Part 1.0, Introduction
The purpose of the corridor study was to find the best location for the highway which was deemed “feasible’ in the Feasibility Study and to begin the legal process to “get ahead” of development and establish the rights-of-way that might be needed in the future. There was no effort to validate feasibility or to establish a specific need or purpose for the highway.
In Chapter 2, we pointed out that the Study Management Group (SMG) had already determined what it wanted--an interstate-like highway-- and the initial definition of all 13 alternatives assumed that. This study presented the final 400-foot corridor that was protected.
The Corridor Protection Report reiterates the Feasibility Study’s determination the outer belt “would benefit the region.” However, there’s no new supporting information to illustrate the benefit, nor is there any attempt to validate that assertion. For the purpose of this report, the benefit is assumed to exist. Though the consultant’s work included an extensive analysis of the highway’s costs, there is no work to ascertain a monetary benefit nor is there any comparison of the qualitative benefits to the project’s $500 million cost.
The report says that the GC will connect communities in the southeastern MetroEast, though in reality it does not. It bypasses every one of them, instead. There is connectivity between each of the communities in the study area, now. None of the connecting roads is congested, either. Moreover, a limited-access highway is not designed to connect communities, but as a means to move large quantities of vehicles at high speed. It might connect the communities to the broader region more efficiently, but one has question the benefit of doing so. Is saving a few minutes on travel for a small percentage of the people worth the cost that everyone must pay, in dollars and in lost opportunities to reap other benefits?
The study claims new access to labor pools would support economic development. Yet, the study itsefs shows that the labor pools are already located in the business areas, and that by 2020 both employment and labor pools would not materially change. Access is thus moot, by its own analysis. Indeed, an objective examination would show the I-64 corridor is the only one needed for access to labor pools in the MetroEast and that’s so those people can get to work in Missouri.
In addition, goods do not substantially flow from Troy to Columbia, but rather along IL4 and I-270. If commerce were planned alongside the corridor, then goods should be expected to flow along it. Yet, the Feasibility Study says stakeholders do not want trucking on the new facility! That apparent contradiction defeats the access argument.
None of these difficulties was questioned by the Corridor Protection Report, though the fallacious predictions were supported, even embellished.
Part 2.0, Purpose and Need
The report lists eight factors that should be evaluated to establish a facility’s purpose and need, and implies there are more, though they are never mentioned. The first two are system linkage and under-satisfied capacity. Two others are cited as important for the GC corridor—safety and economic development. Thus, the report states there are four needs that can only be satisfied with a new highway, and that “some of these needs are clearly understood.”
The study asserts a need to link I55/70, I64, and IL255. A cursory look at those three highways will show they are already linked, and that the GC will actually link them at much farther distances. Currently IL255 intersects both I55/70 and I64. The GC will add no new linkage, and the best that can be said is that it duplicates linkages that currently exist. This assertion is no more verifiable than the assertion that the GC will connect communities.
The capacity argument, as with nearly all of the justification, is dependent upon a substantial, permanent growth in population. That has already been shown to be doubtful in the long run across the region as a whole. We shall examine the specifics for the study area.
Safety will be reduced if the GC is not built according to the report, owing to degraded levels of service on arterials and secondary roads. The implication is that adding a new highway, and thus preventing added congestion, is a preventive action that will keep crash rates for going up. That sounds reasonable, in theory, but from a practical viewpoint, it incorrect. There are many ways to reduce accidents, as we discussed in Chapter 2.
The report claims that “commercial business development has expanded markedly in the Gateway Connector study area…” That was not correct in 2003 and is still debatable today. Giving the word “markedly” some latitude and enlarging the “study area” to be relatively broad, it’s difficult to convincingly demonstrate the expansion of commercial businesses, or a significant increase in commercial vehicle traffic.
The other 6 factors were transportation demand, legislative mandate, social demands or economic development, modal interrelationships, safety, and roadway deficiencies. Appendix B of the Corridor Protection Report details the actual analysis done for the GC. The report stated that 24 criteria were used (classed in 4 categories as engineering, traffic, social/economic, and environmental), but It was not at all clear whether the analysis included any or all of the eight listed factors. Even if it did, the output was highly dependent upon individual judgment in rating the criteria. Such subjective assessment often results in simply validating a predetermined conclusion.
As a summary of the purposes and need for the highway, the comments do not try to convince the reader of their veracity or accuracy. One is expected to accept them; we see none of them as compelling. They certainly do not support a limited access highway over other roadway options.
Part 2.1 Population Trend Analysis
The report states a couple of times that population growth is one of the most significant reasons for expanding highway capacity. As stated, we completely agree that “population growth is an important basis for needed expansion of a transportation network.” We also submit that absence of growth is a legitimate reason NOT to expand the system.
We also take exception to the process, and to the conclusions reached from the trend analysis. The authors note on several occasions that they are not trying to prefer one transportation solution over any other. Yet, they still do a detailed assessment of population and traffic trends and then conclude that the system must be expanded. We wonder why the apparent contradiction? If it’s to establish the “need,” then the analysis should be correct if the recommendations are to be held out as valid. We know why the analysis was not correct.
Simplistic Assumptions
First is the omission by the study group of an evaluation of societal trends that dictate that growth. This report, like the Feasibility Study, takes select data and extrapolates it without assessing the facts and circumstances surrounding the data or the expected conditions in the future. We acknowledge the work of the local cities and the EWG in projecting growth, but suggest that it is in their interest to overstate growth. These organizations even acknowledge that studies are often based on the “worst case,” rather than a “reasonably expected” case.
Experts now agree that has resulted in a lot of wasteful spending and overbuilding. That has happened in District 8. One example: Along US50 from Lebanon to Carlyle millions of dollars were spent to build bridge structures that have never been used. As standards change and the structures atrophy it is most likely that they will never be useful, and it may cost extra to eventually destroy and remove them.
Model Input was Skewed
Secondly, consider the study’s analytical method and what is not included in that method. We have identified at least 3 shortcomings—use of a distorted baseline, not adjusting for annexation, and omitting the effects of Scott AFB closure of its housing units—which have lead to erroneous conclusions.
The report uses three census years, 1980, 1990, and 2000 to conclude growth rates for the counties and cities. The year 1980 followed a big migration out of the area. From 1970 to 1980, nearly 20,000 people left the 3-county area. Had 1970 been used instead of 1980, the growth rates calculated would have been statistically and significantly different. Indeed, the population in the 2000 census was still lower than that of 1970; and it wasn’t until 2008 that it fully recovered to the 1970 level. The 2010 census showed a net increase in the 3-county area to be 17,354 people—a 40-year total growth of a mere 3%. Annualized, it’s practically zero growth!
The St Clair county growth rate is still negative after 40 years, and the US Census Bureau expects that to persist until well past 2030. Both the Illinois Department of Commerce & Economic Opportunity and EWG have adjusted their population projections to more reasonable numbers since this report was published. (NOTE: It appears the DCEO recently took down its county population predictions from its web site.)
Monroe County has experienced “substantial” growth when expressed as a percentage. However, the small size of the county exaggerates the actual effect.
The rates of growth in some of the central cities/towns listed in the study area are even more distorted. While the report points out that “there were also instances where municipality boundaries were likewise altered…” the report otherwise ignores the effect of that alteration, that is, the population added due to annexation of existing residences. There was no effort by the consultant to remove those people from the reported growth numbers. In the case of Shiloh, more than half of the growth was due to its expansion along Lebanon Road toward Belleville, and then between Hartman Lane and Old Collinsville Road. Dozens of subdivisions and hundreds of homes were gobbled up by the city.
Expansion also occurred as Scott AFB closed its housing units; tenants moved families from base housing to off-base quarters, notably in Shiloh and O’Fallon. The study puts the number at 4,538 people. If they all had gone to Shiloh, that number alone represents a 434% increase in population!
Despite these three obvious factors skewing the data, the consultant reported the growth for Shiloh as 631% and O’Fallon as 79%. The data could easily have been corrected as the size of the adjustments was readily available from the two city’s staffs. Yet, none of the stakeholders who should have asked for a review and correction did so.
Instead, the consultant spent a great deal of time manipulating census tracts that were inconsistent across the census years. Unfortunately, how that manipulation was done or what the effects were is not reported. What is known is their discovery of the obvious—the growth in the census tracts was like growth in the cities that made them up.
Relevant Data Not Considered
At the same time the report stresses growth in O’Fallon, Shiloh and Troy, it downplays the trend in the biggest city in the study area—Belleville—and all the core cities like E. St Louis. The report’s data shows the actual declines in population, but does not use it to reach any conclusions about the purpose of need for the highway, even though the highway is an outer belt around these specific cities. For Belleville, that’s particularly noteworthy because the report claims that traffic projected flow patterns “were circumferential movements between…regional employment centers (such as Belleville…)…” Had overall or net population growth also been considered and evaluated in the report, we believe the conclusions would be different.
There is no doubt that growth in the area of the corridor has occurred between 1980 and 2000; and that it continued until at least 2008 when the housing market imploded. At least 10 new subdivisions have sprung up in Shiloh and O’Fallon, though not all of them in/near the corridor. However, we know it’s nowhere near the percentages put forth in this study. We believe an objective assessment, to include new modeling of the traffic flow, would put it well below the level which might cause officials to make a subjective call for a new facility.
Finally, there is another fact that is ignored by the report, perhaps because it’s politically dangerous to mention. The phenomenon of “white flight” has affected all of the cities mentioned in the report, both inside and outside the study area. East St Louis lost nearly all its white residents and fell from more than 80,000 in 1960 to under 30,000 by 2010. Matt Hawkins, an activist fighting city corruption put the actual population at less than 23,000 in 2014. Similar migration can be inferred from other towns in both St Clair and Madison counties. Those tens of thousands mostly stayed in Illinois, and after 1970 many moved into cities now in the study area. This is particularly important because they have already moved! The big uptick, the big growth spurt, the crisis the report seems to be portraying due to a population explosion is largely over. That reality must be considered if a fair prediction of future growth is to result.
The future population projections cited in the report were from EWG and included only three cities. Why others were omitted is not known. As stated, since the Corridor Protection report was published, the projections have changed significantly.
Part 2.2 Traffic
We agree that population growth and increased traffic demand have occurred since the report was released; we disagree on the magnitude of projected long-term growth. The report states the projections “…demonstrate greater future growth, and therefore, greater need for an expanded transportation system.” Recall that the baseline census was 2000 and the projections were for 25 years. We have 2010 data everywhere and 2012 data in many places, so that the growth is known for roughly the first half of the projected period. Table 3 shows that today, roughly 29,000 more people live in/near the study area compared to 2000. That’s not significantly different from many of the projections. In spite of that growth, an examination of the region’s entire transportation system shows that congestion is occurring only along Greenmount Road and Frank Scott Parkway (and that can be debated), but nowhere near the study area. In addition, the level of service has not dropped in spite of the population increase. The claim that there is a need for expansion because of new population growth is just rhetoric and invalid.
In discussing land use, the report asserts again that population growth ”could be expected to generate an additional 35,000 vehicle trips per day…” Since four-lane facilities “can efficiently carry 22,000 to 29,000 vpd,” the report concludes something more is needed. Neither of these statements has been substantiated, and since the report’s objective analysis comes up with entirely different numbers, we submit they are irrelevant, as written.
The report found its travel demand model added 16,000 to 45,000 vpd in the corridor. Much of that increase is between I-64 and SAFB where the projected increase in volume is from 18,000 vpd to 42,000 vpd. Despite increases in the employment at the base, the actual volume in 2014 is still less than 19,000 vpd, essentially unchanged after 14 years of the 25-year projection. Even as employment at the base peaked in 2012, there were fewer than 20,000 vpd along the highway.
Because county officials hope to put up to 1/3 of base-bound traffic onto a new interchange at Reider Road in the next 5 years, it quite possible that volume will drop below the year 2000 volume—not increase by 133%. We believe this illustrates not only the poor performance of the abandoned travel demand model used in 2003, but also validates our assertion that input to the model was erroneous.
Actual Traffic Increase in the Study Area
For a moment, though, let’s assume the model was correct. Table 2 lists the study’s predicted volumes for the 11 road segments selected as “within the study corridor.” In 2000 the volume was 201,200 vpd. The reported model output puts the volume at 322,000 vpd, or a 60% increase, if the connector is not built, or 338,800 or a 68% increase, if it is built. The difference in volume is merely 16,800 vpd. If existing roads could handle 322,000 vpd, is that worth $500 million?
One would reasonably expect the study to address whether the capacity of existing roads is sufficient to handle 322,000 vpd, and whether alternative solutions to increased traffic might be a more efficient and
prudent way to control the increase. For example, if IL 4 north of I-64 did have 13,000 vpd and experienced an unacceptable LOS as a result, it would make more sense to widen that road than to build another road 5 miles to its west. This report does not address the existing capacity issue in any meaningful way.
We looked for some indication of the capacity of the 11 segments in this report because it was used frequently to claim existing roads couldn’t handle projected traffic. We asked Candace Sauermann, who handled the project for the Department, about the capacities of the 11 segments, too. She declined to answer, saying that it is too tough to answer that question. She said that so many variables enter the computation and that it would take too many hours—and a separate study--to ascertain the answer.
Absent any data on the actual capacities of these segments, we believe any conclusion reached on congestion or on the need for system expansion is invalid.
Let’s now forget our assumption and evaluate whether the model was, in fact, correct. In 2012, IDOT’s GIS mapping shows actual volume on those 11 segments had risen to 213,100 vpd--a 6% increase. Arbitrarily doubling that to year 2025, so as to make a direct comparison to the report, brings the increase to 12%. The no-build increase could be 24,800 instead of the 120,800 predicted by the model. That’s a 387% error, much too large to ignore. The actual increase and our extension also mean the expected difference between the “build” and “no build” volumes will be much smaller than predicted.
The model output is flawed, at best, and it is used by the Department deceptively, at worst. Recall this travel demand output, along with population growth, were the only two reasons cited to show a need for the GC. Therefore, the conclusion about the need for system expansion, based on the report’s analysis, is false.
We have already noted that each past occurrence of local congestion, notably at intersections, has been solved by turn lanes and signals. An assessment of those options should trump the “desire” to have a 4-lane divided highway and be included in any follow-on study.
Relief for Other Roads
Instead of considering all roads as we do in the preceding paragraphs, let’s look at the 9 road segments from Table 3, other than the GC—those which are to get relief if the connector is built. They do not include Troy-O’Fallon Road or IL 158 south of I-64. Again, we’ll assume the model projections are correct. The report indicates the 9 roads will have a volume of 267,000 vpd if the connector is not built. If it is built, their volume would drop to 262,800 vpd--a difference of only 4,200 vpd!
From 2000 to 2014, the volume on those roads increased from 176,200 vpd to 185,900 vpd, 5% or 9,700 vpd according to historical data maintained by the Department. The cost to add twice the travel demand model’s projected increase—practically nothing. And that compares to the actual population growth of 14%.
After modeling the corridor, and asserting that the GC would draw up to 32,000 vpd in the north, 48,000 vpd in the center, and 20,000 in the southwest, the report states that that model output justifies a new facility. That logic is tantamount to saying “If you build it, they will come; and since they’re coming, we must build it.” As presented in the report, the reality in that justification is missing. The basis is only a presumption, which has been debunked numerous times across the country, as we discuss in Chapter 4, Current Expert Thinking in Transportation.
But what if the volume increases to 13,000 vpd on Scott-Troy Road (northern corridor), as suggested in the report? In 2014, the volume is already at 11,000 vpd level south of Oak Hill School Road, mainly because of the Braeswood and other new subdivisions. Yet, the accident rate has not measurably increased and there is no congestion at the US50 and Scott-Troy Rd intersection, now that the intersection has been widened and turn lanes added.
So, the assertion that there would be an unacceptable operating condition (LOS D) seems false from the actual conditions. If the volume increases further, we suggest widening of the southern stretches of the road makes more sense than a 6-lane facility. Such an improvement can be done without corridor protection, but using rights –of-way that existed before it.
To the southwest, the report says the connector would provide a by-pass around Columbia that would reduce traffic on IL 3 by up to 85% (from 35,000 vpd now to 5,000 vpd after the GC draws vehicles off it). Given the sources of the traffic now entering IL3, we question the magnitude of the reduction; and if dies fall to 5,000 vpd, does not that suggest the GC was something of overkill to solve the transportation problem?
Still, the people of Columbia ought to decide whether to build a bypass, just as the people of Waterloo accepted an IL 3 bypass around their city. That work does not need to be a part of a bigger outer belt, and if that’s what’s needed, we suggest the project scope be reduced to that level. The City of Columbia’s Comprehensive Plan seems to suggest the same thing!
Local or Through Traffic?
Finally, we are a bit puzzled by the conclusion that a new outer belt facility, preferably an interstate-like highway, is needed if most of the travel on it is expected to be local travel. In at least two places, the report points out that trips would not be through trips, but shorter ones within the local area. That decidedly argues AGAINST a limited access facility, but rather suggests improvements to local roads would be preferable.
Part 3.0, Alternative Development and Analysis
Since the desired facility was established in the Feasibility Study and since the aim of this report was only to find the best corridor, there was no effort to compare the costs and benefits of local road improvements to the costs and benefits of the GC as a whole. We are told that would occur in a Phase I study.
To begin the process of refining the corridor, the consultant broke up the 41-mile stretch into five separate sections, starting at I-55/70 in Troy and ending at I-255 in Columbia. Seven guidelines for developing the alternatives within each section, mostly environmental, and at least five constraints were applied to the physical conditions found within each section. The resulting applications drove the eventual corridor selection and the costs associated with building the limited access facility. It is telling to note that the final selections were chosen by “…formulating ‘reasonable’ alternatives…” in each of the five corridor sections. In other words, the choices were subjective.
To evaluate each of the five segments, 24 criteria were used. The criteria were not listed for reference; however, we note that the Evaluation section of Appendix B provides for subjective assessment in each of four categories of criteria. Thus, the report identified alternatives subjectively and evaluated each of them subjectively. We do not know who provided the ratings, the expertise of the raters, or the number of people rating the segments.
Construction costs for each alternative in each section were estimated, and once the preferred corridor was selected across all five sections, its cost was calculated. The report stated that the cost would be $395.6 million to build the GC. The District 8 Engineer, then Ms. Mary Lamie, subsequently went on record and told a number of organizations that the total could be as high as $500 million because of the additional cost of acquiring properties in the corridor (in 2004 dollars). That number has become the unofficial estimate.
As of the 10-year anniversary of the legal establishment of the corridor and this hearing, inflation alone has increased that cost estimate by 42%. The average cost per mile has, therefore, risen from $10 million to more than $14 million. The consultant’s estimated cost of this project has now increased to $560 million in today’s dollars. If Ms. Lamie’s estimate is correct, the cost to build the highway today is closer to $700 million. Further, if the project starts after 2028, and inflation rises to its long-term average of 3.22%, the project will cost in excess of $1 Billion. Local officials are not clamoring for it to begin, and it’s said to be 15-20 years away still; that means its total cost could rise to over $2 Billion by the time it’s finished.
Part 4.0, Environmental Conditions and Potential Consequences:
Claiming a Legal Right with no Compensation
The immediate effect of corridor protection is to place a deed restriction on each parcel, requiring action on the part of property owners, and potentially limiting their rights as owners. There is no provision to compensate any of the owners for this unilateral imposition of restrictions. We find that concept discriminatory and unfair. These property owners are the very ones who would sacrifice for the common good, yet they are shortchanged at the onset of protection and when land is finally acquired.
NEPA
The report acknowledges the possibility that a facility other than a limited access highway may be “needed,” but suggests that a Phase I study is required to determine that. We strongly disagree that another study is needed. The National Environmental Policy Act (NEPA) requires such a study only if a major project, wherein new construction of 4 lanes or more is planned. Pursuant to CFR 771.117, highway improvements, including adding new lanes and all safety-related improvements, are exempt from a Phase I study. Even in cases of new construction of less than 4 lanes, an Environmental Assessment may satisfy NEPA requirements.
To claim that an EIS is needed is, in effect, to pre-determine that only a 4-lane divided highway can fulfill the perceived need and purpose. However, we know from the Feasibility study that the real momentum behind the highway is political “desire.”
As the state’s experts in transportation, the Department should render a reasoned judgment as to whether this project is needed, in the best interests of the citizens, and worth upwards of one billion dollars. The Department should convey that determination to elected leaders. To pay a consultant to do that for them in an EIS abdicates their responsibility, in our opinion.
Reality: Corridor isn’t Being Protected
It is important to remind the reader at this time that there have been at least 50 requests by property owners in the corridor to complete capital improvements. None of them has been “denied” by IDOT, by buying the property “as is,” instead of allowing the improvements to be completed. Thus, the effect of corridor protection for these last 10 years is virtually ZERO!
So, for all the effort to protect the public from the increases in fair market value of properties in the corridor by establishing its protection, the Department is intentionally failing to follow through. Based up our conversations with District 8 personnel and the trend we observe in the Highway Improvement Plans, wherein the budget for land acquisition dropped 90% from $100,000 per year to $10,000 per year, we anticipate the Department will to continue the lack of protection.
To establish this corridor, IDOT spent untold millions, already. There are also costs inherent in maintaining the corridor, from land acquisition staff actions to legislative costs. We believe the total will eventually exceed the perceived benefit of corridor protection.
To those who would claim that corridor protection avoids future disruption by more people than would otherwise be disrupted, we say that those people should have the right to assess the situation themselves when the time comes. If they decide a highway is needed and are willing to make the sacrifices to get it, then that should be their decision. We ought not assume what will be and make the decision for them.
Environmental Justice
Environmental Justice was addressed in the report, but it was considered only in the direct manner. Because the GC did not traverse any minority-held properties and no minority concentrations were found, it was assumed that there would be no adverse impact of low-income or minority populations. In other words, social justice and environmental justice did not apply to this project.
However, the cost of this project is quite likely to have an indirect adverse impact. Not only will dollars be diverted from other transportation projects that could affect minorities, but the size of the project could reduce other kinds of funds, as well. In addition, one stated goal of the project is to stimulate economic development. As the corridor is far from those minority concentrations, it will necessarily and disproportionately omit them from the benefit. Historically, government-induced development in the St Louis area has done little more than shuffle businesses around. Shuffling them farther from the American Bottoms region may worsen the impact.
As the highway is designed as an outer belt, it will carry traffic away from Belleville, where there’s an ever-increasing minority presence. Once again, they will suffer as induced sprawl takes place.
Our analysis is not speculative. Independent studies, detailed by the Economic Research Defense Council in 2000, found bypasses do, in fact, have consequential adverse effects on core minority communities. We would highlight “adverse” in their commentary.
Adverse Impact or Not?
The report contains an extensive discussion of the geography and geology of the study area, as well as cultural, historic, agricultural and biologic assets and resources. There is, however, very little comment on the impact building a roadway would have. It is curious that whenever the impact is reasonably expected to be adverse, no assessment is made, but when there is expected to be no impact, such an assessment is declared. In fact, in the case of air quality, the report states that the project “is expected to have a positive effect on...air quality…”
Comments in the report include these: “5.66 acres of wetlands will be affected;” “seven sites may have hazardous waste;” “the highway may impact ground water quality in the karst region.” There is no comment whether the impacts will be adverse. As with most construction projects, we believe the impacts will be adverse. For the Department, the issue is only what can be done to minimize the adversity.
There’s also the disingenuous comment that the visual environment of an “undeveloped landscape” will be altered by the GC, as if that would be an improvement.
Postponing criticism to a Phase I study, the Corridor Protection Report appears to be both deceptive and self- promoting. We think common sense should apply. The reality of the adversity must be acknowledged up front, and action must be taken which reflects that reality.
There was almost a step in that direction, according to Part 5.0, Agency Coordination. Much of the discussion at coordination meetings centered on the environmental issues. In the final analysis, though, it was decided only that, when built, the impacts should be minimized—and that those impacts will be determined during the Phase I study. That the agencies’ concerns about the environment were dismissed is found in Part 7.0, Summary and Recommendations. The report unambiguously states “The GC is recommended as a future transportation facility…”
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