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
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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
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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
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May 9, 2005
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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
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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
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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
_______________________________________________________________
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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.
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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
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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
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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 one
looks closely at the eight favorable responses. Three of the responses coded as in favor
of the Parkway were specific in saying that right-of-way should be preserved for a future
decision on the need for the road, rather than supporting construction of the road.
Investment in transit was resoundingly desired throughout the region. A summary of the
findings from the CNT review are below:
There was overwhelming support for transit investment (transit investment includes
mentions of specific projects, as well as general expressions of support for either rail or
bus). Of the 280 comments tabulated from Volume I, 166 were in support of either
general or specific transit improvements.
Connecting Communities documentation of public opinion
The Chicagoland Transportation and Air Quality Commission conducted widespread public
outreach in 2001 and 2002, in anticipation of the CATS 2030 Regional Transportation Plan.
7
Analysis of Public Comment on a Prairie Parkway Alignment
,
Center for Neighborhood Technology, 2004,
http://www.cnt.org/tsp/trans/ctaqc/prairie-parkway
8
Some commented on more than one project, making the sum of all comments larger than the number of
commenters.
Review of the Prairie Parkway Preliminary Engineering Study, Part A
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Like NIPC, CTAQC published a summary report from each local meeting. The Kane County
Connecting Communities report is available on the CTAQC website.
9
The primary
recommendations from the summit were:
· Invest heavily in transit in the Fox River corridor.
· Increase public participation in planning.
· Make those small bicycle and pedestrians improvements now.
· Respect our county land management plan.
In reference to the fourth recommendation, Kane County residents said, "Institutional attempts to
create an outer belt highway should be suspended indefinitely."
CTAQC revisited each community two years after its original (2001) meeting. Results of the
December 2003 Kane County meeting can be found on the CTAQC website.
10
In assessing the
two years that elapsed since their original recommendations, Kane County residents reported:
Caucus participants generally supported county land use and transportation plans. There
is concern that Kane County plans are jeopardized by unchecked development in adjacent
counties or by political agendas that are pursued "behind closed doors," particularly the
outer beltway proposal. In particular this group was adamant that the outer beltway
project be abandoned. It is a project that does not reflect the interests of the residents of
the region, but rather the interests of developers and elected officials.
9
http://www.cnt.org/tsp/trans/ctaqc/cc/summitpubs.htm
10
http://www.cnt.org/tsp/trans/ctaqc/state-of-region-report/
, select Kane County report
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III. Review of the Preliminary Engineering Study
Of the seven chapters of the Preliminary Engineering Study, Part A, most provide a woefully
inadequate basis for future decision-making. To avoid repetition, we will focus on the four
chapters where these biases are most egregious and on one additional area that is overlooked
entirely -- Environmental and Historic Constraints. The chapters of the PES-A on which we
focus are:
A.
Socioeconomic Analyses
B.
Traffic Characteristics/Transportation System Performance Measures
11
C.
Public Involvement
An additional section on Environmental and Historic Constraints follow the review of the above
chapters.
A. Socioeconomic Analyses
The PES-A consistently relies on large percentage changes to small base numbers to inflate the
need for new transportation infrastructure in western Kane and Kendall Counties. The study
area, which falls mostly in Kendall County (population 54,544) is unrealistically inflated to
include 1.2 million residents. The transportation challenges faced by residents of the Fox River
Valley are noted but unheeded in the effort to justify a new highway.
There are serious omissions in the data studied on a variety of levels, including:
Environmental justice implications are casually ignored by skewing the data so that older,
younger, non-white and disabled residents are excluded.
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 denying transportation
options to residents of eastern and western sections of the study area.
Population
The official study area defined in the PES-A includes all of Kendall County (2000 population
54,544) and a portion of DeKalb, Grundy, Kane, LaSalle and Will Counties. The PES-A begins
with the assumption of a population of nearly 1.2 million by computing the total populations of
those counties, rather than computing the study area population. For instance, all of Will
County's population is included in computations although only a narrow sliver on the western
edge of Will County is within the study area. Given the large geographic area of Will County, its
inclusion in totality is unwarranted. For instance, the distance from Yorkville -- roughly the
center point of the Prairie Parkway -- to Crete, in eastern Will County, is 64 miles. LaSalle
County's total population of 111,509 is included in the projections although the only populated
portion, the LaSalle-Ottawa-Peru urbanized area in the center of the county, is not within the
study area (LaSalle County's projected growth areas are not within the study area either).
11
For the purposes of this review, the PES-A chapters on "Traffic Characteristics" and "Transportation Performance
Measures" are discussed simultaneously.
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Kendall County, which appears to have about 75% of the proposed miles of Parkway, has 54,544
residents and is projected to grow by 140% to 131,000 by 2030. If the county reaches those
projections, it will be less populous than Aurora is today.
Calculations performed in the course of this review show that the total population living within
the boundaries of the study area was 552,093 in 2000. The 1.2 million population figure used in
the PES-A is an obvious attempt to inflate the number of presumed beneficiaries well beyond
reasonable estimates. The actual population figures are reproduced in the table below, along
with information on racial/ethnic diversity and the amount of land area covered by each of three
geographies calculated for this review. The actual population of the corridor for five miles on
either side of the proposed alignment (a ten-mile wide corridor) is displayed here as is the total
population for the corridor five miles on either side of the Fox River, through the length of Kane
County. The population of the Fox River Corridor is more than 12 times that of the Prairie
Parkway Corridor; the population that needs relief from traffic congestion is in eastern Kane and
Kendall Counties.
The PES-A does not report on racial/ethnic diversity of the study area. Our calculations show a
substantial and growing minority population that may have been excluded from consideration
under the limited parameters of the PES-A.
Table 2
Population of Study Area, Prairie Parkway Corridor and Fox River Corridor
Total Population
Percent Minority
Area in Acres
IDOT Study Area
552,093
20%
1,020,238
Fox River Corridor
589,440
29%
264,272
Prairie Parkway Corridor 47,925
8%
272,322
These complex relationships and geographies are illustrated in the map on the following page.
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Figure 1. Population of the Study Area, the Fox River Corridor
and the Prairie Parkway Corridor
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The most populous towns within the corridor and their actual growth rates since 1980 are
displayed below:
12
Table 3
Population by Municipality, Prairie Parkway Corridor, 1980 to 2000
1980
1990
2000
% 20 year growth
Minooka 1,427
2,561
3,971
178
Morris 8,833
10,270
11,928
35
Oswego N/A
N/A
N/A
N/A
Plano 4,875
5,104
5,633
16
Sugar Grove
1,490
2,005
5,104
243
Yorkville 3,400
3,925
6,189
82
Total 20,025
32,825
64
The percentage growth rates for these communities are high, and the PES-A emphasizes the high
percentages throughout its analysis of socioeconomic characteristics. But minimizing the actual
population figures themselves -- and focusing on the rate of population growth -- does a
disservice to the discussion of the need for the highway. Very small towns need only attract a
small number of new residents to have massive growth rates. Established population centers
may attract far more residents but see only marginal increases in growth rates because the
population base was so large to begin with. To have a better perspective on the effect of
numerical increases versus percentage increases, the table below displays growth during the
comparable time period for communities in the Fox River Corridor.
Table 4
Population by Municipality, Fox River Corridor, 1980 to 2000
1980
1990
2000 % 20 year growth
Aurora 81,293
99,581
142,990
76
Batavia 12,574
17,076
23,866
90
Elgin 63,798
77,010
94,487
48
Geneva 9,881
12,617
19,515
98
Joliet 77,956
76,836
106,221
36
Naperville 42,312
85,351
128,358
203
Plainfield 3,959
4,557
13,038
229
St Charles
17,492
22,620
27,896
59
TOTAL 309,265
556,371
80
The Prairie Parkway will require the investment of millions of dollars in an area that has seen its
municipalities grow by 13,000 residents over a 20-year period (figures do not include Oswego,
but the increase there will not substantially change the point). This comes at the expense of Fox
River corridor residents, who are accommodating a quarter million more residents than in 1980.
12
Illinois Department of Commerce and Economic Opportunity website:
http://www.illinoisbiz.biz/com/community_profiles/s.html
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Although the PES-A makes reference to congestion in the heavily populated eastern section of
the study area, the solution proposed is for the sparsely populated western portion.
In summary, the PES-A demographic analysis appears to:
Inflate the importance of the growth rate in western Kane and Kendall counties.
Ignore the very small change in actual numbers that the growth rate represents (somewhat
more than 13,000 residents, or just over 650 per year)
Overlook the most populous communities, the communities generally most in need of
relief from congestion, at the far eastern portion of the study area.
Drive development toward the agricultural land in western Kane and Kendall Counties.
The eastern sector is the most desirable place to encourage growth, since infrastructure
already exists to support an increased population and there will be less destruction of
agricultural and natural areas.
The PES-A does not assess the potential effect of the Prairie Parkway proposal itself on the
growth projections for the study area, i.e., it does not forecast what growth will be like with and
without the highway. It appears to assume that past and future growth occur in a vacuum,
unrelated to major public investments.
The PES-A proceeds to paint an inaccurate picture of households, employment, income and land
use based on the inflated population figures.
Households
The study presumes an increase of 89% in the number of households in the study area between
2000 and 2030. There is no discussion of the household types anticipated. Will the study area
be an island of young families in a metropolitan region that has become generally older as the
baby-boom population has aged? Or will it have a proportional share of older households that
may not be comfortable with or able to drive for all trips? Would a larger proportion of retired
residents have less need for the commute trips on which so much of the travel analysis is based?
Employment
The study documents the unfavorable jobs-household ratio and the worsening of that ratio as the
number of households has rapidly grown. Without an integrated land use and transportation
approach, the PES-A anticipates that heavy residential development (which will inevitably
follow construction of a highway) will generate large amounts of commuter traffic to jobs
outside the area. There is no discussion of current and future agricultural employment.
Significant employers reported in the "Land Use" section are clustered in the Fox River Corridor
and the city of DeKalb.
Income
The PES-A reports that average household income of the study area will increase by 72% over
thirty years, while average household income in the Chicago CMSA will grow by just 47%.
There are no calculations of the ways in which travel choice, or lack of choice, will impact
household income. Nor is there any discussion of the number of current and future households at
the poverty level or without a vehicle.
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Land Use
The land use section of the PES-A is a compendium of arguments against the Prairie Parkway.
Most of the land is reported to be agricultural or protected open space. "Kane County policy is
to keep suburban development east of IL47, after an earlier boundary attempt at Randall Road
was not maintained" (PES-A, p. 3-17). City of DeKalb leaders came to a consensus at a "growth
summit" that they hoped to grow by 2% (over period of time unspecified in the PES) (PES-A, p.
3-18).
As this section of the PES-A identifies specific commercial and industrial land uses, it becomes
apparent that other than the urbanized corridor in the eastern edge of the study area and the city
of DeKalb, there are only a handful of businesses scattered within the study area that have 300 to
500 employees. The discussion of land use strays outside the study area boundaries to DuPage
County and the cities of Ottawa and Joliet (PES-A, pp. 3-17 to 3-19) in order to include larger
employers. Employment projections for 2030 indicate that 25-year job growth in the majority of
mile-square segments of the study area will be less than 25 jobs, or less than one per year -- and
this may be an optimistic scenario (Figure 3-4).
Comment
The analysis of numerical data is an area in which reasonable people can disagree. The failure of
the analysts in this study to calculate the needs of specific populations like people with
disabilities, youth/elder or low-income populations is unreasonable, however. The PES-A has no
assessment of the current or future portion of the population that does not or cannot drive for
reasons of age, ability or income. It fails to report the current and future proportion of the
population that is minority and whether or how minority group travel patterns and needs differ in
any way from the mainstream. Without redirection, these kinds of omissions will become
institutionalized. For instance, focus groups conducted during the production of the PES-A
failed to include non-drivers and minorities, even though minorities comprise 20% of the study
area population.
B. Traffic Characteristics/Transportation System Performance
Measures
Although the PES-A's Executive Summary would lead the reader to believe that this is a
transportation study and therefore potentially a multi-modal exploration of alternatives, the
introduction to the chapter on Traffic Characteristics is explicit about this being exclusively a
highway study. Within the two chapters assessed here, a one-half page section (PES-A, p. 5-29)
on "Transit Thresholds" was the only exploration of future transit opportunities. (An earlier
chapter, Study Area Transportation System, inventories existing transit routes and proposed
transit expansions, but that information does not appear to be factored into the analysis of future
performance.)
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. What's
worse, in several cases the data suggests 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
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"greatest in the central and eastern study area and become less pronounced to the western
portions" (PES-A, p. 4-18).
The PES-A analysts factored a minimum of transit improvements into the travel forecasts for
2030, but only those listed as "committed transportation improvements" in the 2030 Regional
Transportation Plan were included (PES-A, p. 4-7). This means that only major capital projects
were included and that potential options like increased service frequency or new bus routes were
excluded. Therefore the PES-A travel forecasts only assume the impact of Metra extensions to
Elburn and potentially to Oswego, neither of which address the need for north-south travel
options. Alternatives evaluations need to be run during Part B of the PES, transparently
calculating the impact of several north-south transit options in or near the Fox River corridor,
where the actual congestion -- present and projected -- exists. This alternatives analysis should
include bus, express bus, bus rapid transit and light rail options. It should also calculate how the
population would disperse itself differently with strong transit options and a no-build scenario
for the Prairie Parkway.
The analysis of truck traffic suffers from many of the same flaws. Highways are publicly funded
but rail infrastructure must be built by private companies; therefore freight is often transported
by truck where rail is insufficient or non-existent. There is no analysis of opportunities to shift
truck traffic from roads to existing or new rail lines.
In a fashion similar to the socioeconomic analyses, relatively low traffic counts are the
foundation for enormous percentage increases and for dire predictions of future gridlock.
"Average Daily Travel" is expressed exclusively throughout Chapter 4 as a percentage so that it
is impossible for the reader to assess whether 100% growth is from two vehicles per day to four,
or from 2000 to 4000. The maps that should visually clarify the data only make it appear more
complicated and alarming. Figure 4-6, Change in Travel Density 2000 to 2030, appears to signal
massive congestion, until one realizes that the highest increases (10,000 vehicles or more per
day) are on existing interstates and in the eastern areas that are dense enough to support transit
(and where transit is reportedly desired by the populace). Travel density on arterials in western
Kendall and Kane Counties needs to be compared to other arterials in the region to give some
context. According to figures harvested from the IDOT "Average Daily Travel" (ADT) web
site
13
segments near the proposed corridor (west of IL 47) have the following ADT:
Table 5
Sample Average Daily Travel Near Prairie Parkway Corridor
Segment with low ADT
Segment with high ADT
US30 6,100 12,000
US34 12,200 13,700
IL71 7,000 10,000
IL47 6,300 16,100
13
http://www.dot.state.il.us/siteindex.html
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In contrast, some of the roads in the eastern part of the study area carry twice as many vehicles
and arterials in other parts of the region are up to four and five times the highest ADT
experienced in western Kendall and Kane Counties.
Table 6
Sample Average Daily Travel -- Other Areas
Segment with low ADT
Segment with high ADT
Fox River Corridor
IL25 8,300 21,800
IL31 14,800
25,500
Outside Study Area
Il59 (Naperville)
42,600
51,100
IL56 (Warrenville)
17,800
18,800
IL19 (Elgin to Chicago)
13,600
48,400
The volume of traffic on interstates shows commensurate reductions when comparing western
Kendall and Kane Counties to other parts of the region.
Table 7
Average Daily Travel on Interstate Segments
Segment with low ADT
Segment with high ADT
I-55
44,500 (Channahon)
156,800 (Stickney)
I-80
21,8000 (Sugar Grove)
167,300 (Lisle)
I-80
34,100 (Minooka)
135,300 (Thornton)
Expansion of existing north-south routes has been the most frequently mentioned
recommendation of the residents of the study area who responded to opportunities to comment
on the Prairie Parkway in 2001 and 2002.
14
The PES-A does not address that recommendation,
but future reports will have to respond by transparently evaluating those alternatives. Future
analyses will also have to improve the evaluation of non-motorized modes, especially for the
80% of trips that are not commute trips. Although eight percent of DeKalb County residents
walk or bicycle to work presently (PES-A, p. 2-1), walking and bicycling are dismissed as
options ("non-motorized transportation presently is not an important mode of transportation for
work trips" [PES-A, p. 2-34]). Walking and bicycling are not analyzed in terms of their potential
contribution to future congestion relief.
The area in which the Characteristics and Measures analyses fail most completely is in the
evaluation of safety and crash data. Future analyses need to distinguish between crashes with
fatalities or injuries, and those involving simple property damage. The brief section on safety
14
Analysis of Public Comment on a Prairie Parkway Alignment
,
Center for Neighborhood Technology, 2004,
http://www.cnt.org/tsp/trans/ctaqc/prairie-parkway
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resorts to speculation in the absence of data, as in "the occurrence of left turn type accidents . . .
may be attributable to (drivers) that become inpatient (sic)" (PES-A, p. 5-34). The only data
offered is a table showing the current and projected "vehicle miles traveled" and crash frequency
(no indication of severity). Based on this sketchy data, unclear but ominous outcomes are
predicted, with references to an "increase (in the) number of crashes," and crashes that are
"expected to increase significantly."
The map found in Figure 5-17, High Accident Locations, 1999 to 2001, shows that most of the
crashes occur in the populated eastern part of the study area. If population is the primary
determinant of crashes, then the logic of building a road that will draw population further west is
questionable. Why rearrange the population that will bear the risk instead of investigating less
destructive -- and less lethal -- modal choices? Part B will need to present an ironclad case that
fatalities and serious-injury crashes will not increase as a result of massive investment in an
additional high-speed highway.
Issues that need to be addressed in future official studies, in addition to type of crash, include:
relationship of speed to fatal and serious-injury crashes; number of fatal and serious-injury
crashes in congested conditions; number of fatal and serious-injury incidents per transit mile (for
comparison).
C. Public Involvement
Public involvement assessments conducted by engineering professionals often fall victim to
predictable problems. The PES-A can be faulted for several of these problems, although the
public involvement is slightly broader than some previous efforts. Public involvement activities
reported on in the PES-A include stakeholder interviews and focus groups.
The stakeholder interviews included a broader than usual cast of actors; the consultant is to be
commended for including a reasonable array of county farm bureaus and civic/environmental
groups along with the customary municipal and business interests. Stakeholder interviews were
"conducted to inform the stakeholders of the Preliminary Engineering Study and to describe the
process . . ." according to the PES-A. Given that the PES-A does not look at alternatives to the
Prairie Parkway, the stakeholders were likely constrained to respond to the project itself rather
than the full range of alternative solutions to congestion. Feedback from the stakeholder
interviews is reported as a list of comments with no indication of high and low priority. This
information would be more useful if the reader could ascertain the relative frequency with which
comments were made.
15
The PES-A also includes results from focus group sessions conducted in 2003 by Public
Communications, Inc (PCI, Inc.) on a contract administered by IDOT. Forty-one participants
represented four categories: business owners/managers, property owners/farmers, drivers and
general interest. The five topics that were under consideration included:
·
Current transportation and travel patterns
15
The Center for Neighborhood Technology's assessment of comments from an IDOT public comment period on
tabulated the responses. The results are available in the
Analysis of Public Comment on a Prairie Parkway Alignment
,
cited above
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·
Attitudes toward highway travel
·
Public transportation
·
Development
·
Future travel needs.
Participant profiles (age, gender, occupation, place of residence) are explicit in the focus group
report
16
but not reported in the PES-A. The parameters for inclusion leave much to be desired.
For instance, only one participant was older than 63. There were two-and-a-half times as many
Kendall County residents as Kane County residents (Kane County is eight times larger than
Kendall County, but not all of Kane County is in the study area). Of the twelve participants in
the Property Owners/Farmers group, only two were farmers. While "Drivers" were a group
specifically solicited, non-drivers appear to have been omitted from the groups. Race/ethnicity is
not reported, leading to the supposition that the group was homogeneous. Twenty percent of the
study area population is African American or Hispanic; this raises a serious question about
whether environmental justice has been overlooked as public involvement is conducted.
These demographic omissions are significant in determining the substantive outcomes. The
town of residence (rather than just the county) is listed for 22 of the participants in the PCI focus
group report, but extracted from the PES-A. Of those 22, fewer than half had convenient access
to transit, and service was surely infrequent for all but the two who lived in Aurora. It is not
surprising that few reported using transit in the last month and most said they do not use public
transportation at all. Deletion of the demographic information from the text reproduced in the
PES-A gives a very incomplete picture of public perception, especially given the other
exclusions: non-drivers, older populations and minorities, for instance.
D. Environmental/Historic Constraints
The PES-A does not inventory environmental and historic assets that would be impacted or
destroyed by a proposed Prairie Parkway. Those assets will have to be thoroughly examined in
future studies. A number of interstate projects in northeastern Illinois have been stalled, and
some eventually abandoned, after years of expensive studies with weak or incomplete
environmental analyses. Federal laws governing environmental impacts include the fairly well
known Clean Air Act (CAA) and National Environmental Policy Act (NEPA). Regulations put
forth by the US Department of Transportation and the Council on Environmental Quality spell
out additional environmental requirements. For instance, when an Environmental Impact
Statement is written it must rigorously and objectively evaluate a "no-build" alternative. And
executive orders, such as the order on Wetlands and Floodplains or the Environmental Justice
Order, provide additional requirements for project planning and construction.
Future studies will need to assess the air quality implications of additional highway infrastructure
and calculate the air quality implications of a transit-intensive alternative. The northeastern
Illinois region (including portions of Kendall County) is designated as a "severe non-attainment"
area. This designation constrains the region's ability to add to its severe air quality burden. An
16
Prairie Parkway Qualitative Research: Focus Groups, Public Communications, Inc., November 2003.
18
The Prairie Parklands: An Inventory of the Region's Resources, Illinois Department of Natural Resources, 2001,
http://dnr.state.il.us/orep/c2000/assessments/pparkweb/pagei.htm
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early review of environmental and air quality impacts of the Prairie Parkway would be fiscally
prudent. If the project will exceed federally mandated air quality thresholds or run afoul of water
and endangered species regulations, then enhanced demographic and traffic analyses are an
expensive but futile exercise.
The protected right-of-way for this highway slices through some of the most environmentally
sensitive natural features in northeast Illinois, including two of the highest quality creeks in the
state -- Aux Sable and Big Rock -- and the Fox River. The impact on endangered species
known to inhabit these three waterways, the potential damage to Silver Springs State Park and
the effect of contaminated runoff on groundwater aquifers are all serious threats deserving
thorough and transparent investigation. The impact of a highway on the Prairie Parklands, which
partially overlap the study area, should also be thoroughly investigated, given the rarity of
natural assets there.
The authors of this report are not in a position to fund the extensive environmental assessments
required and have no desire to duplicate studies that should be part of the official analysis. We
include here a partial list of precious assets that may be threatened by this proposed project, with
the expectation that successor reports to the PES-A will provide comprehensive, high-quality
analysis of the costs and benefits of encroaching on these assets.
Water resources
·
Class A Creeks such as the Aux Sable and Big Rock Creeks
·
Existing or projected water shortages in Kane and Kendall
·
Groundwater aquifers ranging from shallow ones tapped by homeowners to the
Cambrian-Ordovician deep sandstone aquifers supplying groundwater to the Joliet,
Morris and Marseilles areas
18
·
Sixty-seven percent of the river and stream miles in the Prairie Parklands are biologically
significant and/or support state threatened or endangered species
19
Environmentally sensitive areas, especially existing prairie fragments
·
The Prairie Parklands are the largest tract of native tallgrass prairie in Illinois (Goose
Lake Prairie Nature Preserve)
20
·
The Prairie Parklands has the largest concentration of dolomite prairie in Illinois
21
·
The Prairie Parklands has four-firth of the state's wet-mesic upland forest
22
Threatened and endangered species
·
Twenty-four threatened or endangered prairie plants are found in the Prairie Parklands
23
·
Thirty-three of the 34 state listed bird species breed in the Prairie Parklands
24
19
Ibid
20
Ibid
21
Ibid
22
Ibid
23
Ibid
24
Ibid
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·
Threatened and endangered species of fish are found in Aux Sable Creek, Big Rock
Creek and portions of the lower Fox River.
Archaeological assets
·
The Prairie Parklands hold world famous fossils of prehistoric flora and fauna
25
·
1,386 archaeological sites have been located in the 6% of the Prairie Parklands that has
been surveyed thus far
26
Protected public lands
·
Goose Lake Prairie Nature Preserve
·
Silver Springs State Park
·
Midewin National Tallgrass Prairie
Historic and architectural assets
·
Big Rock Township Farms (Mount Green, Merritt Davis, William Davis), Kane County
27
·
Farnsworth House
28
25
Ibid
26
Ibid
27
Landmarks Preservation Council of Illinois
28
Ibid
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IV. Conclusion and Recommendations
The challenge of addressing access and mobility needs in the far west sector of northeastern
Illinois does not need to be difficult and divisive. The Federal Highway Administration
(FHWA) and the state of Illinois have Context Sensitive Design policies that provide guidance
for an improved study protocol. According to the FHWA, "Context sensitive design (CSD) is a
collaborative, interdisciplinary approach that involves all stakeholders to develop a
transportation facility that fits its physical setting and preserves scenic, aesthetic, historic, and
environmental resources, while maintaining safety and mobility. CSD is an approach that
considers the total context within which a transportation improvement project will exist."
The following recommendations are offered to bring the
planning process into conformance with
federal and state CSD policies, and more importantly, to ensure that the any
project built in the
future will address the needs of current and future residents in the most comprehensive way
possible:
1.
Conduct public involvement workshops, focus groups and surveys that proportionally
reflect the views of the population 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.