Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
1
EXECUTIVE SUMMARY
This region has experienced a succession of lengthy and expensive battles over proposals to
build new highways. In the case of the Crosstown Expressway, proposed for Chicago's west
side during the 1960s and 1970s, public outcry killed the project outright. In Lake County,
several expensive studies over multiple decades have attempted to justify a tollway extension,
but there is still a lack of consensus about a proposed extension of I-53. And in Will County, the
battle against the extension of I-355 has raged for almost as long as the I-53 battle; that project
has experienced two setbacks due to inadequate engineering and environmental assessments.
Inadequate and incomplete engineering studies fuel public distrust and create tenable grounds for
legal challenges. Years of study consume millions of public dollars and leave households in or
near the proposed right-of-way in a legal limbo. Incomplete or inaccurate studies that spawn
litigation have to be repeated to compensate for earlier omissions, or to accommodate changing
conditions, adding millions more to the price tag for projects that may never overcome public
resistance or environmental obstacles. For these reasons, we all want to be very careful to
commit these planning dollars very wisely, for projects that have widespread public support and
where the benefits can clearly be seen to outweigh the costs for the greatest number of people.
Whatever one's position on a given project, it is reasonable to assume all Illinois taxpayers can
agree on certain principles in order to use our transportation funds efficiently:
Projects must respond to a clearly documented need
The benefits of a project must exceed the costs
Professional studies must be comprehensive
Professional studies must be accessible to the public.
On that fourth point, the Illinois Department of Transportation (IDOT) has taken an important
first step. The Preliminary Engineering Study, Part A (PES-A) for the Prairie Parkway is
available to the general public on an IDOT District Three web site,
1
along with a number of other
useful documents.
The PES-A is the first in a series of multi-year investigations into the feasibility, cost and
barriers to the project. The purpose of this review of the Prairie Parkway PES-A is to ask
whether it will provide an adequate basis for future decision-making on the project, so that the
public may be assured that planning dollars respond to a clear need. Active debate about the
quality of this planning product can only improve the quality of future products.
The PES-A seems designed to reach a foregone conclusion rather than investigate the best
alternative for responding to transportation needs. Our review of the PES-A reveals several
areas where information is omitted, imprecise or inadequately analyzed. This review focuses
heavily on the sections that are comprehensible to laypersons; a review of the engineering
1
http://www.prairie-parkway.com/
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
2
assumptions by a qualified professional might uncover additional discrepancies in the formulae
and methodologies used to assess future traffic volumes and patterns.
The PES-A fails to lay the groundwork for documenting the purpose and need for a highway in
sparsely populated western Kendall and Kane Counties. It fails to build an adequate foundation
to conduct federally required environmental assessments. It explicitly excludes populations
protected under Environmental Justice policy and civil rights laws. In some areas, the PES-A
violates "best practices" as well as the law.
This review of the PES-A begins with an overview of the context and history surrounding the
proposed Prairie Parkway (pages 7 to 11). It concludes with a critique of selective sections of
the PES-A (pages 12 to 23), sections that seem designed to support only one option. The critique
reveals the following:
The PES-A relies on large percentage changes to small base numbers to inflate the need
for a new highway in western Kane and Kendall Counties.
In several cases the data suggest one remedy and the analysts offer another, in order to
justify the Prairie Parkway as the only logical alternative. Currently, the highest traffic
volumes are in the eastern portion of the study area. Future increases in volume are
expected to be "greatest in the central and eastern study area and become less pronounced
to the western portions" (PES-A, p. 4-18).
The study area stops short of I-39 to the west, which is an existing north-south interstate
route with relatively low average daily traffic.
The population in the study area is inflated in a number of ways. CTAQC provides a
more precise count of population in this review. The number of people living in a 10-
mile corridor centered on the recorded right-of-way is 47,925. The number of people
living within the boundaries of the study area defined by IDOT is 552,093. The PES-A
includes the total population of any county that falls partially within the study area,
inflating the population to 1.2 million. The purpose of including populous areas at a
good distance from the project is to conceal that only a negligible number of drivers and
businesses could make regular use of the proposed project -- unless rapid development
follows construction of the highway.
Safety analysis fails to differentiate between fatal, serious-injury and property damage
crashes, current and forecasted.
The PES-A fails to assess the effect on household income of forcing all residents of
eastern and western sections of the study area to drive for all trips (households that have
no options except to own multiple vehicles devote a much larger percent of household
budgets to transportation costs than do households with travel options)
2
.
The bulk of the Characteristics and Measures section of the PES-A is comprised of traffic
counts, driver surveys, travel forecasts and other technical measures that fail for the same
reason the demographic analyses failed -- the underlying assumptions are narrow and
faulty or the use of large percentage increases to low base numbers inflates the
seriousness of the need.
2
Driven to Spend, Surface Transportation Policy Project,
2000
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
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The PES-A fails to begin an inventory of environmental and historic assets that would be
impacted or destroyed by a proposed Prairie Parkway. The project's fate is directly and
profoundly dependent on being able to overcome several tests to prove compliance with
federal environmental standards.
Public involvement activities conducted for the purposes of this study were somewhat
improved over past efforts, but still left a great deal to be desired. Populations most
frequently asked to take part in public involvement activities were disproportionately
representative of sparsely populated sections of the region rather than from the congested
eastern corridor.
There are serious omissions in the data gathered. Environmental justice implications are casually
ignored. Minorities, non-drivers and seniors appear to have been excluded from the focus
groups, a potential violation of Environmental Justice policies, and laws protecting civil rights
and access by disabled populations.
The review concludes by offering the following recommendations derived from federal and state
Context Sensitive Design policies:
1.
Conduct public involvement workshops, focus groups and surveys that proportionally
reflect the views of the population centers of Kane and Kendall County.
2.
Remediate the exclusion of non-drivers, seniors and environmental justice communities.
3.
Broaden the public dialog to include multimodal options (the public has repeatedly
proposed multimodal options even when explicitly instructed to respond to a highway
proposal).
4.
Address the need to provide new options where congestion exists in a rapidly developing
corridor that already has over half a million people but little travel choice.
5.
Extensively study options that were proposed by the public, such as reconfiguring IL 47
(or a similar north-south corridor) and providing transit options in the populated eastern
corridor.
6.
Evaluate the potential to decrease traffic fatalities by offering alternatives to high speed
auto travel.
7.
Accurately assess the cost/benefit ratio to environmental, agricultural and community
assets of a multimodal option in the eastern corridor versus the auto-only alternative in
the sparsely populated western corridor.
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
4
Preface
The Chicagoland Transportation and Air Quality Commission (CTAQC) is a regional coalition
promoting integrated land use and transportation planning, transparent decision-making and
citizen participation in the planning process. Almost two hundred organizations from the six-
county northeastern Illinois region have joined CTAQC as endorsers of a regional vision for
participatory, community-building transportation planning. Local partners who assisted in the
development of this report include Aux Sable Creek Watershed Coalition, Big Rock Creek
Watershed Committee and Citizens Against the Sprawlway.
Throughout its ten-year history, CTAQC has been dedicated to the proposition that taxpayers'
opinions should be solicited and documented. Transportation investment decisions should
respond to those documented priorities.
Index
I.
Introduction
II.
History and Background
III.
Preliminary Engineering Study -- Observations and Analyses
A.
Socioeconomic Analyses
B.
Traffic Characteristics/Transportation System Performance Measures
C.
Public Involvement
D.
Environmental and Historic Constraints
IV. Conclusion and Recommendations
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
5
I. Introduction
The Context for Transportation Studies
The Illinois Department of Transportation (IDOT) has committed $18 million to study a
proposed "Prairie Parkway." Federal sources provided $15 million; the remaining $3 million is
from the state transportation budget. Planning a new transportation facility is a multi-year
process; the planning horizon is likely to span more than a decade, especially if there is a lack of
consensus in the region about the likely benefit of or need for the project.
The purpose of this review is to assess whether the Preliminary Engineering Study for the
Prairie Parkway will provide an adequate basis for future decision-making on the project. Part
A of the Preliminary Engineering Study (PES-A), which was released in 2004, is also known as
the Transportation System Performance Report. The PES-A will frame the federally required
"Purpose and Need Statement." The P & N guides the development of possible alternative
corridors, and may be refined as information evolves. If there is not a full, well-documented
investigation of all the challenges and opportunities of a given project, the P & N and the
alternatives may be limited in scope. A poorly planned project may increase, rather than
decrease, congestion. Part A may narrow the options considered in Part B (the more detailed
study that is underway now) unless those limitations are challenged.
Under state and federal law, the public is to be included in the decision-making throughout the
process. The timeline below comes from the IDOT District 3 Prairie Parkway website.
3
This PES-A was developed by a respected engineering consulting firm, but fails to address
recent modifications in transportation decision-making at both the state and federal levels. The
preliminary engineering study seems to have been crafted in response to an outmoded consultant
solicitation for a highway plan, rather than a
transportation plan. No attempt was made to verify
that conjecture; the purpose of this report is to stimulate improvements to the process rather than
assign blame for past decisions.
The Illinois Department of Transportation has, very recently, joined the Federal Highway
Administration (FHWA) and other transportation professionals in acknowledging that the era of
3
http://www.prairie-parkway.com/
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
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indiscriminate road building is over. What the taxpaying public demands now is best addressed
by quality of life and connectivity enhancements. Projects of this magnitude are constrained by a
number of federal and state laws. The PES-A and subsequent reports will be assessed for
conformance with the requirements of those laws.
Inadequately constructed analysis leaves the state vulnerable in the courts of law and of public
opinion. The project will surely be challenged in court; designation of specific parcels as
"recorded" for one proposed right-of-way has already been challenged. Even if the proposed
project should ultimately prevail, the "victory" will be expensive and time-consuming.
Meanwhile, the opportunity to address popular consensus on transportation resources may be
overshadowed by the conflict.
At this point, midway through the development of Part B of the Preliminary Engineering Study,
there is sufficient time to correct the deficiencies of Part A, respond to the changing dynamics in
highway planning and hopefully, avoid a long and costly series of court battles over this
contentious issue.
Primary Finding: Preliminary Engineering Study is Inadequate
This analysis of the PES-A uncovers deficiencies and omissions in the
scope of the investigation,
in the gathering and analysis of data, and in the
required public involvement processes. The
PES-A fails to set the groundwork for future documentation of purpose and need, NEPA
4
analysis and an eventual Environmental Impact Statement. Flawed statistical procedures render
some of the information unreliable. The failure of the PES-A to assess the "transportation
system" as a whole, rather than as a highway system, encourages the notion that the study is
designed to reach a foregone conclusion. In some areas, the PES-A violates the law as well as
"best practices." Exclusion of the travel needs of substantial populations (non-drivers,
minorities, elders or children) is certainly poor practice; it may be actionable in court too.
4
National Environmental Policy Act
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
7
II. History and Background
Official Actions
County
Kane County has a comprehensive growth plan, the
200 Kane County Land Resource
Management Plan (adopted in 2004) which explicitly preserves farmland in the western third of
the county and attempts to direct growth to existing communities along the Fox River Corridor
and elsewhere in the county. Kendall County's comprehensive plan is approximately ten years
old. The county is conducting a township-by-township rewrite of the plan, which currently
includes policies on farmland preservation, open space protection and greenways. Nearby
DeKalb County adopted a comprehensive plan in 2000 which emphasizes agricultural
preservation and encourages development in existing urbanized areas.
Regional
Every metropolitan region must, under federal law, develop a fiscally constrained long-range
plan projecting at least 20 years into the future. These plans must be updated every three years.
Theoretically, transportation planners -- in consultation with land use planners, municipalities
and the public -- develop a general framework to be implemented by IDOT, the transit agencies,
municipalities and counties. This framework must, by federal law, ensure the maintenance of
existing infrastructure. Any proposals to expend limited resources for a new project must be
screened for environmental impact, cost-effectiveness and other objective measures.
For a number of complicated reasons, the transportation planning process in northeastern Illinois
operates contrary to the ideal. Political decisions determine what will be funded and built. The
"plan" is fashioned around favored projects rather than projects to address regional needs. The
official regional planning process is at best parallel to, and at worst beholden to, formidable
political imperatives.
The Chicago Area Transportation Study (CATS) has developed the region's official long-range
transportation plan since 1955. CATS is charged with developing plans for the six counties of
northeastern Illinois: Cook, DuPage, Kane, Lake, McHenry and Will. Northeastern Illinois is in
"serious non-attainment" of federal air quality standards. For purposes of air quality analysis, a
small portion of northeast Kendall County is included in CATS' domain. Currently, discussions
are underway about adding all of Kendall County to the official planning area.
Neither of CATS' last two long-range plans included the Prairie Parkway, at least not as it is
proposed today. The 2020 Regional Transportation Plan, developed in 1997 and revised in
2000, referred to an "Outer Belt Corridor from I-90 to I-88" as a project for future study (the
current study is for a corridor between I-88 and I-80). The plan cautions: "Given the agricultural
nature of this corridor, future studies will need to pay special attention to any proposed project's
consistency with the 2020 Kane County Land Resource Management Plan." At least twenty
projects were considered more critical for the region than the Outer Belt; no funds were allocated
at that time for a study.
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
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The 2030 Regional Transportation Plan scrambled to align itself with rapidly moving political
developments. The Prairie Parkway is described this way in the 2030 plan (adopted in October
2003):
The initial proposal is to introduce a new highway facility connecting I-80 to I-88 in
Kane and Kendall Counties. This portion of Kendall County has experienced rapid
growth in the past several years. The Illinois Department of Transportation has recently
acted to preserve a corridor in the area, and has initiated a preliminary engineering study.
The RTP recommends that alignment, staging and facility alternatives be considered in
the study to address community and environmental concerns.
The project is in a watershed identified as very high priority for protection and restoration
in Kane and Kendall Counties. The project also traverses prime farmland. Consideration
of farmland protection is recommended.
The Northeastern Illinois Planning Commission
(NIPC) provided CATS with an environmental
impact score for every potential project prior to inclusion in the plan. The Prairie Parkway was
among the most environmentally damaging projects measured.
State and federal action
Federal transportation law was revolutionized in 1991 when the "Highway Bill" became the
Intermodal Surface Transportation Efficiency Act (ISTEA). ISTEA, and its successor TEA-21,
require a comprehensive approach to meeting transportation needs. ISTEA calls for meaningful
public involvement, which the FHWA defines as the three Cs -- continuous, comprehensive and
collaborative. Other federal laws, including the Clean Air Act (CAAA), the National
Environmental Policy Act (NEPA) and the Americans with Disabilities Act (ADA), impact
transportation planning and funding decisions too. These will be discussed further in other
sections of this report.
The FHWA began to promote better planning practices through "Context Sensitive Design"
(CSD) in the 1990s. CSD's three major foci are: 1) multi-modal planning; 2) inclusion of the
public in the planning process early and often; and 3) respect for the historic, environmental,
cultural and economic assets of a corridor. The Illinois General Assembly directed IDOT to
develop a CSD strategy in 2003. IDOT has done so, rechristening its methodology as Context
Sensitive Solutions.
CSS is being implemented very slowly in Illinois, partly because funding constraints prevent the
retraining of engineers who are typically not skilled at facilitating public meetings. IDOT views
the Prairie Parkway as a premier example of CSS implementation in Illinois.
The implementation of CSS in the case of the Prairie Parkway is complicated by previous IDOT
action to preserve a specific corridor without conducting studies of the purpose, need and impact.
For the purposes of this review, the proposed corridor is assumed to be generally illustrative of
IDOT plans, although variations might be made if a final alignment is chosen.
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
9
Official Boundaries are Fluid
Most of the proposed Prairie Parkway is outside the traditional six-county northeastern Illinois
region, where CATS, NIPC and IDOT's District One office have had planning and
implementation responsibility for many decades.
5
Approximately three-quarters of the proposed
corridor is in Kendall County (IDOT District Three). Most of the remainder is in Kane County
(IDOT District One), and a segment that appears less than a mile touches on Grundy County
(IDOT District Three).
What Does the Public Say?
There have been numerous regional planning processes -- by NIPC, CATS, and CTAQC -- in
the last three to five years that provide ample documentation of the public's priorities for Kane
County. The heavily populated eastern edge of Kane County has a history of consensus on the
need for north-south transit access. The documentary record for Kendall County is less robust
because Kendall County is not part of the northeastern Illinois region.
NIPC documentation of public opinion
The most recent Kane County visioning process was a May 2004 Paint the Town Workshop
conducted by the Northeastern Illinois Planning Commission. The report is available on NIPC's
website.
6
NIPC's participatory process elicits information through surveys and computer
mapping. Survey questions are customized to reflect "headlines" defined by the community.
Relevant headlines in Kane County include:
Table 1
Paint the Town Survey Responses
Headlines
Desirable,
likely
Desirable,
not likely
Likely, not
desirable
Not likely, not
desirable
Not
sure
Direct jobs, population and
investment to the centers
55.6 38.9 0.0
0.0
5.6
Improve existing transportation
(Corridors) across the county
57.9 42.1 0.0
0.0
0.0
Commit to the County's planning for
agriculture, green space, biodiversity
57.9 42.1 0.0
0.0
0.0
Direct growth to existing centers
60.0
35.0
0.0
0.0
0.0
. . .combine greenway corridor with
Prairie Parkway -- 1 mile wide, no
commercial development
10.5 78.9 0.0
10.5
0.0
Enhance intra-suburban mass transit,
e.g. Star Line
50.0 45.0 0.0
5.0
0.0
Improve . . . Randall Road corridor
with bus transit, trail, commuter bike
73.7 26.3 0.0
0.0
0.0
5
The six-county area includes Cook, DuPage, Kane, Lake, McHenry and Will counties.
6
http://www.nipc.org/cg/forums/clusterwrkshp/KaneReport.pdf
Review of the Prairie Parkway Preliminary Engineering Study, Part A
Chicagoland Transportation and Air Quality Commission
_______________________________________________________________
May 9, 2005
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In Kane County there is near unanimity on concepts like enhancing existing transportation and
community assets, protecting open space, honoring county plans and increasing mass transit.
When the Prairie Parkway is addressed, it is only in the context of minimizing the harmful
impacts if the project becomes a reality -- constructing the road is not a priority. These results
come from anonymous keypad polling of a study group that was comprised of municipal, county
and other governmental representatives (80% of the total group) and general community
members (20%).
CATS documentation of public opinion
CATS publishes all documentation related to its plans as raw data, without analysis. Recently
collected public opinion revolved around the adoption of the 2030 Regional Transportation Plan
(2003). The Center for Neighborhood Technology (CNT) conducted a limited analysis of 280
comments published by CATS through May of 2003
7
. General themes, such as support for a
particular mode, were tabulated. Hundreds of individual projects were mentioned; CNT
analyzed only the comments for the large projects. The following is an excerpt from that report:
The table below shows the range of opinion among the 280 tabulated responses on the
five major projects that were most often mentioned.
Total
8
Rt 53 ext I-355 ext Prairie
Pkw
I-290 ex-
pansion
E-W
transit
Favor
69
32 16 8 3 15
Oppose
50
22 10 26 17 0
In general it is fair to say that road expansions, extensions and new projects are much
more controversial than transit projects and in some cases are overwhelmingly rejected
by the public. There is little ambiguity about the taxpayers' desire on the Prairie Parkway
and the widening of I-290. The Prairie Parkway case is even more conclusive when on