20020672 Ver 3_Attachment 01 - Hartgen 2014 Response_20141124

Reply to Response to Comments,
“Review of Traffic Forecasting: Monroe Connector/Bypass, DFSEIS,
December 26, 2013
By
David T. Hartgen
The Hartgen Group
June 9, 2014
In its Response to Comments, May 1, 2014, the NCDOT’s consultant (called the
Respondent below) prepared a detailed response to my 72 original Comments dated December
26, 2013. I thank the Respondent and the NCDOT for timely preparation of explanatory
material, in a readily usable format, regarding my earlier comments. This memo and its detailed
tabular attachment are intended to reply to those responses and state my continued concerns.
Summary of Reply
Reply to Responses to Comments, May 1, 2014
The expanded Responses provide additional clarification of the methods used to prepare
the traffic forecasts. While I find some of the Responses to be sufficient, and find that others in
fact tend to agree with my own comments, unfortunately the expanded Responses raise
additional concerns regarding the traffic forecasts, and also do not alleviate my initial concerns.
Therefore, I am reluctantly compelled to stand by my original overall assessment, that “the
traffic forecasts presented . . . are too uncertain and insufficiently supported to be the basis of
decision-making regarding the Monroe Connector/Bypass.” (D. Hartgen, Review of Traffic
Forecasting: Monroe Connector/Bypass Draft Supplemental Final EIS, November 2013” (December 26,
2013)).
My reply regarding additional and remaining concerns is summarized here. The detailed
attachment provides specific replies.
1.The stated Purpose and Need remains narrow.
The Responses to Comments 13-20 indicate that under NEPA, statements of “purpose
and need” should be revisited when new major information becomes available. The
Responses now admit that the primary objective of the proposed Bypass is to relieve local
(rather than long-distance) congestion on U.S. 74. The Responses also show that average
speeds have increased substantially (10-15 mph increase) since 2008 when the traffic
modeling was conducted, and that large sections of the corridor now operate at or near 50
mph. Yet in spite of this progress, the Responses incredulously assert that only a tolled
(not free) bypass on new alignment would satisfy this arbitrary speed standard.
Attachment 1
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2. The alternatives studied remain narrow.
The Responses to Comments 21-29 indicate that some alternatives were considered but
rejected, but also that other alternatives were not seriously considered. The bulk of this
consideration was conducted in 2007. These potential treatments to existing U.S. 74
include further “superstreet” treatments, widening to 6-lanes, upgrading to freeway status
with frontage roads, consolidation and progression of signals, and localized “flex-time”
for major nearby employers. Other “new alignment” options such as “partial” new-
alignment radials ending at intermediate roads, or even an un-tolled bypass were not
studied, even though a ‘partial’ bypass ending at U.S. 601 was included in air quality
tests in 2005. Instead, NCDOT continues to reject all these options and studies based on
an outdated analysis, and fails to consider the alternatives based on the current data. The
Department doggedly clings to just one alternative: a new 4-6 lane tolled Bypass. This
appears to violate NEPA.

3. Recent road improvements not accounted for on U.S. 74.
Responses to Comments 30-36 indicate that recent improvements to U.S. 74, including
signal improvements at 23 locations, have yielded huge increases in average operating
speed from 2008 to 2014. Additionally, more improvements are planned, such as a series
of “superstreet” installations through one of the most congested segments of U.S. 74 in
Indian Trail. All these improvements, and the improved speed, post-date NCDOT’s
modeling effort and therefore were not factored into the traffic forecasts.

4. Traffic on U.S. 74 has shown ZERO growth since 2000 and is inconsistent with
Study Area population growth.
Regarding perhaps the most significant issue, the Responses to Comments 37-48 agree
with my earlier statement that the traffic trends for U.S. 74 have shown zero growth since
2000 and are inconsistent with the population trends for the Study Area for 2000-2010.
This major inconsistency has still not been satisfactorily explained. Further, the
NCDOT’s own consultant has noted an 8.7% reduction in population forecasts for Union
County, and the MPO has recently adopted a 16% and a 21% reduction in population and
job forecasts, respectively. In the eastern end of the Corridor, where the Bypass would
re-join U.S. 74, the future population reduction is 34%. These are huge changes in the
growth projections for the Corridor likely to result in significant impacts on area traffic
and growth patterns, and should therefore be specifically considered in a revised
assessment.

5. The Metrolina Regional Model (“MRM”) used for traffic forecasting appears to
have been insufficiently calibrated.
Responses to Comments 49-54 indicate that the MRM used for traffic forecasting was
calibrated to a regional, not a corridor, level using data that is now 7-8 years old. Details
of the calibration show that the MRM reports very high relative errors, particularly in
areas affecting study of the Bypass. For example, details show calibration errors to the
order of 34%-80% for Union County roads, significantly above federal standards. An
updated MRM, forecasting to 2040, has recently been developed. This MRM could be
refined and sufficiently calibrated further for a more accurate study of the Bypass.
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6. Questions remain regarding induced travel.
Responses to Comments 55-59 are inconsistent, which at one point indicate that the
MRM was used for distributing the “induced” growth, but at another point, indicate that
the MRM was not used.

7. Traffic forecasting details reveal that traffic forecasts were made by “averaging”
growth rates and other key issues that were not addressed.
Responses to Comments 60-68 indicate that the MRM was not used for estimating the
effect of induced travel on future trip distribution or assignment to networks. Instead, in
a surprising new detail first revealed in Response 43, the traffic forecasts were apparently
developed by “averaging” raw-model/base year growth rates with historical (pre-2000)
traffic count growth rates. How this apples-and-oranges comparison accounts for
balanced traffic or numerous other issues is not explained. This post-model step is
fundamentally arbitrary and is presented without justification. The Responses also reveal
that truck percentages were assumed to be constant in spite of the intervening recession;
that no analysis of time-shifting to avoid congestion was made; that reliability of travel
time was not accounted for; that road capacities were not updated to 2010 rates; and that
diversion rates for various road sections averaged 31% - and were as high as 54% for
some road sections - possibly caused by an assumed very high value of time inside the
model. All of these features should have been updated with appropriate new information
available since 2008.

8. Project cost and cost-effectiveness is not addressed.
Our reply to Comment 69 concludes that, while NEPA does not require a cost-
effectiveness or benefit-cost assessment of project alternatives, virtually all EISs for
major projects contain them. Further, the Bypass would be likely to score very poorly
under North Carolina’s new merit-based project scoring method. While the Bypass is not
subject to the new scoring system, this state-wide shift toward funding the most
meritorious transportation projects indicates that NCDOT should provide taxpayers with
this basic information.

9. External traffic remains un-documented.
The Response to Comment 70 indicates that the data used to estimate current external
traffic is 11 years old and that no estimation method for future external traffic is
described. Given the substantial changes in the economy since 2008, this data must be
updated, particularly given the fact that a new MRM update has recently been completed
for the region’s 2040 Long Range Plan.

10. Inherent uncertainty in traffic forecasting has not been addressed.
We provide new information from two sources indicating that transportation
professionals reasonably expect 20-year traffic forecasts to be, on average, within
approximately 24% of actual counts. The large recent changes in the corridor’s growth
rates, traffic growth rates, other road improvements and numerous large unexplained
adjustments to model forecasts, all suggest that NCDOT’s forecast of Bypass traffic is
likely to be significantly overstated.
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Review of FHWA Documents

The Federal Highway Administration has prepared two documents, in memo form,
responding to our prior comments. I have reviewed these responses and have the following reply:

1. The FHWA analysis of the revised changes in population and employment forecasts (B. Gardner
to J. Sullivan, Review of forecasting and analysis in support of the Monroe Connector/Bypass,
Federal Highway Administration, May 14, 2014) does not actually state the magnitude of the
changes in forecasts (-16% for population, -21% for employment), but agrees with me that the
effect is to lower projections in the far eastern and central portion of the Study Area, and raise
them in the western portion. Elsewhere in my detailed reply I note that the reduction in growth
is -34% in the far eastern edge of the corridor. These findings fundamentally undercut the whole
need for a Monroe “bypass” and at the least, call for a new assessment and revisiting of the
Purpose and Need. Instead of addressing this issue, the FHWA memo reviews the
reasonableness of the estimates of induced travel, which has a much smaller impact in the range
of 3-4%. I am therefore at a loss to explain how the FHWA then concludes that the changes in
the demographic forecasts should not be now incorporated into a revised traffic forecast.

2. The FHWA memo does not comment on my critical concerns that traffic in the corridor has been
flat in growth and inconsistent with population forecasts.

3. Nor does the FHWA mention that the Model Reasonableness and Checking Manual guidelines
have been revised from 1997 to 2010 and that numerous calibration criteria within the MRM do
not pass the guidelines.

4. The FHWA memo does not mention that 2010 capacities were NOT used in traffic forecasting,
instead being only used on a comparison of current volumes on U.S. 74.

5. In its “Prior Concurrence” memo (J. Sullivan to G. Solomon, Prior Concurrence on Combined
ESFEIS/ROD Monroe Connector/Bypass, Federal Highway Administration, April 24, 2014),
FHWA does not mention that the proposed Bypass ends at the far eastern edge of the MRM
study area, and thus connects to long-distance travel from outside the region, so long-distance
travel must be served by the project.

6. Nor does the FHWA memo mention that corridor speeds have increased 10-15 mph, due
apparently to modest signalization improvements, but that these higher speeds are NOT
considered in the traffic forecasts which assumed lower speeds on existing U.S. 74, thus
overstating diversion to the Bypass.

7. The FHWA ‘Prior Concurrence’ memo essentially agrees with the MPO and me that 2030
population forecasts were 9-16% too high, and employment forecasts 20-21% too high. Why
these are not ‘significant’ changes is not clear to me, therefore I am also at a loss to understand
how such large changes in demographic forecasts, apparent errors in calibration, inconsistencies
in traffic count trends versus population trends, and numerous other issues cannot constitute
“significant new circumstances” under NEPA.
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What To Do Now

 Rescind the Record of Decision as unresponsive to the requirements of NEPA and
require the agencies to address both the age of the analysis and changes in the region.

 Re-visit the Purpose and Need based on updated information and changes in traffic count
trends and demographic trends.

 Re-calibrate the MRM for the study corridor, starting with the most recent version, using
all the available data (roads, demographic, traffic counts, external, etc.) that have been
developed since 2008. Prepare a detailed sub-regional traffic model for the Study Area.

 Expand the analysis of alternatives to consider upgrades to U.S. 74, of a variety of types
and combinations of those alternatives.

 Expand the analysis to consider the whole east side of Charlotte, including access from
the Ballantyne area, AND include with this consideration the need for radials in
northwest Union County.

 Re–forecast traffic using the most recent growth estimates and other changes, and re-
forecast anticipated future changes to roads, traffic characteristics, capacity and speeds.

 Score various alternatives using the new STI scoring method.