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U.S. DOT Blows Chance to Reform the City-Killing, Planet-Broiling Status Quo

1:03 PM PDT on April 20, 2016

The Obama administration purportedly wants to use the lever of transportation policy to reduce greenhouse gas emissions, and Transportation Secretary Anthony Foxx recently said he'd like to reverse the damage highways caused in urban neighborhoods, but you'd never know that by looking at U.S. DOT's latest policy prescription.

U.S. DOT has drafted new rules requiring state DOTs to track their performance. Reformers hoped the rules would get states to reconsider highway expansion as a method of dealing with congestion and emissions, since widening roads induces more traffic and pollution. By introducing better metrics and reporting requirements, the thinking goes, U.S. DOT could compel states to document the failure of highway expansion, which would lead to pressure for a new approach.

Is U.S. DOT teeing up a lot more projects like Houston's Katy Freeway? Photo: Wikipedia
U.S. DOT isn't taking steps to hold transportation agencies accountable for building ecological disasters like the Katy Freeway. Photo: Wikipedia
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But the rules released yesterday are a big disappointment, say analysts. While it will take a bit more time to fully assess the 423-page document [PDF], advocates are already going on the record panning U.S. DOT's effort.

Greenhouse Gas Emissions

On the question of whether state transportation agencies should be required to at least report the emissions impact of their transportation plans, U.S. DOT "whiffed," writes Joe Cortright at City Observatory:

There’s nothing with any teeth here. Instead -- in a 425 page proposed rule -- there are just six pages (p. 101-106) addressing greenhouse gas emissions that read like a bad book report and a “dog-ate-my-homework” excuse for doing nothing now. Instead, DOT offers up a broad set of questions asking others for advice on how they might do something, in some future rulemaking, to address climate change.

This is hugely disappointing, considering that anonymous Obama administration officials were bragging about the impact of these reporting requirements to Politico earlier this week. At the rate things are going, half of Florida will be under water before American transportation officials acknowledge that spending billions to build enormous highways serving suburban sprawl is broiling the planet.

Traffic Congestion

There was also some hope that U.S. DOT would reform the way congestion is measured. Current measures of congestion emphasize vehicle delay, which leads to policies that actually promote more driving and more total time spent in cars, as agencies seek to temporarily reduce delay by widening roads. Policies that reduce traffic by improving transit or enabling people to live closer to work don't rate well under this measure of congestion.

Stephen Lee Davis at Transportation for America says the new rule "would still push local communities to waste time and money attempting to build their way out of congestion by using a measure of traffic congestion that’s narrow, limited and woefully out of date."

Cortright says the metric could have been worse, but it's still measuring the wrong things:

The core measure of whether a metropolitan area is making progress in addressing its congestion problem is what USDOT calls “annual hours of excessive delay per capita.” This congestion measure essentially sets a baseline of 35 mph for freeways and 15 mph for other roads. If cars are measured to be traveling more slowly than these speeds, the additional travel time is counted as delay. The measure calls for all delay hours to be summed and then divided by the number of persons living in the urbanized portion of a metropolitan area.

The proposed measure is, in some senses, an improvement over other measures (like the Texas Transportation Institute’s Travel Time Index) that compute delay based on free flow traffic speeds (which in many cases exceed the posted speed limit)...

—This is all about vehicle delay, not personal delay. So a bus with 40 or 50 passengers has its vehicle delay weighted the same amount according to this metric as a single occupancy vehicle.

—This ignores the value of shorter trips. As long as you are traveling faster than 15 miles per hour or 35 on freeways, no matter how long your trip is, the system is deemed to be performing well.

When you get down to it, U.S. DOT's congestion metric belongs to the same line of thinking that led Houston to spend $2.8 billion widening the Katy Freeway to 23 lanes only to see traffic congestion return with a vengeance a few years later. Instead of managing demand for freeways, it will lead to more supply.

California has shifted away from an emphasis on vehicle delay and instead uses "Vehicle Miles Traveled" as a performance measure. VMT measures how much traffic a given project will add to streets and highways. U.S. DOT is nowhere close to such an enlightened position.

Biking and Walking

Caron Whitaker of the League of American Bicyclists also notes another big disappointment.

US DOT releases draft perf. measure for performance of major roads. Doesn't include any measure for bike/ped! @BikeLeague

— Caron Whitaker (@CaronWhitaker) April 19, 2016

What You Can Do

Now for the good news. This process isn't over yet. The rule can be amended -- and anyone can weigh in. The comment period will open Friday and will likely be open through the summer. U.S. DOT needs to be inundated with comments that call for a modern approach to measuring transportation system performance.

It's worth noting that U.S. DOT officials are touting this rule -- which took three years to draft -- as environmental progress. Gregory Nadeau wrote on the Fast Lane Blog:

This is a down payment on the administration’s 21st Century Clean Transportation Plan, a budget proposal to reduce traffic and carbon intensity of the transportation sector.

Let's hold them to that.

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