20020672 Ver 3_Environmental Impact Statement_20131102

Review of Traffic Forecasting:
Monroe Connector/Bypass
Draft Supplemental Final EIS, November 2013
By
David T. Hartgen, Ph.D., P.E.
The Hartgen Group
9700 Research Drive, Suite 150
Charlotte NC 28262
www.hartgengroup.net
December 26, 2013
A Report Prepared for the
Southern Environmental Law Center
Chapel Hill, NC 27516
www.southernenvironment.org
Attachment 1
2

Review of Traffic Forecasting: Monroe Connector/Bypass Draft
Supplemental Final EIS, November 2013

Contents
Summary of Review 2
1. Purpose and Need 4
2. Alternatives Considered 7
3. Improvements to U.S. 74 11
4. Traffic and Population Trends 14
5. Model Calibration 24
6. Induced Travel 28
7. Details of Traffic Forecasts 29
8. Costs and Cost-effectiveness 32
9. External Travel 32
10. Uncertainty 33
Reviewer Qualifications 36

Summary of Review
The Monroe Connector/Bypass is proposed as 4 to 6 lane high-speed connector
that would be sited about 1-2 miles north of present U.S. 74, its primary alternative. It
would begin on U.S. 74 about 1 mile southeast of the present I-485, bypass Monroe, and
re-join U.S. 74 about 1 mile west of Marshville, in eastern Union County. The
approximate length is 19.7 miles. The project is estimated to cost $ 845-$923 million,
funded partially by tolls. Construction would start in October 2014, with a planned
opening in 2018. The following map shows the general location of the proposed road.

Proposed Monroe Connector/Bypass, Union County

3

The Southern Environmental Law Center has asked me to review the Draft
Supplemental Final Environmental Impact Statement (“DSFEIS”) for the Monroe
Connector/Bypass, dated November 2013,1 with particular focus on the traffic forecasts
for the proposed Connector and U.S. 74. This memorandum documents my review of the
methods used in forecasting traffic on the proposed Monroe Connector/Bypass and U.S.
74 as described in the DSFEIS and other documents.

A summary of my primary observations regarding the DSFEIS is as follows:

1. The stated Purpose and Need for the Bypass appear to have been written
narrowly so that only alternatives on new alignment satisfy the stated Purpose
and Need.
2. The alternatives considered appear to be inappropriately biased against
upgrades to U.S. 74.
3. Traffic forecasts for 2035 were not re-computed for some alternatives, thus
possibly over-stating future Bypass traffic and under-stating traffic
improvements for some alternatives. Some of the recently completed and
planned future improvements to U.S. 74 and their effect on traffic forecasts
have not been included in the traffic forecasts, and their effect on Bypass
traffic therefore appears to be under-stated.
4. Traffic growth on U.S. 74 has been flat from 2000 to 2012 and is inconsistent
with population growth trends. The DSFEIS simply ignores these
inconsistencies. Moreover, the forecast of population, which drives the traffic
forecast, is based on a pre-Recession projection; recent population growth has
slowed markedly. Essentially the entire justification for the project rests on
traffic forecasts that ignore 12 years of recent history, recent economic
upheaval, and slower population growth.
5. The regional travel demand model (used to forecast Bypass traffic) and the
traffic operations simulation model (used to study traffic flow on U.S. 74)
both appear to have been insufficiently calibrated.
6. The DSFEIS attempts to addresses the directive of the 4th Circuit Court, but
leaves key questions regarding induced traffic unanswered.
7. Questions remain concerning details of the traffic forecasts. The three key
assumptions of the traffic forecasts (growth of the area population, percentage
diversion, and magnitude of long-distance travel) all appear to be overly
optimistic.
8. Project costs and cost-effectiveness are not sufficiently detailed.
9. External traffic forecasts are undocumented.
10. Inherent uncertainty in traffic forecasts has not been sufficiently considered.

1 NCDOT, Monroe Connector/Bypass Administrative Action, Draft Supplemental Final Environmental
Impact Statement (Nov.13, 2013), available at www.ncdot.gov/projects/monroeconnector/download/.
4
In summary, based on these and other issues described below, my review finds
that the traffic forecasts presented in the DSFEIS are too uncertain and insufficiently
supported to be the basis for decision-making regarding the Monroe Connector/Bypass.

My qualifications for this review include 23 years in transportation planning and
traffic forecasting at New York DOT, 18 years as Professor of Transportation Studies at
UNC Charlotte, and seven years as president of The Hartgen Group, a transportation
planning consultancy. In addition, I am familiar with the U.S. 74 corridor. The
Appendix to this memo provides a brief overview of my qualifications. The remainder of
this memo discusses my findings in more detail.

1. The stated Purpose and Need for the Bypass appears to have been written
narrowly.

According to the DSFEIS, the purpose of the project is to: “improve mobility
and capacity within the project study area by providing a facility for the U.S. 74
corridor from near I-485 in Mecklenburg County to between the towns of Wingate
and Marshville in Union County that allows for high-speed regional travel consistent
with the designations of the North Carolina SHC program and the North Carolina
Intrastate System, while maintaining access to properties along existing U.S. 74.”2
This statement implies that congestion within the study area is long-distance in
character, that a high-speed long-distance facility will increase study-area mobility,
and that the system designations of the Legislature are inviolate. None of these
assumptions are the case. Indeed, the North Carolina General Assembly has recently
(2013) repealed the Intrastate System legislation.

 The DSFEIS focuses on the second and third stated purposes, not the
first.
Focusing on the second and third purposes, and not the first, leads to the
consideration of alternatives that are largely on new alignment, that is, off
existing U.S. 74’s current location. This is inconsistent with the requirements
of the National Environmental Policy Act (“NEPA”) and virtually all of
transportation economics, in which the objective is to evaluate proposed
projects by their benefits versus their costs.

 Congestion on U.S. 74 is largely locally-based, not long-distance.
The DSFEIS says that congestion on U.S. 74 is uniform throughout the day
and by direction: “Based on these field travel time runs, corridor average
travel speeds are approximately 40 mph eastbound and westbound during all
three peak periods.”3 The NCDOT travel time runs and recent INRIX data
show that travel speeds are essentially uniform by direction and AM peak-
lunch-PM peak (DOT 40 mph, INRIX 43-44 mph). This suggests that most of
the traffic on U.S. 74 is locally-based traffic (otherwise the congestion would
be more severe in peaks and nearer to Charlotte, where traffic volumes are

2 DSFEIS at 1-3 (underlining added).
3 Id. at 1-7.
5
higher). A further observation is that there is a reduction in traffic volume on
U.S. 74 between Monroe and the Mecklenburg County line, also suggesting
that the traffic congestion around Monroe is locally-based, and is not headed
to Charlotte. A third point is that the location of the facility, about 2 miles
north of U.S. 74, means that local traffic on U.S. 74 would be unlikely to use
the proposed Bypass as such use would require driving farther and out of the
way for many local short trips, and paying a toll, to save (or perhaps even
lose) travel time by using the Connector.

 Long-distance traffic is low in volume.
Traffic volumes on U.S. 74 fall off sharply at the eastern edge of Monroe,
from about 38,000 ADT4 in the vicinity of the Medical Center, to just 24,000
ADT at eastern edge of the study area, and about 19,000 ADT at Forest Hill
Road, where the proposed Connector would rejoin U.S. 74.5 Although no data
on external traffic (leaving the study area) is provided, probably only 1/3 of
the 19,000 ADT at the study area’s eastern edge is long-distance traffic (the
ADT at the Anson County line, further east, is just 13,000 and some of that is
local). Even if 1/2 of the 19000 ADT were to divert to the Bypass (an
optimistic assumption), the resulting drop in traffic on U.S. 74 (about 8500)
would be about 6-7%, less than the typical daily variation in traffic volume.
Therefore the primary justification for the Bypass, long-distance traffic, is also
relatively low in volume.

 The proposed Bypass is unlikely to reduce congestion on U.S. 74.
The above two factors — most traffic on U.S. 74 is local, and long-distance
traffic is quite low and might not divert — suggest that it is almost entirely
local traffic, not long distance traffic or the lack of a high-speed bypass, that
causes the present congestion on U.S. 74. If most congestion is locally-based,
then provision of a bypass will not alleviate it. It is therefore not likely that
the proposed Connector would significantly reduce congestion on U.S. 74 or
improve mobility in the study area.

 The DSFEIS misrepresents the availability of “sufficient funds.”
The DSFEIS states that “Similar to previous state and local TIPs and the
conclusion in the Final EIS, current fiscally constrained planning documents
do not have sufficient funds available from traditional sources in the
foreseeable future to construct all priority projects in the state.”6 This
statement ignores the Governor’s new Strategic Transportation Investment
(“STI”) Plan (2013), an effort to prioritize and fund highway projects by
worthiness. The statement therefore pre-judges that the Monroe Bypass
would not “pass muster” under the new statewide transportation prioritization
formula, and therefore needs more funds in the form of tolls. But elementary

4 ADT, Average Daily Traffic, is an estimate of traffic volume, in vehicles per day, widely used in
transportation planning.
5 NCDOT, Traffic Count Maps (2012), available at www.ncdot.org.
6 DSFEIS at 1-1 (underlining added).
6
transportation economics teaches that a project’s worthiness should be
determined WITHOUT regard to its funding sources. The Monroe Bypass
should be subjected to the same worthiness criteria as virtually all other
projects in the state, and if found sufficiently worthy it could then be funded
without tolls. But no data on the project’s cost-effectiveness is provided.

The Monroe Connector/Bypass is the only yet-to-be-built road project
presently authorized to be directly funded by the NC General Assembly
through the NC Turnpike Authority; other projects previously permitted (the
Garden Parkway, the Cape Fear Skyway, and the Mid-Currituck Bridge) have
been removed from toll-authorized funding.

 The DSFEIS misstates the end point of the project.
The DSFEIS states that “On the western end, the project would begin at I-485,
another controlled-access facility.”7 This is factually not the case (it ends on
U.S. 74, about 1 mile from the present I-485). Though the Draft recognizes
the facility’s true end point elsewhere, this inaccurate statement at the
beginning of the document, in the summary of its purpose and need, wrongly
implies that the project extends the Interstate system by providing for long-
distance travel, whereas the project’s asserted justification is the reduction of
congestion.

 The DSFEIS inappropriately introduces the issue of fairness.
The DSFEIS states: “Although Union County is the fastest growing county in
the State, it is the only county adjacent to Mecklenburg County that does not
have a high-speed interstate-type facility connecting it to Mecklenburg
County.”8 This statement is factually incorrect. Union County is no longer
the fastest growing county in North Carolina. At least 10 counties, led by
Onslow, reported faster growth rates between 2010 and 2012 than Union
County’s 3.3%, or 1.7/%/year.9 Also, Lancaster County, SC, adjacent to
Mecklenburg County, has no high-speed connection to Mecklenburg County.

The statement further implies wrongly that all “adjacent” counties to
metropolitan areas somehow deserve a high-speed “interstate-type”
connection to the metropolitan county. This criterion is not one used by the
STI program to evaluate projects. The STI criteria require that all highway
projects be evaluated by cost-effectiveness and congestion reduction, among
other factors, but not by geographic proximity or design lever. Further,
NCDOT is already upgrading existing U.S. 74 in Mecklenburg County to
high-speed design standards, and this upgrade could be continued into Union
County. If this criterion were added to the STI, then counties adjacent to

7 Id.
8 Id.
9 US Census, Certified County Population Estimates, 2012, available at
http://www.osbm.state.nc.us/ncosbm/facts_and_figures/socioeconomic_data/population_estimates/county_
estimates.shtm.
7
Wake, Guilford, Forsythe, Cumberland, Buncombe, New Hanover, and
Durham should also have their connections upgraded raised to “interstate-
type.”

 Neither beach access nor weekend traffic is mentioned in the document.
It is commonly thought that travel times from Charlotte to the North Carolina
beaches are hampered by congestion on U.S. 74, and that as a result, beach-
going weekend traffic is often stuck in congestion between Charlotte and
Monroe. Yet the DSFEIS does not study, review or even mention local or
long-distance weekend traffic.10 The proposed Monroe Bypass might serve an
additional unmentioned purpose of providing faster access across Union
County for Charlotte-area beach-goers — in other words, a major
unmentioned beneficiary of the Bypass would be the occasional (largely
weekend) users from an adjacent county! If these factors are part of the
project’s justification, they must be spelled out and evaluated on their merits
using appropriate traffic analysis methods. This oversight demonstrates either
unfamiliarity with an unstated key “purpose and need” of the project, or
(worse) implies that stating this additional purpose would reduce the project’s
political support.

2. The alternatives considered appear to be inappropriately biased against U.S. 74
upgrades.

NEPA requires that the alternatives considered for road projects include the “no-
build” alternative, a TSM/TDM alternative, and a variety of “build” alternatives.
While the ranges of alternatives to be considered vary widely from project to project,
the intent of NEPA is to ensure that a wide range is considered. Alternatives found to
be viable must then be evaluated to equivalent levels of detail in terms of benefits,
impacts and costs. This does not appear to be the case for the Monroe
Connector/Bypass.

 The DSFEIS limits the alternatives to those that were judged to fit a
biased Purpose and Need.
The DSFEIS describes the three-stage winnowing process used to identify
feasible alternatives.11 In the first step, a wide range of alternatives were
considered, including:
 No-Build or No-Action Alternative
 Transportation Demand Management Alternative
 Transportation System Management Alternative
 Mass Transit and Multi-Modal Alternatives
 “Build” Alternatives, including Upgrading Existing Roadways and
New Location Alternatives[12]

10 Traffic counts, speed runs and traffic forecasts in the study are for weekday traffic only.
11 DSFEIS at 2-2.
12 Id.
8
The DSFEIS then states that three criteria, based on the purpose and need,
were applied to each alternative:
 Does the alternative address the need to enhance mobility and
increase capacity in the U.S. 74 corridor?
 Is the alternative consistent with the NC Strategic Highway Corridor
program and the NC Intrastate System (i.e. does it allow for high-
speed regional travel)?
 Does the alternative maintain access to properties along existing U.S.
74?[13]
But as detailed above, because the stated “Purpose and Need” is biased toward
inappropriate criteria, the alternatives developed to meet those criteria are not
judged on the right set of criteria.

 Elimination of “frontage road” and “not maintaining property access”
alternatives arbitrarily restricts the options.
The DSFEIS eliminates several alternatives based on their asserted failure to
provide access to existing U.S. 74 properties. It notes that “However, as part
of the purpose and need criteria for the project, there is a need to maintain
access to existing properties along existing U.S. 74, so frontage roads would
be needed for the Upgrade Existing U.S. 74 Alternatives under either a toll or
non-toll scenario to provide property access.”14 But the alternatives
apparently do not include various “frontage road” options, either separately or
in combination with other features such as Superstreets,15 reversible lanes, or
signal optimization. Essentially, by restricting the review to those alternatives
that are asserted to strictly meet the biased Purpose and Need, the DSFEIS
arbitrarily eliminates a wide range of other feasible options. Partial frontage
roads for some sections and not others are also not explored fully. Partial
freeway upgrades along with partial upgraded arterial treatment is another
option that is clearly possible but is not explored. Neither do the alternatives
apparently consider options that take a minimal, or minor, number of existing
properties along existing U.S. 74, while the proposed Bypass would take 95
households, 47 businesses and 499 acres of active agricultural land.16 Failure
to adequately consider “on-current-alignment” options is also surprising as
upgrades to U.S. 74 in Mecklenburg County include on-current-alignment
upgrades. If NCDOT could pursue this alternative to improve U.S. 74 in one
county, then why not in the adjacent county?

 Tolling availability further restricts the options to those off U.S. 74.
Tolling options are not permitted in North Carolina without the express
approval of the Legislature. As of this writing, only one un-built road, the
Monroe Connector/Bypass, is presently approved for tolling. The presence of

13 Id. at p. 2-3 (underlining added).
14 Id. at 2-4.
15 So-called “Superstreets” are arterials that are upgraded for higher speeds and flows by a variety of
engineering/designs that restrict some movements and limit some conflicts.
16 DSFEIS at 3-4 to 3-5.
9
the tolling option for the Monroe Connector/Bypass, not permitted for other
projects in the state, biases the review of alternatives towards those that rely
on additional traffic-generated revenue, rather than on the usual funding
options. Although the DSFEIS states that “the tolling aspect of the project
had no influence on the concepts identified for detailed study and little
influence on the roadway preliminary design,”17 the screening process
nevertheless eliminated all options except tolling options: “All [25] PSAs
[preliminary screening alternatives] assumed that toll collection would be
made using an open road tolling technology, which allows for tolls to be
collected at highway speeds and eliminates the need for conventional toll
plazas.”18 This is either a remarkable coincidence, or a result of a process that
pre-judges the range of feasible options.

 The DSFEIS ignores MAP-21’s focus on projects “within operational
right-of-way.”
The new federal highway act, MAP-21, passed in August 2012, specifically
streamlines the environmental review process for projects “within the
operational right-of-way.”19 This new law, not mentioned in the DSFEIS, is
intended to rapidly progress projects that have minimal or little environment
impact, speeding their construction.20 By ignoring this opportunity, the
DSFEIS eliminates a wide variety of options that could be progressed faster,
and possibly cheaper, than the proposed Monroe Connector/Bypass.

 Other alternatives, particularly upgrading U.S. 74 using “Superstreets,”
providing frontage roads while upgrading U.S. 74 to freeway status,
and/or consolidating intersections should have been evaluated.
The DSFEIS discusses the effectiveness of one lately-added alternative, “TSM
Alternative Concept 2” that would improve traffic flow on U.S. 74 over the
short term (to 2015).21 The DSFEIS concludes that “by implementing the
improvements listed in Table 3-5 of the Final EIS, an overall Level-of-
Service[22] D in 2015 could be attained at the intersections along the U.S. 74
study corridor, except for the intersection of U.S. 74 at Rocky River Road (SR

17 Id. at 2-4.
18 Id. at 2-6.
19 Public Law No. 112-141, 1316.
20 The Moving Ahead for Progress in the 21st Century Act (“MAP–21,” PL112–141, 126 Stat. 405) was
signed into law on July 6, 2012. Sections 1316 and 1317 require the Secretary of Transportation to
promulgate regulations designating two types of actions as categorically excluded under 23 C.F.R.
771.117(c) from the requirement under 40 C.F.R. 1508.4 to prepare an environmental assessment (“EA”) or
environmental impact statement (“EIS”): (1) Any project (as defined in 23 U.S.C. 101(a)) within an
existing operational right-of-way. Proposed rules implementing this requirement were issued on Feb 28,
2013 (FR 78:40, p. 13609 ff).
21 DSFEIS at 2-9.
22 Level of service (LOS) is a term referring to the quality of operational service provided to road users,
given traffic, design and environmental circumstances. It varies from LOS A (free flow) to LOS F (stop-
and-go traffic). LOS D (moderate congestion) is the generally accepted NCDOT level that balances cost
and motorist delay.
10
1514).”23 The DSFEIS relies on 2007 estimates projecting that implementing
these improvements would result in an average 2015 peak travel speed of
between 29-30 mph.24 However, after implementing just some of these
solutions, NCDOT has observed average peak travel speeds well above these
projections, as high as 45 mph.25 This finding is then dismissed because the
alternative does not meet the need for “high speed travel” through the
corridor, even though it is estimated to result in improved operation (LOS D)
on U.S. 74.

The DSFEIS also states that assuming the 2035 traffic volumes, the option is
not feasible: “A comparison of the year 2015 traffic volumes used in the U.S.
74 Corridor Study to the year 2035 No-Build volumes developed in Revised
Monroe Connector/Bypass No-Build Traffic Forecast Memo (HNTB, March
2010), shows that the volumes in 2035 along U.S. 74 would generally be
significantly higher. Therefore, the levels of service at the intersections in
2035 would be expected to degrade to below LOS D and travel speeds based
on the computer model also would decrease.”26 However, given the admitted
success of the recent improvements in improving LOS, the highly uncertain
traffic forecasts (see below) and the flat recent traffic counts (discussed
below), this is clearly a premature conclusion.

 An additional option, widening U.S. 74 without tolls, was also eliminated
prematurely.
The DSFEIS also notes that based on questions raised by the Corps of
Engineers, the option of an “on-current location” was revisited. The review
concluded that “[I]n the design year 2035, U.S. 74 under all four scenarios is
expected to exceed LOS D in the majority of the corridor…. The Superstreet
6-Lane scenario option provided the highest corridor capacity compared to
the other three scenarios.”27 This statement finds that U.S. 74’s level of
service will be unsatisfactory (LOS D is the NCDOT standard for operation)
with any of these options, but (in apparent conflict with its own
recommendation for a Bypass) NCDOT has moved to implement a
“Superstreet” improvement along a 2.7 mile section of the existing U.S. 74
through Indian Trail.28 Therefore it is unclear, to say the least, why a
“Superstreet” option was eliminated from the feasible alternatives. This
appears to be a violation of NEPA which requires comparable evaluation of
viable options. At the least, prudence would dictate that the “Superstreet”
option now being implemented on a portion of U.S. 74 should be reviewed for
effectiveness, and additional Superstreet improvements be considered in

23 DSFEIS at 2-9.
24 See id.
25 Id. at 1-7 – 1-8.
26 Id. at 2-9.
27 Id. at 2-10.
28 Id. at 2-11.
11
combination with other improvements in the corridor, BEFORE a decision to
build the Bypass is made.

 No discussion of “flexible work schedules” or “work-at-home” as an
alternative.
Even though NCDOT’s own data show no large variations in travel time by
time of day or direction, and that most of the traffic using the facility is local,
there is no discussion of other alternatives such as staggered work schedules,
increased work-at-home, or other similar options for reducing traffic loads at
specific intersections. The percentage of Union County residents working at
home doubled from 3.4% in 2000, to 6.9% in 2012.29 The TDM alternatives
considered did not significantly explore this issue.

 The DSFEIS does not contain key comparative data for all alternatives.
Most EISs contain detailed comparative data, by impact, for all viable
alternatives, INCLUDING the no-build and other “improve existing road”
alternatives. This information is missing from the DSFEIS, raising the
question of whether it violates NEPA requirements that all alternatives be
investigated and described to an equivalent level of detail.

3. Travel time improvements on U.S. 74 and their effect on traffic forecasts for the
Monroe Connector/Bypass appear to be under-estimated.

For a variety of reasons detailed below, the impacts of improvements to U.S. 74
on traffic flow appear to have been under-estimated. This likely over-states the
expected diversion to a future Bypass.

 The DSFEIS uses the wrong speed criterion for setting road performance.
There is no requirement that Interstate, NCSTI or STRAHNET routes have
operational travel speeds that are equal to the posted speeds.30 If that were the
case then virtually all of state-owned urban arterials in North Carolina would
need upgrades, widenings or bypasses. NCDOT standards for LOS D
(moderate congestion) typically have traffic operating speeds 5-15 miles
below the posted speed. Even if speeds are accepted for a criterion, the
standard for speed study is the 85th percentile, not the average speed. As,
according to the INRIX data, the reported average (close to 50th percentile)
operating speed on U.S. 74 is 44 mph, using the 85th percentile would raise
the current operating speeds on U.S. 74 even further, probably to the 48-50
mph range. This reduces the need for the project and the potential time
savings.

29 US Census, at
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_12_5YR_B08101
&prodType=table, for 2012;
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_00_SF3_P030&pr
odType=table, for 2000.
30 DSFEIS at 1-6.
12

 Possible misuse of speed measurement data.
The 2013 INRIX data show an average travel speed through the corridor of 44
mph, 10% (4 mph) higher than the NCDOT’s travel time runs.31 In other
words, drivers now are averaging faster speeds than the DOT speed-run tests.
This 10% difference is so large that it calls into question the accuracy of the
travel time savings from the model.32 Later it is noted that the speed runs
appear to be based on just three runs in each direction/time period33 which is a
very small sample. The INRIX data, on the other hand, are based on observed
speeds of hundreds (perhaps thousands) of actual drivers over a 2-month
period, 24 hours a day, Tues-Thurs.34 This is a huge amount of data that is a
much more realistic description of actual corridor operation than just a few
speed runs. Therefore, the INRIX actual operating speeds, not the travel time
runs or posted speeds, should be used as the basis for the traffic forecasts on
U.S. 74. Without this correction, estimates of future traffic speeds on U.S. 74
(build and no-build) will continue to be too low, and diversion to the proposed
Bypass will continue to be over-stated.

 The suggested diversion to the Bypass (40-50%) would require a very
high value of time.
Traffic diversion (assignment) models operate by assigning traffic to the path
with the shortest “generalized cost,” considering travel time, reliability,
congestion, and tolls. The fundamental principle underlying most modeling
systems is that users choose that path which has the lowest generalized cost,
spreading out by route (and time-of-day in advanced models) such that no
traveler can improve his generalized cost by changing paths.35 To estimate
total generalized cost, tolls must be converted into time units using a traveler
value of time, which is generally assumed to vary by location, trip purpose
and vehicle class. Values of time vary by region, but most value-of-time
studies put it at about ½ the average wage rate, or about $9/hr. That is about
½ the prevailing median wage rate for Union County, $18.48/hr.36

Using the reported INRIX actual speeds for U.S. 74, the average 44-mph
travel time through the 19.7-mile U.S. 74 section (between the approximate
end points of the proposed Bypass) is now about 26.9 minutes, and at 65 mph
the average travel time between the same points using the Bypass, would be

31 Id.
32 Id. at 1-7.
33 The data are for March 19-21, 2013. See Memorandum from Bradley Reynolds, HNTB, to Jennifer
Harris, NCDOT, RE: U.S. 74 Travel Time Comparison (April 18, 2013, updated Oct. 24, 2013).
34 DSFEIS at 1-6.
35 In traffic modeling this is referred to as “user equilibrium,” or “stochastic user equilibrium” if
probabilistic route choices are made. The Metrolina Regional Model used in this study is operated with
TransCAD software, which is a quite sophisticated package, but many of its advanced features appear not
to have been used in the study.
36 US Department of Commerce, Southeast Division, County employment and wages in North Carolina, 4th
Quarter 2012, available at http://www.bls.gov/ro4/qcewnc.htm. Calculated as $739 per week/40 hrs/week.
13
18.2 minutes.37 To be worth paying the proposed $2.58 average toll, the
average savings in time (8.7 minutes) would have to be worth about
$17.80/hour.38 This is a high value of time for traffic modeling, almost twice
the commonly used rate, and about twice the value of time that the NCDOT
found in its own stated preference survey. This means that, if local residents
value their travel time at less than $17.80/hour, the traffic estimate for the
Bypass is likely to be significantly overstated. Another implication is that
Bypass use might be infrequent rather than regular, for trips when time is
valued highly, but not for most trips.

 The DSFEIS downplays the effectiveness of prior and planned actions on
U.S. 74.
The DSFEIS notes that some improvements to U.S. 74 have been
implemented.39 But these improvements have not been incorporated into the
2035 traffic forecasts, which were created in 2007 and have not been updated
in the DSFEIS. In fact these improvements post-date the 2035 forecasts —
occurring mostly between 2010 and the present — and so have of course not
been included. Additionally, the 2035 forecasts do not factor in additional
improvements such as the four Superstreets that are now planned in the next
couple of years. It is likely that the improvements made so far helped to
improve the current operating speeds in the 44-mph range, given that traffic
volumes have not increased and INRIX speeds show an increase over time.40
Additional future improvements (e.g. partial Superstreet treatment, shutting
off some access, better signal timing, or even upgrading more of U.S. 74 to
freeway status) might also be equally effective. But at the very least, the
planned improvements should be coded into the regional network and used as
the basis for all forecasts.

 An inappropriate traffic forecast was used for the operations simulation
model.
Instead of using just one traffic forecast predicted to use U.S. 74 in the local
simulation model (SIMTraffic, which estimates future driving speeds based on
a forecast of traffic), the consultant should have also tested the operation of
U.S. 74 with lower more-realistic future traffic volumes, as discussed below.

 Inconsistent traffic forecasts for U.S. 74 WEST of the project.
The DSFEIS asserts that “Year 2035 traffic volumes on U.S. 74 west of I-485
are projected to be lower with the proposed project than under the No-Build
alternative.”41 The difference is about 7% lower, quite a large amount. This

37 19.7 miles*60 min/hr/44 miles/hr = 26.9 min; 19.7*60/65 = 18.2 minutes.
38 $2.58*60 min/hour/8.7 minutes = $17.80. The value of time would have to be even higher for shorter
trips that have to go out-of-the-way to use the Bypass, but might be lower accounting for congestion on
U.S. 74.
39 DSFEIS at 2-11.
40 Id. at 1-6.
41 DSFEIS, Appendix F, Errata (underlining added).
14
finding is inconsistent with traffic modeling theory which predicts that
improvements in travel time caused by new roads will also result in
INCREASED traffic on major feeder roads leading to the project, such as U.S.
74 just west of I-485. The NCDOT team found a similar inconsistency in
reviewing the Wilbur Smith forecasts made in 2008.42 No explanation is
given for this new finding, but it may be due to the hidden assumptions
regarding induced land use or trip distribution.

4. Traffic growth on U.S. 74 has been flat from 2000 to 2012, and is inconsistent
with population growth.

Two central issues regarding the need for the Bypass is whether the traffic on U.S.
74 has been growing historically, and is likely to continue to grow in the future.
Careful review of the statistics for growth and traffic in the corridor suggest that
neither is the case.

 The DSFEIS reports incorrect population growth statistics for Union
County and selectively reports Union County growth rates. The DSFEIS
asserts that Union County is the fastest growing county in the state: 49% from
2000 to 2010, or 4.9%/year.43 This is factually incorrect. The growth rate for
Union County for 2000-2010 was 62.8%,44 but the growth rate for the study
area was 49.3%.45 Further, Union County is no longer the fastest growing
North Carolina county: As noted above, at least 10 other NC counties have
registered more rapid growth from 2010 to 2012, while the Union County’s
growth rate has fallen sharply, to just 1.7%/year.46 It is not uncommon for
counties near larger metropolitan areas to experience high “surges” of growth
as the metropolitan county growth spreads out, then to decline in growth rate
as growth moves elsewhere.

The DSFEIS notes that “According to the CRTPO [Charlotte area] 2035
Long-range Transportation Plan, the southern and eastern portions of
Mecklenburg County, which is the area along the Union County line, is
expected to be one of the most rapidly growing areas in the region.”47 But the
DSFEIS fails to mention that almost half of Union County’s growth has been
in the southwestern edge of the county, substantially south of U.S. 74 and
mostly outside of the Bypass corridor.48 The following table demonstrates this
growth pattern, using the DSFEIS data from Appendix D (Updated Census
Tables).

42 C. Scheffler, Monroe Bypass no-build traffic forecast summary, interoffice memo to Spencer Franklin,
NCTA (May 6, 2013).
43 DSFEIS at 1-2.
44 2010 US Census, available at www.census.gov.
45 DSFEIS at 4-1.
46 US Census, population counts, 2012. (207,896-201,294)/201,294/2 = 1.7%/year.
47 DSFEIS at 1-1.
48 US Census, 2010, and DSFEIS, Appendix D, Updated Census Tables.
15

Population Growth, 2000-2010, Union County and Study Area49

Geographic area

2000
Population

2010
Population

Difference
Percent
Change
from
2000-10
Union County

123,677 201,292 77,615 62.8
DSA-Union Co. part

66,603 102,357 35,745 53.7
DSA-Mecklenburg Co.
part

13,867 17,746 3,879 28.0
Total DSA

80,470 120,103 39,633 49.3
Union NON-DSA part

43,207 81,189 37,982 87.9

The table shows that the portion of Union County outside the DSA actually
grew at almost twice the growth rate of the study area, almost 90% in just 10
years. The following figure (from the DSFEIS) shows the present Union
County road system and the proposed future land use. Note that the growth in
the southwest corner, between Indian Trail and Marvin, is on the south side of
U.S. 74, and is mostly OUTSIDE the Bypass study area.

49 DSFEIS at Appendix D (Updated Census Tables).
16

Most of this growth took place in the area south of Ballantyne (in
Mecklenburg County) over 10 miles from the proposed Bypass on the south
side of U.S. 74, and therefore would not be able to even use the Bypass.
Essentially the DSFEIS’ own data shows that recent growth has been most
rapid in areas NOT served by the proposed Bypass. Therefore the rapid
growth rate of Union County between 2000 and 2010, even if reported
correctly, is irrelevant for evaluating the need for the project.

 Union County out-of-county commuting shares are declining, not
increasing.
The DSFEIS states that in 2006 about 61% of Union County workers
commuted outside of the County, but that in a more recent census survey
(2006-09), 50% of workers commuted outside.50 Such wild swings in such a
short time question the data’s validity, but even if true it shows declining
dependence, not increasing dependence, of Union County on adjacent-county
jobs.

 The DSFEIS selectively reports trends in commuting time.
The DSFEIS states that commute times for Union County residents average
27.8 minutes, the highest of the region’s counties, implying that the Bypass

50 DSFIES at 1-4.
17
would somehow reduce them.51 The DSFEIS does NOT mention, however,
that commute times are improving, not worsening, for all counties in the
region, and that from 2000 to 2010 Union county’s average commute time fell
from 29.0 minutes to 27.8 minutes, the largest drop of the region’s counties.52
Union County commute times are improving, not worsening, and within-
county employment is increasing, decreasing the share of long-distance
commuting.

 Recent traffic growth on U.S. 74 has been flat.
In spite of Union County’s now-slowing population growth since 2000, traffic
on U.S. 74 has not increased substantially since 2000. The following table
shows the NCDOT traffic counts for various sections of U.S. 74, and the
DSFEIS forecast volumes.

Average Daily Traffic on U.S. 74 Parallel to the Proposed Monroe Bypass

Historical

DSFEIS Forecast

Count Location

2000

2005

2010

2012

12-year
Annual
Percent
Change

Raw
Model
2030
No
Build

Raw
Model
2035
No
Build*

Estimated
Volume
2035
No Build*

2035
Annual
Percent
Change,
from
2012

Meck.-Union Line 56000 58000 5400057000 0.15 70300 101600 89000 2.4
NW of Monroe 48000 48000 4600050000 0.35 40000 66200 65000 1.3
East of Monroe 26000 27000 2400027000 0.32 32200 41500 60600 5.4
W of Marshville 20000 21000 1700019000 -0.4 23000 21000 31600 2.9
Anson-Union Line 15000 15000 1400013000 -1.1 - -

*Source: NCDOT, Traffic Count Maps, and DSFEIS, Traffic Forecast Summary,
November 8, 2013, Appendix G.53

At the Mecklenburg-Union line, just west of the project end, the traffic has
grown just 0.15%/year (1.8% in 12 years), and has actually declined since
2005. Near Monroe, growth has been modest, about 0.4%/year. At the
eastern edge of the project, traffic volumes are much lower and have declined

51 Michael Baker Consultants, Monroe Connector/Bypass, Union County Growth Factors Technical
Report, at 16 (November 2013).
52 US Census, 2000 and 2010.
53 DSFEIS at G-21– G-23.
18
not increased, since 2000. The DSFEIS notes that its own analysis of traffic
counts from 2007 to 2012 also showed “zero change,”54 but then the DSFEIS
simply ignores this data and asserts that “Based on 2008 and 2035 No-Build
traffic forecasts, (HNTB, March 2010), average volumes along the U.S. 74
corridor are projected to increase approximately 34 percent.”55 So the whole
need for the project simply ignores the last 12 years of history regarding
traffic trends on U.S. 74.

In Appendix G to the DSFEIS, the data show projected 2035 traffic volumes
on U.S. 74 for the “no-build” alternative. The implied percent changes from
current volumes range from 1.3 to 5.4% per year are 5-10 times faster than the
recent 12-year history. Nowhere in the document is it explained how the
traffic will grow 34% in 23 years when the past 12 years have shown “zero
change” in traffic.56 One might argue that, yes traffic growth has been flat
recently, but as the Recession ends it will accelerate. This argument fails to
note that traffic has been flat since 2000, BEFORE the Recession. Failure to
justify this highly optimistic “kink” in the traffic forecast and failure to
consider recent traffic trends, while knowing that recent evidence indicates a
huge change in prior trends, are serious oversights.

A serious inconsistency in the table is the magnitude of the traffic forecasts
themselves. NCDOT’s rated LOS D capacity of 6-lane arterials is about
55,000 ADT,57 but the forecast for U.S. 74 at the Mecklenburg County line is
89,000 ADT, 60% higher than a 6-lane “no-build” could carry. Similarly, for
the 4-lane section northwest of Monroe, the rated capacity is about 40,500
ADT,58 but the forecast for the “no build” is 61% higher, 65,000 ADT. As the
congestion-decay equations of traffic forecasting models generally limit flow
rates to the rated capacity (they spread out the traffic to “fit” within the road
system), it is not clear how these “no-build” forecasts for U.S. 74 could be
60% higher than the rated capacities.

Another anomaly in the table is the large differences between the 2035 “raw
volume” (model output) forecasts and the estimated 2035 volumes. These
differences are quite large, and are 46-50% higher for volumes east of
Monroe. Although the DSFEIS cautions about the use of raw volumes
directly in forecasting, the process used to estimate the estimated volumes is
not adequately described. Differences of this magnitude, particularly at the
eastern edge of the project where long-distance travel would be entering the
region, and particularly on the high side (favoring the Bypass) need to be fully
justified.

54 Id. at 4-20.
55 Id. at 1-13.
56 Id. at G-9.
57 NCDOT, Transportation Planning Branch, LOS D [traffic volume] standards for systems planning
(October 14, 2011). Calculated for “boulevards,” piedmont area, suburban location, 45 mph.
58 Id.
19

 Inconsistent historical growth data for population and traffic.
A fundamental inconsistency in the DSFEIS is the apparent inconsistency
between the population growth and the corridor traffic growth. The recent
history of population growth in the region is shown in the following table:

Population Growth, 2000-2010*

Area

2000

2010

Percent
Change
2000-10

Percent
Change/year

Union County

123,677

201,292

62.8

6.3

Mecklenburg
County

695,454

919,628

32.2

3.2

Project Study Area

80,470

120,103

49.3

4.9

*Source DSFEIS, Appendix D, Updated Census Tables.

All of these population growth rates have been much faster, per year, than the
traffic growth rates shown above, about ten times the traffic growth rates. The
last item, the population of the study area, is referred to several times as a key
historical justification for the project’s need. Yet, this raises a fundamental
question: How can the traffic growth on U.S. 74 be “zero growth” when
Union County and study area population is growing so fast?

This inconsistency is neither identified nor explained in the DSFEIS. It has a
number of possible explanations, for instance:
1. The current traffic congestion on U.S. 74 has actually slowed its
growth; with more capacity, it would have grown more.
2. The Recession slowed the traffic growth, but not the population
growth.
3. Population growth is largely in areas south and west of U.S. 74, near
the Mecklenburg line, and thus does not use U.S. 74. (This is
suggested by the sub-area discussion above).
4. Population growth is largely locally-based and does not use regional
highways.
5. Traffic data is misestimated, or population data is miscounted.
20
6. The traffic model used for forecasting does not capture the reasons for
travel behavior.
It is not appropriate for us here to determine the reasons for this discrepancy.
Nevertheless, because the discrepancy impacts the validity of the traffic
forecasts (see discussion below) it must be researched and then incorporated
into the Purpose and Need for the project.

 The population forecasts used to forecast traffic are probably
significantly over-stated.
The process used to estimate future traffic is described in the DSFEIS59 and
can be summarized as follows:

1. A Charlotte-region population forecast is estimated by reviewing US
growth.60
2. County growth to each of 35 counties/sub-areas in the region is
allocated from the regional control total, using statistical relationships
from 227 counties in 29 regions nationwide.61
3. County population growth and “population-chasing” employment is
then allocated to traffic analysis zones (“TAZs”) within counties, using
travel time to employment and other factors.62
4. Non-population-chasing employment is estimated using expert
review.63
5. “Induced” growth due to the presence of the Bypass is estimated by a
variety of methods.64
6. TAZ-level population and employment forecasts, and non-residential
growth (in acres of development) are then converted to trip ends, by
purpose, and then to productions and attractions.65
7. Although not explicitly discussed, external travel (leaving and entering
the study area) is presumably estimated separately.66
8. Trips between origins and destinations are then estimated, by purpose,
and external travel origins and destination are added.67
9. O-D pair trip flows, by time of day, are then assigned to the network
(“build” or “no-build”), adjusting for capacity, toll rates, and value-of-
time.68

59 DSFEIS Section 2 (Alternatives Considered) and Appendix G (Traffic Forecast Summary)
60 DSFEIS at 2-15, 4-25; see also Hammer, Demographic and Economic Forecasts for the Charlotte Region
(2003).
61 DSFEIS at 2-15, 4-25; see also Hammer, Demographic and Economic Forecasts for the Charlotte Region
(2003).
62 DSFEIS at 2-15, 4-25.
63 Id. at 2-15, 4-25.
64 Id. at 2-17–2-18, 4-27, 4-29.
65 Id. at 2-15, 4-25 – 4-27.
66 There is no reference to external travel in any of the documents we reviewed.
67 DSFEIS at 2-15; Comprehensive Traffic & Revenue Study (October 2010) at Chapter 3.
68 Id. at 2-15; Comprehensive Traffic & Revenue Study (October 2010) at Chapter 3.
21
10. The raw volumes (direct from the model) are then adjusted further for
local access and “balance.”69

The process begins with estimates of likely population growth for the region
and its counties. Specifically, a Charlotte-region population forecast is
estimated by reviewing US growth, and then assigning portions of that growth
to each of the major regions of the US.70 In the next step, the total regional
growth is then allocated to 35 local counties/sub-areas using historical
statistical relationships from 227 counties in 29 regions nationwide.71 The
DSFEIS reviewed this forecast, prepared in 2003, finding it in substantial
agreement with the 2010 Census estimate for Union County.72 It then went
further, suggesting that the Hammer forecasts are valid for the future because:
“Put more succinctly: ‘Why would Union County have such robust growth in
the absence of new transportation infrastructure?’ The short answer is that
the factors that caused Union County to experience higher growth than any
other regional county since 1990 are still in place and are likely to continue to
result in higher than average growth.”73 The Baker assessment then goes
even further, putting the 2030 population forecasts for Union County
(adjusted for “reconciliation”) near the upper range of the Hammer
forecasts.74

While the Hammer study appeared to accurately predict the 2010 Census
estimate of population, its accuracy for future years is questionable. The
Hammer study, prepared in 2003, made the following critical (and as it turns
out, wrong) assumptions:
1. The US will continue to grow as in the past. The Hammer study
essentially trends the US population and economic activity forward.
But the Recession of 2008-12 significantly slowed both in-migration
and US growth, employment was cut by over 4 million, and recent US
population increases (births – deaths + net in-migration) have slowed
too. The key relationship between population and employment
(percent of population that is employed) was also weakened. The
current growth rates for the US are now 1/3-1/2 what was estimated
just 10 years ago, and the employment/population ratio is the lowest in
50 years. Further, virtually all of the 2000-2010 Census population
growth for Union County was already “in place” by 2009, when the

69 Id. at 2-15 to 2-16.
70 Id. at 2-15, 4-25; see also Hammer, Demographic and Economic Forecasts for the Charlotte Region
(2003).
71 DSFEIS at 2-15, 4-25; Indirect and Cumulative Effects Quantitative Effects Quantitative Analysis
Update (November 2013) at 32; see also Hammer, Demographic and Economic Forecasts for the Charlotte
Region (2003).
72 Michael Baker Consultants, Monroe Connector/Bypass, Union County Growth Factors Technical Report
(November 2013).
73 Id. at 5.
74 Id.
22
Recession hit hard, and so the 2010 census estimate was largely
unaffected by the Recession. But as noted above, the recent (2010-12
population growth rate for Union County has been much slower, just
1.7%/year.
2. The Charlotte region will continue to excel relative to other regions.
The Hammer study assumed that the Charlotte region will continue to
exceed the national growth rates.75 But North Carolina and the
Charlotte region was very hard-hit in the Recession, with large banks
and other employers shedding jobs inordinately, and unemployment
remains significantly above the US and NC levels. This effect has
slowed the local employment growth to a crawl. This “inconvenient
truth” is ignored by the Baker review.
3. Union County will attract a relatively large share of regional growth.
The Hammer study allocated growth to the region’s 35 county and
sub-county areas based on employment-population-economy
relationships developed from around the US.76 But in the 2000’s, most
of the growth in Union County was driven not by local county
economic activity but by proximity to Charlotte, particularly in the
Ballantyne area, which is not even in the study area. Essentially,
Union County’s growth in population was a “population” boom near
to another county’s “job” boom, which has now slowed. The
Hammer study and the recent Baker review do not discuss the location
of that growth within Union County, and thus overlook the fact that the
most of the Union County growth has been outside of the Bypass study
area.

Dr. Hammer’s estimates were reviewed by the UNC Kenan School, which
found them to be too high. The Kenan review recommended an 8.7%
reduction in the 2030 corridor growth for “national” trends, and a re-allocation
of some growth within the County to zones in the Bypass corridor.77
Therefore, Dr. Hammer’s forecast of population and employment for Union
County is likely to be significantly over-stated, as are Baker forecasts made
from it.

Of course, in 2003-04 Dr. Hammer could not have foreseen the 2008-12
Recession or its disproportionate impact on banking sector employment. That
is exactly the point: If one is to believe Dr. Hammer’s 2030 forecast now, one
must now assume an equally unlikely upward “turn-around kink” in
population for the region and particularly for Union County. To reach the
projected 337,000 population by 2030 from its current (2012) level of
208,000, Union County would have to average 3.4% growth annually, twice
its recent growth rate of 1.7%. Assuming this would mean justifying the
Bypass on an unsupported future turn-around in growth for the Charlotte

75 Hammer, Demographic and Economic Forecasts for the Charlotte Region (2003), at 6.
76 Id. at 6-7.
77 Quantitative ICE Report at 43.
23
region, and a return to a rapid growth spurt for Union County, events as
unlikely as was the recent Recession.

 The Hammer population forecasts are then used to forecast traffic.
Unfortunately from a modeling perspective, Dr. Hammer’s assumptions about
future Union County population growth are also used as the basis for the sub-
area allocation to zones (the Smith study and refinements to it). The Smith
study is described as allocating the county-level population and “population-
chasing employment” control totals to TAZs based on vacant residential acres
and travel time to employment.78 The DSFEIS apparently continues to use the
county-level control totals in making these TAZ allocations.79 In other words,
the higher-level population forecasts are then used to estimate zonal
population and employment, which are then used for estimating local traffic
growth. This means that, if the Hammer-based forecasts of population growth
by county are high, then the TAZ forecasts will be high in the same
proportion.

 The Smith re-study incredulously found no impact of the Bypass on
population growth.
According to the DSFEIS, the original Smith study completed in 2004,
allocated county-level control totals to TAZs using vacant residential acres
and travel time to employment.80 In 2012 Mr. Smith re-analyzed the impact
of the Bypass on population and “population-chasing employment,” and found
no change in growth forecasts for any of the TAZs.81 This result is not
believable given the projected change in access that the proposed Bypass
would create, particularly in those TAZs both near the Bypass and close to the
Mecklenburg line. This suggests that the original allocations prepared by
Smith did not consider the key factors that affect regional population growth.
For example, the Smith study did not consider that the whole study area
growth might slow if U.S. 74 became congested to the extent predicted
elsewhere in this DSFEIS.

 The revised DSFEIS shows a modest impact of the Monroe Bypass on
induced growth.
Later in the discussion, the Michael Baker team indicated dissatisfaction with
the Smith study on the precisely those grounds — that it did not show a
difference in development for the “build” vs. the “no build” forecast.82 Among
the obvious factors that might have been included in a more careful
assessment of potential growth would be school quality, sewer and water
availability, zoning density restrictions, improved road access, rising

78 DSFEIS at 2-15, 4-25.
79 Id. at 2-15, 4-25.
80 DSFEIS, Indirect and Cumulative Effects Quantitative Effects Quantitative Analysis Update (Nov.
2013).
81 Id. at 41.
82 Id. at p. 52.
24
congestion on existing roads, crime rates, average housing values and
neighborhood incomes, provisions for and distance to shopping and retail, etc.
The Baker study then uses other methods to estimate induced residential
growth (about 1%). A method developed by this author (Hartgen) in 2000 is
also used to estimate induced commercial growth at Bypass interchanges.83
Other methods are also used to estimate the impact of the Bypass on
industrial, transportation, and other uses. Overall, the review found modest
estimates of induced growth, about 3.4% overall (a difference of 3200 acres,
“build” vs. “no-build” (128,200 vs. 125,000), from a base of 95,200 acres of
development.84 The report does not indicate what markets this “non-
residential” growth would serve, but it seems unlikely that they would be
other than the nearby new population. However, as noted below, this
difference does not seem to have been actually used to make new traffic
forecasts.

5. The Regional Travel Model and the traffic operations model appear
to have been insufficiently calibrated.

It is widely agreed that the use of a traffic model in forecasting first requires that it is
well calibrated, that is, it matches reasonably well existing traffic counts, travel times,
and speeds in the base year. This elementary step is intended to ensure that the
model, when used for forecasting, will not require inordinate adjustments to raw
traffic forecasts.

Standards for model calibration accuracy are detailed nationally. The general rule of
for regional model calibration accuracy is that estimated base-year traffic for roads
with volumes over 50,000 ADT should be within ±20% of observed counts, and
within ±30% of observed counts for roads with volumes between 50,000 and 10,000
ADT, with most roads showing considerably less error.85 And of course, if a specific
project is being studied, such as U.S. 74, estimated base-year traffic volumes on that
road should be close to actual ground counts. In addition to this limited standard, for
major studies such as this one good practice is also to calibrate the models by cut-line
in-out balance, geographic region, road functional class, time-of-day and direction to
a similar or tighter level of accuracy, for greater confidence in forecasting. In
addition, travel times and speeds through the base-year network should correspond
closely to observed field data.

83 Id. at 59.
84 DSFEIS at 4-30.
85 Federal Highway Administration, Travel Model Reasonableness Checking Manual, Travel Model
Improvement Program (2010).
25
 The calibration of the Metrolina Regional Model (“MRM”) used for this
study has not been demonstrated.
In prior documentation of the regional modeling effort for this study,86 the
consultant (Wilbur Smith Associates, now CDM Smith) states that: “The
base-year model was calibrated in the immediate project area to achieve the
best traffic volume assignments compared to observed traffic counts and
observed speeds from speed-delay runs conducted for the traffic and revenue
analysis. . . . The base year 2008 model was run using inputs supplied by the
MPO. . . . A series of traffic assignments were compared with ground counts
supplied by the NCDOT and those collected specifically for the traffic and
revenue study...Adjustments were made to input network speeds and trip
tables in the study area in order to improve the calibration of the model in
comparison with ground counts for the specific corridor area. After
calibration was obtained, a series of traffic assignments to the highway
network were made for years of 2008, 2010, 2015, 2020, and 2030 under No-
Build, Toll-free, and Tolled conditions.”87 This statement admits the presence
of initial calibration errors which were (apparently) “improved” by changes to
network speed and trip tables. But no data comparing “observed” vs.
“estimated” or “improved” traffic is provided, no chart showing either
regional or study area agreement by link type or volume is provided, and no
calibration statistics by cut-line are given. No reference is made to time-of-
day or directional agreement. As the MRM was not updated for the DSFEIS,
the possibility of remaining errors, such as those caused by inadequate
calibration, is a distinct possibility.

 The current DSFEIS does not discuss calibration.
The DSFEIS contains no discussion of calibration, but instead asserts that
prior modeling is adequate for the purpose of environmental assessment.
Therefore, one is left to assume that the current traffic forecasts are based on
an adequately calibrated model, which as noted above has not been
demonstrated. Given that recent traffic has not grown to the extent forecast in
2008, the MRM should probably have been re-calibrated.

 Errors in calibration will be carried forward into future estimates.
If the original MRM was not adequately calibrated, traffic forecasts are in
serious doubt as calibration errors on specific road links are therefore carried
forward into future tests. Essentially, if traffic for a specific road section is
over-estimated in the base year, it is likely to be also over-estimated in the
future year as well. The problem is particularly severe for calibration of U.S.
74 traffic volumes, which, as noted below, are clearly open to question since
U.S. 74 apparently was modeled with too-high volumes, and with too-slow
speeds relative to actual INRIX travel speeds. The accuracy of traffic
forecasts for new roads is also open to question. This also affects estimates of

86 Wilbur Smith Associates, Traffic forecasting for TIP Projects R-3229 and R-2559 Monroe
Connector/Bypass (Sept. 19, 2008).
87 Id. at 9 (underlining added).
26
traffic diversion and revenue for toll roads. In addition, errors in calibration
carried forward in forecasts, are also likely to impact other key elements of the
EIS, particularly noise, air quality and stream runoff, bringing large portions
of the EIS into serious question. In short, the use of poorly calibrated traffic
models to make forecasts is a serious mistake in traffic modeling that must be
corrected BEFORE the resulting traffic forecast can be used in decision-
making.

 The traffic operations simulation model (SIMTraffic) also appears not to
be well calibrated.
The study uses a traffic operations simulation model (SIMTraffic) to simulate
traffic operations for existing and no-build future traffic on U.S. 74. Good
planning practice dictates that these models also be “calibrated” in the field,
that is, they replicate existing travel times and speeds before being used for
forecasting. According to the consultant’s documentation, in 2008 calibration
was undertaken by driving 4 runs through the project section, 2 in the AM and
2 in the PM peaks.88 The reported (average of the 2 runs in each direction?)
travel times in 2008 was 41 minutes (30 mph) eastbound in the PM peak, and
40 minutes (30 mph) westbound in the AM peak.89 The SIMTraffic model for
the same conditions yielded 47 minutes, at 29 mph (westbound) and 50
minutes at 24 mph eastbound, that is, the SIMTraffic tests showed significantly
higher travel times and (according to the consultant) “slightly lower speeds”
than the travel time runs.90 The consultants attributed these differences to
different input traffic volumes (the SIMTraffic volumes were taken from the
regional travel demand model and were higher than the 2007 field volumes),
and so the consultant considered the SIMTraffic model “calibrated.”91 The
following table summarizes their findings:

Travel Time Calibration Runs on U.S. 74, 2008 (PBSJ)
Travel Time
Runs

SIMTraffic

Minutes

Speed

Minutes

Speed
Westbound PM Peak 41 30 47 29
Eastbound AM Peak 40 30 50 24

The consultant’s conclusion that this is adequate calibration is not believable.
First, the use of just 4 travel time runs to prepare a baseline for calibration is
wholly inadequate, as traffic varies considerably just day-to-day, let alone on

88 PBSJ, Draft Existing and Year 2030 No-Build Traffic Operations Technical Memorandum (March
2008), at 12.
89 Id.
90 Id.
91 Id.
27
weekends or by time-of-day or direction. A much larger set of runs, perhaps
30 for each time/direction, would be needed for statistical accuracy and for
obtaining data for travel time reliability (see discussion below). Further,
setting aside the obvious miscalculation of speed (47 minutes through a 19.7-
mile section is 25 mph, not 29 mph), the large differences in travel time
between the field runs and the simulation model could not possibly have been
caused by different traffic volumes as the volumes were virtually unchanged
between 2007 and 2008. Either the traffic volumes used to calibrate the
model were way too high — a serious error as one should always use field-
measured volumes for calibration — or the model’s performance was
understated. Either way, the SIMTraffic model clearly underestimated the
2007 speeds on U.S. 74.

Further, recent analysis (in early 2013) of new travel time runs on U.S. 74 and
INRIX data also suggests that speeds on U.S. 74 are significantly higher now
than in 2007. NCDOT re-did the travel time runs on U.S. 74 in March 2013,
this time with (apparently) three runs in each direction/time period. They
found average speeds of 39.1-43.9 mph, about 10 miles per hour faster than
the runs made in 2007!92 In other words, the NCDOT’s own tests showed that
travel speeds had improved significantly between 2007 and 2012. Using a new
source of data provided by INRIX, which tracked the speeds of hundreds
(perhaps thousands) of actual road users between January 1 and Feb 28, 2013,
the INRIX analysis also found that the actual operating speeds were even
higher — between 44.2 and 44.9 mph, than in the upward-revised field runs.
Both these sources say the same thing: Travel speeds on the present U.S. 74
have improved substantially over the past 7 years, and are MUCH HGHER
(by 10-15 mph) than the speeds used to calibrate the SIMTraffic operations
model. No explanation is given for these findings, but they are likely a
combination of poor initial model calibration and recent improvements to U.S.
74 to smooth and speed its operation.

Errors of this magnitude in calibration cannot be ignored. If not revised to
accurately reflect current operating conditions, the SIMTraffic model used for
studying flow on U.S. 74 is likely to significantly overstate congestion and
travel time through the section, and therefore overstate the potential for
diversion to a proposed Bypass.

To correct the above problems, several steps should be undertaken. First, road
capacities should be updated in both the simulation model and the regional
travel model. The new Highway Capacity Manual (2010)93 revises procedures
for calculation of capacity for both arterials and for freeways, which in some
cases results in higher capacity estimates. Failure to use the 2010 Highway

92 Memorandum from Bradley Reynolds, HNTB, to Jennifer Harris, NCDOT, RE: U.S. 74 Corridor Travel
Time Improvement (April 8, 2013).
93 Transportation Research Board, HIGHWAY CAPACITY MANUAL 2010, National Research Board (2010).
28
Capacity Manual in such cases would therefore bias the traffic forecasts
against the no-build alternative by underestimating its ability to carry traffic.

Second, the regional travel model should be calibrated sufficiently to show (at
the very least) FHWA-standard agreement with existing volumes by direction
and time of day.

Third, the simulation operation model should be re-calibrated to show close
agreement with INRIX travel times and speeds through the section, also by
direction and time of day. These elemental steps must be undertaken
BEFORE either model is used in forecasting.

6. The DSFEIS leaves unanswered key questions regarding induced travel.

The DSFEIS describes methods and results for an estimate of “induced land use
development.”94 This estimate, about 3.4% (an increase of development from 125,000
acres “no-build” to 128,200 acres “build,” compared with a base-year value of 95,200
acres), includes induced-growth impacts for residential, commercial, industrial, and
other land uses.95 A variety of methods are used to make this estimate, including one
developed by this reviewer (Hartgen) in 2000, a review of estimated industrial land
use impacts, and a review of development forecasts in the original EIS.96

However, some additional questions remain. Among them are:

 Are there different land use forecasts for each alternative?
The documentation of the changes in land use forecasts do not specifically
address the question of whether separate land use forecasts were prepared for
all alternatives, or (more likely) for just one Build alternative, a generic
“corridor” alternative, and the No-build. This raises the question of whether,
for modeling purposes, the induced impacts of other alternatives (e.g., an “on-
current alignment” upgrade of U.S. 74) should also have been studied.

 Are the land use forecasts carried into the modeling, through trip
generation, trip distribution and assignment steps?
Nowhere in the material submitted is it specifically stated that the different
land use forecasts were then used to re-estimate trip generation, trip
distribution, and then assignments of estimated traffic. This might be implied
by the discussion of “raw model volumes,” but the report does not actually
explain how the adjusted volumes were calculated. Elsewhere (Appendix C-
3, section 6.7) the description of the method seems to imply that standard
traffic forecasting methods (trip generation, distribution, and assignment)
were NOT used in the revised EIS. So, which is it? Was a standard 4-step
model used for the DSFEIS, or not?

94 DSFEIS at 4-29.
95 Id. at 4-30.
96 Id. at 4-29.
29

 Do the trip distribution and assignment steps in the traffic forecast for
the “no-build” alternative now exclude “project-induced travel”
development and exclude the Bypass in the No-build forecast?
It is still not clear if the land use, trip generation, trip distribution and
assignment steps described in the DSFEIS include the project’s effect. For
instance, even if the land use forecasts were found to be the same for “build”
and “no-build” scenarios, the trip distributions from them would certainly
NOT be the same since they undoubtedly included the Bypass in distributing
trips between TAZs. If the trip distributions for the no-build alternative
included the proposed Bypass in the network, then that would incorrectly
forecast the traffic using the no-build network.

 If not, how do the traffic forecasts actually reflect the induced
development?
The DSFEIS needs to state clearly, in professional “modeling” language that
can be reviewed by independent experts, exactly how the revised traffic
forecasts for the “build” and the “no build” were prepared.

7. Questions remain concerning details of traffic forecasts.

The extensive coverage of induced traffic issues in the DSFEIS does not contain a
commensurate discussion of the traffic forecasting method itself, so the reader is left
to understand that the assumptions in the original traffic model forecast remain valid.
This raises numerous questions regarding various issues, including:

 Was the MRM used with the updated ICE land use forecasts to estimate
future traffic volumes?
The DSFEIS states that changes were made to land use to account for the
induced effects, and “then the [Metrolina Regional] Model was run…”
implying that the full generation-distribution-assignment sequence was used.97
The technical documentation further reports an 3.5% increase of VMT in
Union County as a result.98 But elsewhere, the Traffic Forecast Memo
Appendix (Nov. 8, 2013) states: “This approach uses the original accepted
forecasts and base data assumptions to mathematically calculate traffic
estimates and redistributions of traffic for conditions not included or known at
the time of the initial forecast. This methodology is appropriate because the
differences being considered do not change the original forecast,
assumptions, methodology or base data. The interpolation and extrapolation
process is a method for developing new data points for years not considered
in the base forecast but within the range of volumes established by the base
forecast.”99 And at a later point the documentation says: “Based on a
meeting with NCDOT Transportation Planning Branch (TPB) on March 21,

97 DSFEIS Appendix C-3, at Section 6-7.
98 C. Scheffler, op. cit. Table 5.
99 DSFEIS at G-9.
30
2013 and the document Guidelines to Determine When to Request an Updated
Traffic Forecast 2 (NCDOT TPB, February 24, 2009), the current Build
traffic forecasts meet the guidelines that indicate the existing forecast is valid
and an updated forecast is not warranted. All of these guidelines are met
since no new alternatives have been identified, the current let date of the
project is less than the Future Forecast Year plus 20 years, the study area is
not experiencing growth not previously considered in the forecast, and the
traffic forecast is not five years older than the Base Year.”100 These different
statements make it unclear as to exactly whether new traffic forecasts were
prepared using the MRM, or by some other method, or not at all.

 Truck percentages.
It is well known that truck traffic forecasting is one of the weakest elements of
traffic modeling. For proposed toll roads, the issue is doubly important as
trucks constitute typically 5-10% of traffic but pay 20-40% of toll revenue.
Nowhere in the report does it clearly state the assumptions for truck forecasts,
but most studies generally use current truck percentages and apply them to
future ADT estimates. This simple “take down percent” for regional truck
forecasts is probably inappropriate if it has not been updated since the
Recession, because the Recession significantly affected truck travel too.

 Time of day percentages.
In standard modeling practice, time-of-day percentages (so-called K factors
for peak hour travel) are assumed to be about 9-10 percent of ADT, based on
historical traffic counts. However, in many regions peak periods are
lengthening as commuters shift start times to avoid congestion, and work trips
are declining as a percentage of total travel. In more advanced models these
effects are accounted for by feedbacks between time-of-day assumptions and
traffic assignment. The MRM does not apparently account for such trends,
either through feedbacks or by increasing the length of peak hours.

 The value of time used for modeling is unclear.
The Traffic and Revenue Study states the values of time for trip classes, $7-
22/hr for trucks, and $7-8/hr for cars.101 These values seem low for both cars
and trucks, given national studies. Elsewhere in this review we note that a
high value of time, about $18/hr, would seem to be necessary to create
substantial diversion. A high value of time for trucks would similarly be
needed for substantial truck diversion. As the estimated toll for trucks on the
proposed Bypass would be over $10,102 the value of time for trucks would
seem to be too low to induce much diversion.

100 Id. at 14.
101 Comprehensive Traffic & Revenue Study (October 2010), at 6-3, 4-9.
102 Id. at Figure 6-3.
31
 The reliability of travel time has not been considered in diversion or
benefits.
Recent research on travel time reliability (the value that travelers place on the
certainty of arriving within a given time window) suggests that this value is
quite high, perhaps higher than the value of time itself. Several national
studies103 have developed guidelines for including reliability in traffic
forecasting, and how improved operations affect reliability. These methods
have not been incorporated into the analysis of the Monroe Connector/Bypass
or its alternatives.

 Road capacities have not been updated.
The DSFEIS forecasts rely on regional networks that use estimates of
highway capacity from the 2000 Highway Capacity Manual.104 The new
Highway Capacity Manual generally raises highway capacities for various
road classes, and significantly changes the capacity estimation and level-of-
service procedure for urban and rural arterials such as U.S. 74. In particular,
the new method for estimating capacity for signalized arterials includes signal
progression, access points, and traffic volumes, all of which are obviously
relevant for study of U.S. 74. These updated capacities have apparently not
been used in the traffic modeling. If the estimates of capacity for U.S. 74 are
too low, the effect would be to over-state future congestion estimates on U.S.
74, and thus over-state diversion to the Bypass, and also under-state the
viability of other alternatives.

 Market capture rates (40-50%) seem very high.
While the percentage of non-local traffic was not calculated as part of the
traffic forecasts for the project, given that less than half of the traffic on U.S.
74 is appears to be non-local,105 the overall capture rate of around 50%
suggested by the traffic forecasts seems very optimistic indeed. Assuming a
generous capture rate of 50% of non-local trips, an overall capture rate less
than 25% seems more likely, and even that might be too high if the diverters
are infrequent rather than every-day diverters, as the forecast assumes.

 Earlier errors in the 2030 and 2035 traffic forecasts reduce confidence in
current estimates.
The report notes that earlier traffic forecasts, by Wilbur Smith Associates
(now CDM Smith) contained errors resulting in higher traffic forecasts.106
This revelation raises questions about whether the current traffic estimates can
also be trusted.

103 For instance, Kittleson and Associates, Evaluating Alternative Operations Strategies to Improve Travel
Time Reliability, National Cooperative Highway Research Program, Report S2-L11, Transportation
Research Board (2013), available at www.trb.org.
104 See Transportation Research Board, HIGHWAY CAPACITY MANUAL 2000, National Research Council
(2000).
105 See Part 1, above.
106 See, e.g., C. Scheffler, op. cit. Table 5.
32

8. Project cost and cost-effectiveness are not detailed.

Environmental impact statements generally contain comparative estimates of cost
for viable alternatives. The DSFEIS reports an estimated cost range of $845-923
million (in year of expenditure, assuming award in October 2014 and opening in
October 2018).107 But the discussion of costs for the Monroe Connector/Bypass is
incomplete:

 If the construction of the road is delayed significantly, which might happen
given environmental and financing issues, this cost estimate is likely to be
higher.
 No data is provided for maintenance and operation costs after construction but
during service life, converted to present worth, for various alternatives.
 No costs are shown for other alternatives, particularly those for various
upgrades of U.S. 74. This appears to violate NEPA regulations that require
comparable evaluation of viable alternatives.
 No data is provided on the relative cost-effectiveness of the alternatives. Most
EISs show costs, benefits and cost-effectiveness, using such measures as
benefit-cost ratios, for various alternatives, not just for the recommended
alternative.
 The DSFEIS contains no summary table that compares the impacts, costs,
benefits, and other features of the viable alternatives.

9. External traffic forecasts for U.S. 74 and other roads is not discussed.

In modeling terminology, “external traffic” is that traffic which leaves, enters or
goes through the study area. The issue of how to forecast external traffic is
particularly severe for proposed projects on the edges of regions, such as the proposed
Monroe Connector/Bypass, which ends at the far eastern edge of the MRM coverage
area. Specifically, the traffic on U.S. 74 just east of the proposed project terminus is
treated as “external” traffic, and therefore is not forecast directly using the MRM.
Instead, external traffic is forecast separately using a variety of methods such as
trend-lining, statewide modeling, or inter-regional modeling. It is then typically
added to the internal (within the Model) forecast of trip ends, or is added to trip OD
matrices, or is added directly to network volumes as a “pre-load.” In each case, the
separate treatment of external traffic is in addition to that of within-region traffic
modeling. In some cases, such as on U.S. 74 just east of the project, external traffic
could be as much as 30-40% of traffic volume. This includes truck traffic, which is
often a significant portion of smaller-region external traffic.

In the case of the proposed Bypass, our review of recent traffic count history at
the far eastern edge of the region (Union-Anson County line) shows that the external
traffic has actually been declining in recent years.

107 DSFEIS at 3-10.
33

U.S. 74 Average Daily Traffic at the Union-Anson County Line

Count Location

2000

2005

2010

2012
12-year Percent
Change per year

Anson-Union Line

15000

15000

14000

13000

-1.1

Source: NCDOT Traffic Count Maps, available at www.NCDOT.gov.

Neither the DSFEIS nor the earlier documentation we looked at contains references to
external traffic, leaving the reader completely in the dark as to how it was forecast,
whether the current count history was considered or the 2009-12 Recession was
accounted for. However, given the huge changes in recent US economic activity, it is
likely that any forecasts of external traffic prepared before the Recession would now
have to be substantially revised.

10. Considerable uncertainty exists in traffic modeling.

Traffic modeling and forecasting is a craft, not an art or a science. The process is
fraught with uncertainty throughout because each step in the process involves the use
of critical and generally not-verifiable assumptions concerning the nature of growth
or traffic. Uncertainties in the myriad assumptions that must be made in virtually all
of its steps have the effect of making “output” uncertainties substantial.

The DSFEIS supporting documents recognize this uncertainty, but only for land use
inputs, noting that errors in population and land use forecasts can be very high. “For
county level projections of 25 years, the typical mean algebraic percentage errors are
about 30 percent while for census tracts (which are typically larger than TAZs)
errors are typically 45 percent for the same period. Thus, despite the best efforts of
researchers and forecasters, the error rates for long-range projections are still quite
high and thus any projection or estimate of induced and cumulative effects must be
considered the best estimate within a wide range of error. The accuracy of projected
growth under any future scenario could be affected by many variables. These include
individual owner or developer actions, the timing of or changes in utility provision,
changes in local or state regulations on land use and, most importantly, changes in
national or regional economic conditions. While the potential for error is high, the
techniques used by the MPO are the best available and provide the best available
data for projecting population and employment conditions in the future.”108 Such
“input” errors and also errors in model calibration are also carried forward into traffic
forecasts. However, just because the techniques of land use forecasting are the “best
available” does not mean that their results can be trusted for decision-making.

108 Quantitative ICE Analysis, at 78 (underlining added).
34

In addition to large errors in inputs, and errors in calibration (discussed above) recent
studies have found wide variations in the accuracy of modeled traffic forecasts, and
the errors can be either an “under” or an “over” forecast. A study of 20-year traffic
forecasts for Minnesota found that freeway traffic was under-forecast by about 5%,
while forecasts for other roads were over-forecast by 14-29%.109 On the other hand, a
US national review of toll road forecasts found that for 15 US toll roads, the actual
traffic averaged 35% under the predicted traffic.110 In England, the Department for
Transport found that 90% of major road traffic forecasts were within 43% of actual
traffic — a very wide spread for policy making.111 In another study of 104 toll roads
worldwide, Bain found that after correcting for “optimism bias” the average 20-year-
out actual traffic was about 20% under the predicted traffic.112 Also worldwide,
Flyvbjerg and colleagues found in a review of 258 road and transit projects that the
actual road traffic averaged about 17% under the forecast traffic, but actual costs
were 250% over the forecast cost, with toll roads in particular having larger errors.113
In short, the limited reviews so far have found that the average error in 20-year
forecasts of road traffic range from ±20% upwards to ±30-40%, with most actual
traffic coming in substantially under the forecast traffic. The errors are also
substantially higher for toll roads, leading some observers to suggest that “optimism
bias” may be substantially inherent in forecasts prepared on behalf of project
advocates. This author (Hartgen) has recently reviewed the topic and has found that
the overall accuracy of traffic forecasts is likely to be so large that he recommends
considerable caution in their use and less reliance on traffic forecasts for
transportation decision-making.114

The DSFEIS partially recognizes this uncertainty (at least in inputs) and employs
sensitivity tests to evaluate the range of its results. However, the range of variation in
the assumptions (for instance assumption concerning population forecasts, a 20%
difference for value-of-time, a 30% difference in economic growth, the use of
electronic toll collection, and 5% difference in fuel prices) do not seem to be extreme
enough given recent history.

The recent experiences of South Carolina’s Southern Connector, in bankruptcy, the
New York court case regarding toll-road forecasts in Detroit and Alabama, and North
Carolina’s Triangle Expressway — built 6-lanes wide but carrying just 20,000 ADT

109 David Levinson and Parvithra Parthasarathi, Post-construction evaluation of traffic forecast accuracy.
TRANSPORT POLICY, (Elsevier), 2010.
110 National Cooperative Highway Research Program, Estimating toll road demand and revenue,
SYNTHESIS 364, Transportation Research Board (2006), available at www.trb.org.
111 Department for Transport (United Kingdom), TRANSPORTATION ANALYSIS GUIDANCE: TREATMENT OF
UNCERTAINTY IN MODEL FORECASTING (2013), available at www.dft.gov.uk/webtag/index/php.
112 R Bain, On the reasonableness of traffic forecasts, TRAFFIC ENGINEERING AND CONTROL (2011)
available at www.tecmagazine.com.
113 B Flyvbjerg et. al., MEGAPROJECTS AND RISK; AN ANATOMY OF AMBITION, Cambridge University Press
(2003).
114 D. Hartgen, Hubris or humility? Accuracy issues for the next 50 years of travel demand modeling,
Transportation 40:6 (November 2013), available at www.springer.com/11116.
35
near I-40 and 4,000-6,000 ADT elsewhere — all encourage extreme caution in the
use of traffic and revenue forecasts for decision-making, particularly for proposed toll
roads where project risk is shifted to distant investors, or if fiscal failure occurs, to the
People of North Carolina.

36
Qualifications of the Reviewer
November 2012
David T. Hartgen
Emeritus Professor of Transportation Studies, UNC Charlotte
President, The Hartgen Group Inc.

QUALIFICATIONS
 Senior manager with 45 years experience in state and federal government, academia
and consulting.
 Hands-on consulting, management and policy in transportation issues.
 National reputation for high-quality, objective analysis of transportation issues.
 Extensive expertise in a wide range of complex transportation issues.

EXPERTISE
Economic Development
Beltways and economic development Land pricing and road access
Traffic impacts of site development Commercial development along Interstates
Business views of transportation Economic sector and industry targeting
Truck traffic and routing Regional economic performance

Regional productivity and competitiveness Regional distribution systems
Congestion and highway capacity Evaluation of road proposals

Transportation Funding
Comparative performance of highway systems Legislation and road performance
Condition of state and municipal road systems Bridge condition and performance
Needs and funding options for road systems International performance

Airports and Ports
Impacts of commercial airports Characteristics of air travelers
General aviation airport impacts Port competitiveness
Transit
Light rail transit evaluation Transit system comparative assessment
Transit system performance Transit route location assessment
Visions, trends and costs Transit rider characteristics

Sprawl, Growth, and Travel
Sprawl and road investment Travel patterns in numerous cities
Travel demand modeling Travel behavior, carpooling, transit use
Forecasts of travel and congestion Regional demographic forecasts

Environment, Energy and Organizational Change
Environmental impacts Air quality and greenhouse gas analysis
Transportation energy and pricing Electric vehicles and natural gas fuels
Organizational change and planning Information technology

37
EXPERIENCE
January 2007-Present: President, The Hartgen Group, Charlotte, NC. Consultancy
in transportation performance, congestion, financing, transit operations, accessibility and
regional productivity, greenhouse gas assessment, funding options. Extensive national,
state and local studies. www.hartgengroup.net.

January 1989–December 2006: Professor of Transportation Studies, UNC
Charlotte. Professor, Department of Geography and Earth Sciences; Adjunct Professor,
Civil Engineering, 1989-2000; Associate, Urban Institute, 1989-2000.
 Academic: Graduate courses in Transportation Policy, Analysis Methods, Impacts,
GIS, Public Transportation, Transportation Planning, and Management and Finance.
Numerous research studies and student theses.
 Leadership: Organized, initiated and directed Interdisciplinary Transportation
Studies Center, 1991-March 2000. Research, workshops, conferences, reports.
Extensive nationwide media contact.
 Research: Traffic forecasts, road system performance, highway impacts, site
evaluation, economic impacts, school locations, transportation system performance,
household travel, trade, air quality, passenger security, electric and natural gas
vehicles, airport impacts, transit performance, motor sports impacts, highway system
condition and needs, sprawl and road investments.

August 1987 - December 1988. Principal Transportation Analyst, New York State
Department of Transportation, Albany, NY, 12232
 Information technology plan for the New York State Department of Transportation.
 Testimony on emergency evacuation plans for the Shoreham Nuclear Power Station
on Long Island.

February 1981 - July 1987. Director, Transportation Statistics and Analysis, New
York State Department of Transportation, Albany, NY 12232.
 Leadership: Directed 60-person office responsible for data collection, systems
planning and forecasting. Revitalized an extensive highway and traffic data system
into information system. Designed and implemented new methods of rapidly
assessing highway condition, cut data delivery time by 90% and improved accuracy
and reliability.
 Research: Principal investigator on 6 federal studies of traffic, forecasts, and energy.
Implemented demonstrations of employer and community-based ridesharing.
Updated NYS household trip generation rates. Transit fare sensitivity, financing, and
project benefit-costs. Integrated corporate database. Infrastructure needs assessment
model to forecast repair needs. Canal information system.
 Academic: Adjunct Professor, SUNY-Albany, Department of Geography, 1984-
1988. Student intern program with local universities. Guest lectures at numerous
universities in US and Europe.

May 1984 - March 1985. Policy Analyst, Federal Highway Administration,
Washington, DC 20590.
38
 Evaluated highway information needs for FHWA and the States. Recommended
improvements to FHWA planning-related data systems.
 Reviewed pavement initiatives studies, long-term monitoring of pavements.
Developed bridge and highway condition deterioration models.

July 1967-- February 1981. Transportation Analyst, New York State Department of
Transportation, Albany NY 12232.
 Designed and developed transportation plans, traffic models, and planning methods.
Directed staff of 10-15 analysts. 68 papers and reports.
 Adjunct Professor, Union College, 1976-79; Syracuse University, 1974.

PROFESSIONAL
 Board of Directors, Cabarrus County Chamber of Commerce; Charlotte Transit
Advisory Committee, Cabarrus County Planning and Zoning Board.
 Active in national organizations. Transportation Research Board. US Co-Editor,
Transportation (Springer Academic Publications). Professional Engineer, Maine
(retired). Scholar, John Locke Foundation. Adjunct Scholar, Reason Foundation.

EDUCATION
 Ph.D., Civil Engineering, Northwestern University, 1973
 M.S., Civil Engineering, Northwestern University, 1967
 B.S., Civil Engineering, Duke University, 1966

RECOGNITION
 Walter P. Murphy Fellowship, Northwestern University, 1966-67
 Profiled in Transportation Research News, National Academy of Sciences,
November 1978
 Profiled in the Charlotte Observer, November 1991
 Outstanding paper, Transportation Research Board, National Academy of Sciences,
1993
 Profiled in the Charlotte Business Journal, March 29, 1993
 Op-ed profile, Charlotte Observer, December 1, 1997
 Scholar, John Locke Foundation, 1999
 Scholar, Reason Foundation, 2005
 Member Emeritus, Transportation Research Board Committee on Travel Behavior,
2002

PUBLICATIONS
355 publications and reports on a wide range of transportation issues. Selected
recent:
 Comparative Performance of State Highways, 20th Report. In press, Reason
Foundation, 2012.
 Review of Wake County (NC) Transit Plan, John Locke Foundation, May 2012.
 Are Highways Crumbling? ALEC Conference, May 2012. In press, Reason
Foundation, 2012.
39
 Employers’ Views of Traffic Congestion. In press, Transportation Research Board,
2012.
 Wisconsin State Highway System Needs and Resources. Wisconsin Policy Research
Inst., May 2011.
 Greenhouse Gases and Transportation Policies. Reason Foundation, Sept. 2011.
 Comparative Performance of State Highway Systems, 19th Report. Reason
Foundation, Sept. 2010
 Distributing Transportation Funds. Testimony, Joint Oversight Comm., NC Gen
Assembly, Apr 2010
 How Traffic Congestion Affects Regional Economic Performance. Reason
Foundation, Oct 2009.
 North Carolina Transportation Issues. Presentation at the John Locke Foundation,
Feb. 23, 2009.
 Comparative Transportation Performance of Canadian Provinces. Fraser Inst.,
Vancouver BC, 2008.
 Mega-region Growth and Transportation Readiness. Urban Land Institute, 2008.
 Assessment of Charlotte’s Light Rail Line. John Locke Foundation, 2008.
 Economic Impacts of Highways in South Carolina. Report to SCDOT, 2007.
 National Study of Highway Congestion. Reason Foundation, 2006.
 Performance of North Carolina Transit Systems. John Locke Foundation, Spring
2006.
 Cost-Effectiveness of North Carolina Highway Projects. John Locke Foundation,
Spring 2005.
 Highways and Sprawl in North Carolina. John Locke Foundation, September 2003.
 Highways and Sprawl in Ohio. Buckeye Institute, January 2003.
 Guidelines for Highway Needs Studies. Eno Foundation, Transportation Quarterly,
Spring 2003.
 Performance: A Point-counterpoint Exchange. Eno Foundation, Transportation
Quarterly, 2002.
 The Charlotte Region: A Distribution Powerhouse. Ventures Business Magazine,
March 2001.
 North Carolina Highway Performance, Needs and Funding. John Locke Foundation,
October 2000.
 New York State Highway Needs. Associated General Contractors of NY, 1999.
 Arkansas State Highway Needs. Governor’s Citizens Highway Council, June 1998.

CONTACT:
8711 High Ridge Lane The Hartgen Group
Concord, NC 28027 9700 Research Drive, Suite 150, Charlotte NC 28262
704-784-2974 980-237-1398
Cell 704-785-7366 [e-mail]