Dear Sir or Madam,

It has become increasingly clear that both the public process and the technical analysis of the proposed 'improvement' have critical flaws. Flaws that make ODOT legally liable for deficiencies in public process, and it's consultant for technical analysis. ODOT has not been compliant in releasing information necessary for public comment, and persons in positions of authority (and reasonably expected knowledge) have been duplicious about the existence of certain critical data-sets that it required the threat of legal action to secure the release of.  Nor has the technical analysis been of an acceptable standard: it reflects neither the state of the art, nor the state of the practice. The state of the art (Ewing et al 2014: Structural Equation Model of VMT in US Urbanized Areas) clearly demonstrates a strong correlation between freeway lane miles and vehicle miles traveled. Regarding the State of the Practice, the shape of the VMT line in the graph makes it appears alarmingly clear that ODOT's consultant has simply projected forward VMT counts on a single facility, without accounting for diversion to other routes, other times, and other modes. This is exactly the sort of technical issue that travel demand models were developed to overcome. That only hourly traffic volumes, rather than industry-standard AADT volumes were reported supports this conclusion.

Regarding the assumed bridge noted by City Observatory (http://cityobservatory.org/theres-a-3-billion-bridge-hidden-in-the-rose-quarter-project-ea/) and the State of the Practice: While it is reasonable and proper to include the effects of other transportation improvements in the analysis (such as a certain bridge), it is also reasonable to include proper characteristics of those improvements. Ie, a tolled versus untolled bridge.

I note with some concern ODOT's failure to engage in 'value engineering'. Rather than minimizing the required right of way and associated bridge construction costs through the use of narrow shoulders, ODOT has instead based it's analysis on wide shoulders. Given a long history of the conversion of shoulder space into 'auxiliary' lanes over time, it seems suspicious that ODOT is providing ROW in excess of projected need, at substantial public cost.

Respectfully,
Matt Miller
Transportation Planner
PhD Student, Metropolitan Policy, Planning and Design.