The Defenders Comments on the 2040 Plan, submitted to CMAP

August 6, 2010
To: CMAP
From: Environmental Defenders of McHenry County, 124 Cass St. Ste 3, Woodstock IL 60098
mcdef@owc.net
 

RE: Comments on Go To 2040 Plan

The Environmental Defenders of McHenry County support CMAP commitment to “plan more effectively for the livability of communities” (defined by the residents of our region as healthy, safe, walkable— with transportation choices and a ‘sense of place’) in the Go To 2040 Plan. Because our organization’s mission is ‘Citizens Working for a Healthy Environment’, we have concentrated our review on plan recommendations which most directly have environmental consequences.

We support the conservation of energy and water as a top priority. We support retrofitting buildings for increased energy efficiency and maximizing the energy efficiency of new buildings as well as integrating water conservation goals with land use planning, preserving open space in aquifer recharge areas and using green infrastructure to manage stormwater.

We wholeheartedly agree that “Access to parks and open space is part of what makes up quality of life, and open space also has a crucial role in flood protection, public health, drinking water supply and quality, and adaptation to climate change.” Specifically, we support the call for a green infrastructure network that follows waterway corridors, expands existing preserves, and creates new preserves in the region with a target of an additional 150,000 acres of land to be preserved across the region over the next 30 years.

We support the concept of building a sustainable local food-shed, which would help in preservation of our region’s remaining farmland, among the best in the world, as well as reducing the energy costs associated with bringing in food from distant places and providing people in our region with fresh, healthy food.

On Regional Mobility, we agree with calls for investment in the existing system and a focus on improving the public transit system.

However, as we read the details of the plan, we have specific concerns which we raise below. Excerpts from the plan are followed by our comments.


Challenges and Opportunities Section

Page 26 Energy and water are not being used efficiently and the region suffers from the degradation of air and water quality.

Page 42 The region should conserve energy and water resources by reducing its consumption in our residential and commercial buildings.

Critical concerns about the quality of the region’s air and water described in the first excerpt are not addressed by the focus on conservation in the second excerpt which was taken from the Conclusion of this section. Specifically, we need to address the quality of our region’s water resources not just the quality of water supplies.


Livable Communities Section

Page 51 By incorporating open space, carefully designing buildings and landscapes, and using small-scale green infrastructure features, the localized negative impacts of density can be avoided.

This is an important, necessary point if we are to sustain and improve the quality of the water resources of our region.

Page 59 Technical assistance activities will often take the form of creating model ordinances or codes for municipal consideration, often on topics like water conservation that may be outside of usual comprehensive planning practice.

The plan should note the important leadership which NIPC/CMAP has provided the region in developing model ordinances addressing water quality issues, consistent with its responsibility for the Regional Water Quality Management Plan. These have been important tools for communities which CMAP needs to continuously update and promote to municipalities.

Page 72 Integrate land use policies and site planning with water resources. Land use policies that promote compact development will reduce residential water use and reduce both capital and operating costs for water utilities. Green infrastructure, like rain gardens and permeable pavement, should be integrated more fully into site planning. Using green infrastructure to manage stormwater has many benefits and can be more cost effective when compared with gray infrastructure.

The plan should directly state the groundwater recharge, improved surface water quality and reduced flooding benefits of using green infrastructure to infiltrate stormwater.

Page 72 Communities that are dependent on groundwater should consider accessing water from the Fox and Kankakee Rivers.

Communities that are dependent on groundwater should be encouraged to vigorously pursue a water management strategy which puts water taken from the ground back on the ground in order to recharge their aquifers. The concerns about the effects of both direct surface water withdrawals and lowering of the water table due to shallow groundwater pumping on the aquatic life in the Fox and Kankakee Rivers cannot be ignored.

Page 80 According to the Illinois State Water Survey (ISWS), flow in the Fox River will continue to increase as a result of population growth and the associated wastewater discharge. As a result, the Fox River has the potential to supply significant new water demands.

That population growth will lead to new wastewater discharges and new water available in the Fox River for human needs should not be assumed. As communities seek to sustain their groundwater supplies, it is likely that they will opt to land apply their wastewater in order to recharge the water to the aquifer from which it was taken. This is especially likely in McHenry County where the bulk of available groundwater is found in the shallow aquifer. Thus, population growth in McHenry County is not likely lead to the assumed increased flows in the Fox River.

Page 81 Furthermore, federally-imposed standards on water providers to control emerging contaminants, such as pharmaceuticals and personal care products, demand costly and energy intensive treatment processes. It is important that the energy implications of such standards are closely studied and mitigated before enforcement.

This statement is disturbing as it does not weigh the serious concerns which are emerging about the adverse impacts which pharmaceuticals and personal care products have on aquatic life which live in streams receiving wastewater dischargers and on the people who take their drinking water supplies from the waters. Cost and energy should not be the predominant considerations.

Page 94 Ideally a watershed plan will consider multi-objective projects that address several problems simultaneously.

Defenders strongly support planning on a watershed scale to simultaneously address water quality, water supply and green infrastructure objectives.


Regional Mobility Section

Our comments on the specifics in this section are summed up by the following quote from the book Suburban Nation. A longer excerpt is found in the endnote to these comments.[i]

“If, as is now clear beyond any reasonable doubt, people maintain an equilibrium of just-bearable traffic, then the traffic engineers are wasting their time--and our money--on a whole new set of stopgap measures that produce temporary results as best. These measures, which include HOV (high-occupancy vehicle) lanes, congestion pricing, timed traffic lights, and "smart streets," serve only to increase highway capacity, which causes more people to drive until the equilibrium condition of crowding returns. While certainly less wasteful than new construction, these measures also do nothing to address the real cause of traffic congestion, which is that people choose to put up with it.” - An excerpt from Suburban Nation: The Rise of Sprawl and the Decline of the American Dream

From: "If you don't want an automobile, you don't have to have one." - Secretary of Transportation Ray LaHood’s definition of Livability

Page 67 "require supportive land use planning before new transit investment is made."

Some land use patterns cannot support transit oriented developments/ investments. Roads must be evaluated in the same context. Land use planning needs to take place before expanded road investments are made. (i.e., Alden Road, Fleming Road project in McHenry County)

Page 166 “While finding new revenues is important, the region needs to get more serious about setting priorities for how existing funds are spent, on both the operating and capital side. The region’s transportation decision makers should stress the use of performance-driven criteria, rather than arbitrary formulas, when making investment decisions. CMAP strongly recommends a focus on maintaining the existing system first, and using most of our remaining resources to modernize the system. While some expansions are necessary, and these will be recommended in the plan’s list of major capital projects, very few of these projects require building brand new facilities from scratch. Instead, the emphasis is on making the existing system operate more efficiently given the amount of funding we can reasonably expect to receive.”

- Once you start listing priority projects, everyone forgets what you just said – all they hear is “this project is a priority”.

- Widening and extending roads does not decrease congestion over time. Focus should be on public transportation systems.

- Good to maintain the existing system – but we also need to consider difference construction standards for roads – if build properly, roads can require much less maintenance and can last longer. Use road construction best practices (e.g. many of Canada’s roadways) to reduce deterioration and maintenance (planned obsolescence).

- Modernizing the system should be focused on the public transportation infrastructure – the only way to truly reduce road congestion is to get people out of cars and into busses, trains, etc. Subsidizing the cost of public transportation coupled with elimination of national subsidies for gasoline can assist here.

Page 167 “Making our system “world class” does not simply require raising taxes or fees for more revenue, nor does it require expanding the system much beyond what is here today. Instead, the primary goal should be to prioritize spending on maintenance and modernization efforts. “Modernization” comprises a range of enhancements, including more comfortable and attractive trains, buses and stations, traveler information systems, state of the art pavement materials with longer life spans, signal timing improvements, bus stop improvements, corridor upgrades, and a variety of other strategies that can improve mobility, access, and the reliability of our transportation network.

- This is excellent (minus the corridor upgrades), but you have to mean it.

- One thing is said here, but then the plan steps in the opposite direction with the priority projects list.

Page 171 “Long-term lease agreements (like the leasing of the Chicago Skyway) involve a publicly- financed transportation facility that is leased to a private-sector entity for a prescribed period of time during which the private entity has the right to collect revenue from the operation of the facility. In exchange, the private entity must operate and maintain the facility, and in some cases make improvements to it.”

- We are highly skeptical of this approach.

- This creates a “lowest-common-denominator” quality of project.

- This also creates a system where the project most likely to make money for a private interest is what gets built, over the project that is high quality but less profitable.

Page 185 “Both auto and transit trips increase, and transit’s mode share grows slightly. The high-priority projects support GO TO 2040’s focus on reinvestment in existing communities, and they have limited impact on sensitive natural areas. On the other hand, the projects do have negative impacts on most air quality outcomes. This occurs mostly because the region is expected to be larger (in terms of households and jobs) than it would have been without the projects, and also because the projects improve mobility within the region and hence lead to additional travel. The negative impacts on air quality are minor, and are more than compensated for by the positive impacts of the strategies within GO TO 2040. They are also well within expected air quality conformity limits.”

- The plan needs to promote steps to improve regional air quality, not make it even worse by proposing a suite of projects which will make the problem worse.


New Projects or Extensions
Central Lake County Corridor: IL 53 North and IL 120 Limited Access
Elgin O'Hare Expressway Improvements (includes Western O'Hare Bypass, EOE East
Extension, and EOE Add Lanes)

-Better to use the money spent on these projects to improve mass transit
- IL 53 North corridor runs contrary to stated intent of the plan

CTA Red Line Extension (South)
West Loop Transportation Center

Expressway Additions and Improvements
I-190 Access Improvements
I-80 Add Lanes (US 30 to US 45)
I-88 Add Lanes
I-94 Add Lanes North
I-294/I-57 Interchange Addition

- Better to use the money spent on these projects to improve mass transit. Increasing the load capacity on these areas is ultimately short sighted (See quote from Suburban Nation and endnote.)

Managed Lanes and Multimodal Corridors
I-55 Managed Lanes
I-90 Managed Lanes
I-290 Multimodal Corridor

- Better to use the money spent on these projects to improve mass transit. Increasing the load capacity on these areas is ultimately short sighted (See quote from Suburban Nation and endnote.)

Transit Improvements
CTA North Red/Purple Line Improvements
Metra Rock Island Improvements
Metra Southwest Service Improvements.
Metra UP North Improvements
Metra UP Northwest Improvements/Extension
Metra UP West Improvements

- Need to ensure that these improvements are not built in far out places that do not and should not have the population capacity needed to sustain or justify their construction and maintenance. Mass transportation is self defeating if it ends up actually encouraging sprawl development by pacing itself ahead of perceived demands.


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[i] Why building new roads doesn't ease congestion
An excerpt from Suburban Nation: The Rise of Sprawl and the Decline of the American Dream
by Andres Duany, Elizabeth Plater-Zyberk, and Jeff Speck
North Point Press, 2000, pp. 88-94.

There is, however, a much deeper problem than the way highways are placed and managed. It raises the question of why we are still building highways at all. The simple truth is that building more highways and widening existing roads, almost always motivated by concern over traffic, does nothing to reduce traffic. In the long run, in fact, it increases traffic. This revelation is so counterintuitive that it bears repeating: adding lanes makes traffic worse. This paradox was suspected as early as 1942 by Robert Moses, who noticed that the highways he had built around New York City in 1939 were somehow generating greater traffic problems than had existed previously. Since then, the phenomenon has been well documented, most notably in 1989, when the Southern California Association of Governments concluded that traffic-assistance measures, be they adding lanes, or even double-decking the roadways, would have no more than a cosmetic effect on Los Angeles' traffic problems. The best it could offer was to tell people to work closer to home, which is precisely what highway building mitigates against.

Across the Atlantic, the British government reached a similar conclusion. Its studies showed that increased traffic capacity causes people to drive more--a lot more--such that half of any driving-time savings generated by new roadways are lost in the short run. In the long run, potentially all savings are expected to be lost. In the words of the Transport Minister, "The fact of the matter is that we cannot tackle our traffic problems by building more roads."2 While the British have responded to this discovery by drastically cutting their road-building budgets, no such thing can be said about Americans.

There is no shortage of hard data. A recent University of California at Berkeley study covering thirty California counties between 1973 and 1990 found that, for every 10 percent increase in roadway capacity, traffic increased 9 percent within four years' time.3 For anecdotal evidence, one need only look at commuting patterns in those cities with expensive new highway systems. USA Today published the following report on Atlanta: "For years, Atlanta tried to ward off traffic problems by building more miles of highways per capita than any other urban area except Kansas City…As a result of the area's sprawl, Atlantans now drive an average of 35 miles a day, more than residents of any other city."· This phenomenon, which is now well known to those members of the transportation industry who wish to acknowledge it, has come to be called induced traffic.

The mechanism at work behind induced traffic is elegantly explained by an aphorism gaining popularity among traffic engineers: "Trying to cure traffic congestion by adding more capacity is like trying to cure obesity by loosening your belt." Increased traffic capacity makes longer commutes less burdensome, and as a result, people are willing to live farther and farther from their workplace. As increasing numbers of people make similar decisions, the long-distance commute grows as crowded as the inner city, commuters clamor for additional lanes, and the cycle repeats itself. This problem is compounded by the hierarchical organization of the new roadways, which concentrate through traffic on as few streets as possible.

The phenomenon of induced traffic works in reverse as well. When New York's West Side Highway collapsed in 1973, an NYDOT study showed that 93 percent of the car trips lost did not reappear elsewhere; people simply stopped driving. A similar result accompanied the destruction of San Francisco's Embarcadero Freeway in the 1989 earthquake. Citizens voted to remove the freeway entirely despite the apocalyptic warnings of traffic engineers. Surprisingly, a recent British study found that downtown road removals tend to boost local economies, while new roads lead to higher urban unemployment. So much for road-building as a way to spur the economy.

If traffic is to be discussed responsibly, it must first be made clear that the level of traffic which drivers experience daily, and which they bemoan so vehemently, is only as high as they are willing to countenance. If it were not, they would adjust their behavior and move, carpool, take transit, or just stay at home, as some choose to do. How crowded a roadway is at any given moment represents a condition of equilibrium between people's desire to drive and their reluctance to fight traffic. Because people are willing to suffer inordinately in traffic before seeking alternatives--other than clamoring for more highways--the state of equilibrium of all busy roads is to have stop-and-go traffic. The question is not how many lanes must be built to ease congestion but how many lanes of congestion would you want? Do you favor four lanes of bumper-to-bumper traffic at rush hour, or sixteen?

This condition is best explained by what specialists call latent demand. Since the real constraint on driving is traffic, not cost, people are always ready to make more trips when the traffic goes away. The number of latent trips is huge--perhaps 30 percent of existing traffic. Because of latent demand, adding lanes is futile, since drivers are already poised to use them up.4

While the befuddling fact of induced traffic is well understood by sophisticated traffic engineers, it might as well be a secret, so poorly has it been disseminated. The computer models that transportation consultants use do not even consider it, and most local public works directors have never heard of it at all. As a result, from Maine to Hawaii, city, county, and even state engineering departments continue to build more roadways in anticipation of increased traffic, and, in doing, create that traffic. The most irksome aspect of this situation is that these road-builders are never proved wrong; in fact, they are always proved 'right': "You see," they say, "I told you that traffic was coming."

The ramifications are quite unsettling. Almost all of the billions of dollars spent on road-building over the past decades have accomplished only one thing, which is to increase the amount of time that we must spend in our cars each day. Americans now drive twice as many miles per year as they did just twenty years ago. Since 1969, the number of miles cars travel has grown at four times the population rate.· And we're just getting started: federal highway officials predict that over the next twenty years congestion will quadruple. Still, every congressman, it seems, wants a new highway to his credit.·

Thankfully, alternatives to road-building are being offered, but they are equally misguided. If, as is now clear beyond any reasonable doubt, people maintain an equilibrium of just-bearable traffic, then the traffic engineers are wasting their time--and our money--on a whole new set of stopgap measures that produce temporary results as best. These measures, which include HOV (high-occupancy vehicle) lanes, congestion pricing, timed traffic lights, and "smart streets," serve only to increase highway capacity, which causes more people to drive until the equilibrium condition of crowding returns. While certainly less wasteful than new construction, these measures also do nothing to address the real cause of traffic congestion, which is that people choose to put up with it.

We must admit that, in an ideal world, we would be able to build our way out of traffic congestion. The new construction of 50 percent of more highways nationwide would most likely overcome all of the latent demand. However, to provide more than temporary relief, this huge investment would have to be undertaken hand in hand with a moratorium on suburban growth. Otherwise, the new subdivisions, shopping malls, and office parks made possible by the new roadways would eventually choke them as well. In the real world, such moratoriums are rarely possible, which is why road-building is typically a folly.

Those who are skeptical of the need for a fundamental reconsideration of transportation planning should take note of something we experienced a few years ago. In a large working session on the design of Playa Vista, an urban infill project in Los Angeles, the traffic engineer was presenting a report of current and projected congestion around the development. From our seat by the window, we had an unobstructed rush-hour view of a street he had diagnosed as highly congested and in need of widening. Why, then, was traffic flowing smoothly, with hardly any stacking at the traffic light? When we asked, the traffic engineer offered an answer that should be recorded permanently in the annals of the profession: "The computer model that we use does not necessarily bear any relationship to reality."

But the real question is why so many drivers choose to sit for hours in bumper-to-bumper traffic without seeking alternatives. Is it a manifestation of some deep-seated self-loathing, or are people just stupid? The answer is that people are actually quite smart, and their decision to submit themselves to the misery of suburban commuting is a sophisticated response to a set of circumstances that are as troubling as their result. Automobile use is the intelligent choice for most Americans because it is what economists refer to as a "free good": the consumer pays only a fraction of its true cost. The authors Stanley Hart and Alvin Spivak have explained that:

We learn in first-year economics what happens when products or services become "free" goods. The market functions chaotically; demand goes through the roof. In most American cities, parking spaces, roads and freeways are free goods. Local government services to the motorist and to the trucking industry--traffic engineering, traffic control, traffic lights, police and fire protection, street repair and maintenance--are all free goods.·

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1 This article is an excerpt from Andres Duany, Elizabeth Plater-Zyberk, and Jeff Speck. Suburban Nation: The Rise of Sprawl and the Decline of the American Dream, North Point Press, 2000, 88-94.

2 Donald D.T. Chen. "If You Build It, They Will Come…Why We Can't Build Ourselves Our of Congestion." Surface Transportation Policy Project Progress VII.2 (March 1998): I, 4.

3 Ibid., 6.
Carol Jouzatis. "39 Million People Work, Live Outside City Centers." USA Today, November 4, 1997: 1A-2A. As a result of its massive highway construction, the Atlanta area is "one of the nation's worst violators of Federal standards for ground-level ozone, with most of the problem caused by motor-vehicle emissions" (Kevin Sack. "Governor Proposes Remedy for Atlanta Sprawl." The New York Times, January 26, 1999: A14).
·
Jill Kruse. "Remove It and They Will Disappear: Why Building New Roads Isn't Always the Answer." Surface Transportation Policy Project Progress VII:2 (March 1998): 5, 7. This study, in analyzing sixty road closures worldwide, found that 20 percent to 60 percent of driving trips disappeared rather than materializing elsewhere.

4 Stanley Hart and Alvin Spivak. The Elephant in the Bedroom: Automobile Dependence and Denial; Impacts on the Economy and Environment. Pasadena, Calif.: New Paradigm Books, 1993, 122.
·
Jane Holtz Kay. Asphalt Nation: How the Automobile Took Over America, and How We Can Take It Back. New York: Crown, 1997, 15; and Peter Calthorpe. The Next American Metropolis: Ecology, Community, and the American Dream. New York: Princeton Architectural Press, 1993, 27. Since 1983, the number of miles cars travel has grown at eight time s the population rate (Urban Land Institute traffic study). The greatest increases in automobile use correspond to the greatest concentrations of sprawl. Annual gasoline consumption per person in Phoenix and Houston is over 50 percent higher than in Chicago or Washington, D.C., and over 500 percent higher than in London or Tokyo (Peter Newman and Jeff Kenworthy. Winning Back the Cities. Sydney: Photo Press, 1996, 9). Currently, almost 70 percent of urban freeways are clogged during rush hour (Jason Vest, Warren Cohen, and Mike Tharp. "Road Rage." U.S. News & World Report, June 2, 1997: 24-30). In Los Angeles, congestion has already reduced average freeway speeds to less than 31 mph; by the year 2010, they are projected to fall to 11 mph (James MacKenzie, Roger Dower, and Donald Chen. The Going Rate: What It Really Costs to Drive. Report by the World Resources Institute, 1992, 17).
·
Almost any situation seems acceptable to justify more highway spending, even the recent road rage epidemic. Representative Bud Schuster, the chairman of the U.S. Congressional Committee on Transportation and Infrastructure, made this recommendation: "The construction of additional lanes, the widening of roads and the straightening of curves would decrease congestion and reduce the impatience and unsafe habits of some motorists" (Thomas Palmer. "Pacifying Road Warriors." The Boston Globe, July 25, 1997: A1, B5).
·
Stanley Hard and Alvin Spivak, The Elephant in the Bedroom: Automobile Dependence and Denial, 2. Much of the information here on the science and economics of traffic congestion comes from this book, which should be required reading for every professional planner, traffic engineer, and amateur highway activist.

The logic behind the desire to make use of free goods is suggested by an argument overheard at a recent planning conference: "Of course there's never enough parking! If you gave everyone free pizza, would there be enough pizza?"
 

GO TO 2040 "Invent the Future" Workshops - 2009 

-paraphrased from Chicago Wilderness