be a local government approval process, but it would be possible under Colorado law.”

Toor should know. He worked on the FASTER legislation passed in 2009, which plainly allows conversion to tolled lanes after a public process.

CDOT Compared I-70’s Greenhouse Gas Emissions to Total Global Emissions

SWEEP questioned whether greenhouse gas emissions from the extra traffic would satisfy regional standards. In response, CDOT said greenhouse gas emissions had been “adequately addressed” and referred to another section of the mammoth document. Here’s what that section said:

The affected environment for carbon dioxide and other greenhouse gas emissions is the entire planet. In addition, from a quantitative perspective, global climate change is the cumulative result of numerous and varied emissions sources (in terms of both absolute numbers and types), each of which makes a relatively small addition to global atmospheric greenhouse gas concentrations. In contrast to broad scale actions such as actions involving an entire industry sector or very large geographic areas, it is difficult to isolate and understand the greenhouse gas emissions impacts from a particular transportation project.

“Obviously any individual project is going to be insignificant if you’re comparing it to total global emissions,” says Toor. “Under that logic, no action short of a global climate change agreement would be meaningful.”

CDOT Relied on Travel Behavior From Last Century to Make Its Case

CDOT justified the highway widening by saying traffic on I-70 is projected to increase dramatically. But those predictions were based on an old model that didn’t account for the fact that traffic hasn’t been increasingly very much since 2006. Regional planners have since updated their traffic model, but CDOT won’t use it, because its modeling is “based on federal requirements.” CDOT says the difference between the two models is negligible, about 5 percent.

Confused? This should simplify things: The EIS reveals that both models are based on “pre-2000 household survey data.”

In other words, says Toor, “they don’t reflect any of the changes in travel behavior that’s taken place since the year 2000.”

Six Years of Traffic Data Isn’t Good Enough for CDOT, But Two Years Is

Between 2006 and 2012 driving essentially leveled off in the Denver region. Since then there’s been a modest upward trend. CDOT says that trusting data from the six years of no growth is “near-sighted.” But in the very next sentence the agency treats the uptick in the last two to three years as gospel:

Recent data from the past 2 to 3 years suggests that VMT is beginning to trend upward and in some cases is trending upward at a rate that is near or above the pre-economic downturn annual increases.

“Fair enough — it is clearly the case that over the last two years travel trends are turning around,” says Toor. “With the advent of very cheap gasoline, it is clearly true that travel is trending back upwards. But you’re making a billion-dollar-plus decision on infrastructure that’s gonna serve for many decades and I think it would be important to look at the longer term travel behavior trends.”

Traffic levels are also heavily influenced by infrastructure. CDOT’s prophecy of more traffic is self-fulfilling because creating more space for cars will lead people to drive more.

“Fundamentally I think that CDOT is an agency that’s evolving and is getting better and better over time, but that this particular project is one that has been around for a long time, and essentially still reflects the older thinking of the agency,” says Toor. “As opposed to the direction I think they hope that they are headed.”