Colorado State Highway 82
East of Basalt to Aspen EIS
A Case Study
Revised and Updated August, 2009
Note: Efforts to restore oversight by the federal government have reached the Council of the Inspectors General on Integrity & Efficiency. A complaint to this agency was filed in June, 2010.
Appendix Exercises 1-3
Can shortfalls in projected vehicle trips be accounted
for by a shift to mass transit person trips at the Entrance
to Aspen, 1987 – 2005?
Has RFTA ridership ever accounted for 37% of the
person trips at the Entrance to Aspen, even if only
for a peak hour?
How much effect did the 1995 paid parking program
have on 1993 peak hour traffic at the Entrance to Aspen?
West Glenwood Springs to Aspen
Corridor Investment Study (May 2003)
Roaring Fork Valley Bus Rapid Transit Project
Citizen Comment to the Federal Transit Administration
Added - October 14, 2010:
Roaring Fork Valley BRT Environmental Assessment
The National Environmental Policy Act (NEPA) Environmental Impact Statement (EIS) named in the title of this report was, for this particular transportation project, the initial procedural tear in the fabric of the federal oversight process established to protect the taxpayer from waste, abuse, and fraud in the application of public funding. The manipulation of this document led to the corruption of the integrity of subsequent and related processes which were falsified and compromised in order to support, or avoid contradicting, the original flawed product.
This Case Study addresses the following list of interdependent and mutually impaired documents:
Colorado State Highway 82 East of Basalt to Aspen EIS - (Not completed)
Colorado State Highway 82 East of Basalt to Buttermilk Ski Area EIS - (1993)
Colorado State Highway 82 Entrance to Aspen EIS - (1997)
West Glenwood Springs to Aspen Corridor Investment Study (CIS) - (2003)
Reevaluation of the Colorado State Highway 82 Final EIS (FEIS) - (2007)
Federal Transit Administration (FTA) Section 5309 Very Small Starts (VSS) grant application for the Roaring Fork Transportation Authority (RFTA) Bus Rapid Transit (BRT) Project - (In process)
This report contains an Appendix comprised of three “exercises” which are essentially work sheet demonstrations of methods used to evaluate some portions of the above referenced transportation studies. The exercises are not essential to understanding the report, but one purpose in taking the unusual step of including these work sheets is to demystify the transportation planning process. It may require trained staff and consultants armed with arcane protocols and black box computer programs to baffle elected officials and the public, but it requires no more than tenth grade reading and math skills to reveal the extent of the problems with their conclusions.
The exercises in the Appendix can also be used to demonstrate that the aforementioned staff and consultants cannot respond in kind to the information presented here. This exposition is intended to be a guide to those entrusted with protecting the public interest, who will find, if they choose to pursue these matters, that transportation experts cannot produce any factual basis to refute the charge that transportation data and forecasts for the study area have been concocted for political purposes.
Statistical analyses were completed in 2007, and accessed data sets for traffic counts and mass transit ridership covering the period from 1987 to 2006. It is therefore important to note that problems discussed in this critique are not relative to short term anomalies such as the recent spike in gasoline prices or subsequent national recession.
Addendum A and Addendum B to this report were both originally submitted as public comment into the CIS and VSS transportation planning processes. The extent to which factual information is incapable of affecting the predetermined expansion of mass transit expenditures in the Roaring Fork Valley, and the futility of attempts to participate in those processes, is amply demonstrated by the absence of any substantive official reaction or response to the empirical evidence presented in the addenda.
In August of 1989, the Colorado Department of Highways issued the State Highway 82 East of Basalt to Aspen Draft Environmental Impact Statement/4(f) Evaluation – Project FC 082-1(14), a study which found that highway capacity increases would be necessary to resolve existing and future congestion along the 18 mile project corridor between the two towns. Complications were encountered after that date due to City of Aspen non-compliance with Clean Air Act requirements for PM10 particulate levels, but mitigation measures were developed and all other aspects of the process, including voter approval of the transfer of city owned 4(f) open space property to the state, were proceeding to a timely conclusion.
State funding was in place for construction of the most critically congested portion of the highway at the Entrance to Aspen.
majority of the
A meeting between Aspen officials and then CDOT Director Dr. Ray Chamberlain on March 20, 1992, led to the setting aside of the Entrance to Aspen segment of the highway for additional study. This action resulted in the release of the East of Basalt to Buttermilk Ski Area Final EIS (FEIS) in October of 1993, and the start of the Entrance to Aspen EIS the following year. There was no statutory or regulatory requirement or procedural antecedent for the splitting of the process to create the appearance of two separate studies; it was simply done by executive fiat in response to a request from a political body.
practical terms, it is useful to view the East of Basalt to Buttermilk Ski Area
(Basalt to Buttermilk) FEIS and Record of Decision (ROD) as the final embodiment
of the “original” (Basalt to
“A four-lane highway is the only option which will provide an acceptable capacity and level of service, and satisfy safety concerns for existing and forecasted traffic on State Highway 82.” - Basalt to Aspen Draft EIS, (DEIS) 1989
“Travel demand studies prepared for the FEIS showed
that an improved
city council majority which negotiated a separate EIS for the Entrance to
From its inception, the Entrance to Aspen EIS process was designed to fit data and assumptions to a predetermined outcome, in direct contravention of the Council on Environmental Quality’s NEPA Implementation Procedures:
Sec. 1502.2 Implementation.
(f) Agencies shall not commit resources prejudicing selection of alternatives before making a final decision (Sec. 1506.1).
(g) Environmental impact statements shall serve as the means of assessing the environmental impact of proposed agency actions, rather than justifying decisions already made.
The practical impact of this failure of process have been enormous. Construction costs for the project itself have more than doubled, so far, since 1993. Millions of vehicle trips have been subject to long delays - with the accompanying loss of time to highway users, degradation of air quality, wasted fuel, and the visual blight of a very urban phenomenon in an otherwise rural setting.
By tailoring an EIS outcome for the benefit of municipal policy makers, state and federal staff and consultants failed the general public, and the absense of effective oversight to prevent this failure must be addressed. Efforts to secure remediation of this problem at the federal level will continue, but the Entrance to Aspen experience should inform the State of Colorado that federal agency oversight is not a sufficient protection of state interests in either this or the general case.
In a 1996 election, Aspen residents endorsed a conceptual version of the “two lane parkway with light rail” proposal which is described as the preferred alternative in the Entrance to Aspen FEIS and ROD. Stipulations in the ballot language provide that, “the light rail transit system shall be built only after adequate financing mechanisms and final design details are identified and approved by a public vote”.
This conditional new authorization for the use of 4(f) open space land was later augmented by a provision in the ROD calling for exclusive bus lanes to be built as a first phase, despite the fact that no voter authorization was obtained for that use. Thus a Record of Decision was issued for a project on which no final decision had been reached on either of two primary design components. Provided with greater detail regarding costs, performance, and physical impacts, voters later turned down a financing proposal for the light rail alternative, and the exclusive bus lane concept was similarly rejected  .
In reaction to the apparent impasse, this author contacted the Colorado Division of the Federal Highway Administration (FHWA) in 2001, to enquire about methods or procedures under the NEPA process which could be used to proceed with an alternative other than the inaptly named “Preferred Alternative”.
Early in the discussion with the FHWA, it became apparent that much of the information on which they and the public relied during the comparative evaluation of the preferred alternative was comprised of false assumptions and false data. In particular, the error in their finding that alternatives other than the preferred alternative would be unable to meet air quality conformity standards was brought to the attention of the Colorado Department of Transportation (CDOT) and the FHWA in a conference call held on November 14, 2002. The FHWA later responded to this new information by deciding that no review would be undertaken – because CDOT had advised them that funding for the Entrance to Aspen might not become available for another ten years.
Thus, a project which had been removed from state funding priority due to a lack of public support was barred from being revised to a publicly acceptable alternative until such time as funding was restored to the rejected alternative.
In response to the paradox created by the Colorado Division of the FHWA, the request for federal intervention was moved to Washington DC. This appeal was based on the following problems in the FEIS and ROD for the Entrance to Aspen:
(1) Mathematical Error
The study area of the FEIS
is reported as 4.3 miles, and the alternative of “
(2) Modeling Error
The VMT estimate (166,300) for the alternative of “2 General Highway Lanes – LRT/Transit Lanes” (LRT = Light Rail Transit) either doesn’t suffer from the same gross error described above (creating a false comparison), or the vastly lower VMT credited to the Light Rail option is evidence of a significant modeling error. If the VMT totals were calculated in the same manner for both alternatives, transportation planners produced an estimate which could only be fulfilled if one out of every three vehicles on the highway was diverted to the light rail system – a proportion representing 100% of the projected 50% traffic increase. This magnitude of effectiveness is clearly not a feasible outcome.
(3) Comparative Error
The lower VMT estimate for light rail is also afforded to the exclusive bus lane option, but not the HOV option, despite there being no practical difference. The passenger requirement for access to an HOV lane can be adjusted upward to reduce vehicle counts in that lane, thereby achieving the same performance as exclusive bus lanes in regard to maintaining bus system schedules. Transportation Management (TM) measures (i.e. paid parking) intended to limit growth in vehicle traffic, and increase mass transit ridership, operate independently of highway design.
(4) Regulatory Error
The artificially lower VMT, and presumed PM10 production, for light rail and exclusive bus lane options is described as, “equivalent to a new emissions budget for the Aspen PM10 nonattainment area;” by default making these the only alternatives which could satisfy this hypothetical emissions budget. The real emissions budget is based on levels necessary to maintain human health, not a mathematical abstraction, and the HOV alternative would remain within those limits, even at the artificially inflated traffic levels described in (1).
The totally unfounded emissions budget assumption described in item (4) above may now be moot as a result of the delisting of Aspen as an air quality nonattainment area, but during the conduct of the EIS it improperly limited the choice of reasonable alternatives.
It is worth noting that nothing in the observations described above requires anyone knowledgeable in the art of highway or transportation planning to discover or understand. There are no tools beyond common sense and basic math and reading skills necessary to confirm these observations. This point is significant to the eventual official response to the information.
It is also worth noting that the same federal law (42 U.S.C. 4332) which requires that a report be prepared on the environmental impact of a proposed action also requires that report to include alternatives to the proposed action, and stipulates that even in the event the report is prepared by a state agency, “the procedures in this subparagraph shall not relieve the Federal official of his responsibilities for the scope, objectivity, and content of the entire statement”.
At no time during a nearly five year exchange of correspondence with the FHWA, at either the Colorado or national level, did any official express any concern over the failure of the process to provide the public and decision makers with objective and accurate information for use in the comparative analysis of the various alternatives. Washington DC FHWA officials simply conferred with their own Colorado Division and repeated the local determination that no review would occur prior to project funding. 
The one Washington concession towards a possible resolution again came in the form of an assurance that whenever the project was restarted, a written reevaluation would be conducted, and at that time “concerns about the ROD could be taken into account formally”. However, with the funding paradox still intact, there was no apparent occasion when such a reevaluation would occur.
The Entrance to Aspen segment of Highway 82 contained
a bridge which, at the time of its replacement in 2007, was approximately 120
years old. Deteriorating structural
integrity led to the funding of a replacement, and the
The announcement of a written reevaluation process was soon followed by a statement from the state Program Engineer that the “purpose and scope of the reevaluation is technical in nature, and not geared toward expansive public input or analysis of screened alternatives,” and added with underlined emphasis that, “only the preferred alternative is being reevaluated.” This determination violated the specific requirements of the reevaluation process (see Procedure - Link 1), and reversed FHWA assurances regarding the appropriate remedy for prior comparative errors.
Upon confirmation that “concerns about the ROD” would not be addressed, the Colorado Division FHWA was again contacted, and presented with an expanded set of such concerns. No reply, nor even an acknowledgement of receipt, was ever provided, and the FHWA Division Administrator signed off on the completed reevaluation on July 13, 2007. Construction of the exclusive bus lanes was completed in the fall of 2008.
From the earliest organizational meetings in 1987 to the release of the Reevaluation in the summer of 2007, the EIS documentation for the 18 mile highway segment between Basalt and Aspen may have set a record for new title pages. The production of Draft, Draft, Final, Draft, Draft Supplemental, etc., with various place names attached, obscures the essential fact that this has been one project and one process throughout.
“The purpose of the action under study is to improve the safety and capacity of State Highway 82 in a manner that is affordable, that recognizes public concerns and that complies with all applicable regulations. The need for the action under study is evidenced by existing traffic congestion and by safety statistics.”
Although the Basalt to Aspen DEIS further elaborated on its description of project purpose and need for about two-thirds of a page, the selected portion quoted above accurately represents the sense of the document. No similar excerpt from the Entrance to Aspen DEIS can adequately summarize the various versions and several pages of material that the later study devoted to the same task.
An early starting point is relatively uncontroversial:
purpose of the Entrance to Aspen Environmental Impact Statement (EIS) process
is to develop a transportation solution that addresses the transportation
capacity inadequacies and safety problems of the study corridor while avoiding
or minimizing adverse environmental impacts.”
- Entrance to
However, a later section independently developed by the Aspen city council, titled “Entrance to Aspen Resolutions”, contains their statement of “Project Need” and “Project Intent” along with a set of guiding principles, ten “Project Objectives”, which must be addressed:
primary purpose of this project (the Entrance to Aspen EIS) is to develop and
evaluate potential solutions which will improve transportation and safety along
the State Highway 82 project corridor for those who travel it. In addition to this general goal, each of the
potential alternatives studied in this document must address the ten project objectives
developed as part of the scoping process.”
- Entrance to
Later in the Entrance DEIS, the significance of the project objectives is elevated further, when we learn that to simply “address” them will not be sufficient:
“The project objectives are the foundation of the EIS process and must be met by the proposed transportation improvements.”
The project objectives are presented in a four page table in the “Purpose and Need and Project Objectives” Technical Reports Volume of the 2007 Reevaluation, along with narrative on how the preferred alternative satisfies the objectives. Objective No. 2, Transportation Capacity, restates a goal from the city council’s 1995 Project Intent that, “this project will…seek to achieve the stated community goal of limiting the number of vehicles in the year 2015 to levels at or below those in 1993/1994.” Objectives No. 1 and 9 also tie the preferred alternative to this vehicular limitation goal, which is a pure municipal policy statement, not a NEPA requirement that “must be met”.
of limiting traffic is intended to be achieved with a series of Transportation
Management (TM) techniques which are, with the possible exception of congestion
pricing, entirely under the control of the Aspen city government and/or area
transit authorities, completely independent from CDOT or any highway
alternative built under the FEIS and ROD for the Entrance to
The one relevant physical attribute of the highway design (limiting capacity to two lanes for general traffic) which is believed to contribute to the goal of reducing traffic volume is not listed among the TM measures because limiting capacity is not a federally recognized policy. In the discussion of Objective No. 2 it is noted that, “Though the highway system will operate under congestion, this congestion is considered part of the disincentive for single occupancy vehicle (SOV) travel and will increase transit usage.”
The extent of the expected level of future congestion can be inferred from Table 2-1 in the Traffic Characteristics and Safety Technical Report, but is never directly acknowledged. Very little change in traffic volume or Level of Service (LOS) is noted between 1993 and 2005, with one short highway segment deteriorating from a Level E to Level F – worst conditions. The “stated” community goal is to maintain traffic at 1993-2005 levels, and the preferred alternative provides no additional lane capacity for general traffic. Consequently, there will be no improvement in traffic congestion, by design.
The latest iteration of the standards applicable to projects to qualify them for federal-aid highway funds is contained in the federal SAFETEA-LU legislation, which the Reevaluation describes as addressing the challenges of “improving safety, reducing traffic congestion, improving efficiency in freight movement, increasing intermodal connectivity, and protecting the environment.” Emphasis added.
The federal standards are not incompatible with provisions for the use of highway funds defined by the Colorado state constitution and Highway Users Tax Fund, as exemplified by the directive that “such revenue [gasoline excise tax above the first seven cents per gallon] shall be expended only for improvements to highways within the state, including new construction, safety improvements, maintenance, and capacity improvements” C.R.S. 43-4-205 (6) (b). Emphasis added.
Federal and state law recognizes the need to coordinate planning between highway and other transit modes, and allows the use of some highway funds for that purpose. However, expenditures to implement mass transit plans are explicitly derived from designated transit funds, leaving no question that the primary and overriding purpose of any highway project is to improve highway function.
Care was taken to apply funds from transit specific tax sources to construct the short section of exclusive bus lanes completed under the Reevaluation, a technical accommodation which obscures the larger context. The value of expenditures made to improve highway function on the first sixteen mile section of the project - paid for solely by highway funds - will never be fully realized until the congested bottleneck is eliminated along the final two miles of the complete project.
A municipal policy to preserve congestion, a decision
which could be changed by the current or any future city council, or by the
public through the initiative process, has been granted pre-eminence over state
authority and the project need which initiated the entire process. The abandonment of the lane capacity increase
necessary to satisfy the original project need is a retraction of the
protections and guarantees for the use of taxpayer funds secured by federal
code, and the
Any such renegotiation of core policy must be the province of the state legislature, not a municipal government, CDOT employee, or transportation consultant.
RE: Reevaluation of the
The Reevaluation Introduction reports that the process is being conducted under Code of Federal Regulations (CFR) standards, and provides a redacted quote from 23 CFR, Part 771.129, Re-evaluations. From this same source we learn that, “A written evaluation of the final EIS will be required before further approvals may be granted if major steps to advance the action…have not occurred within three years after the approval of the final EIS, final EIS supplement, or the last major Administration approval or grant.”
However, no similar reference is provided for the description of the “Study Process”, despite the availability of equally quotable federal guidelines. Instead, the Reevaluation defines its own procedures: “The reevaluation assessed whether any regulatory changes or changes in the project design concept or scope, affected environment, or environmental impacts have occurred since publication of the FEIS and ROD.” The Executive Summary section adds “proposed mitigation measures” to this list. Emphasis added.
The Executive Summary findings reflect an even narrower focus, stating that, “There have been no substantive changes to the Preferred Alternative…the existing environment or the impacts of project construction…nor have any additional types of impacts been identified that were not previously evaluated,” and neither have there been any, “changes in regulations or requirements”. Emphasis added.
The federal guidelines for the conduct of a reevaluation do not support the limitation of scope introduced into the Entrance Reevaluation by the underlined language above. First, the U.S. DOT Technical Advisory (T 6640.8A-XI) for reevaluations clearly states that, “The entire project should be revisited to assess any changes that have occurred and their effect on the adequacy of the final EIS.” In addition, “It should focus on the changes in the project, its surroundings and impacts, and any new issues identified since the final EIS was approved.” Emphasis added.
The broader intent of the federal guidelines for reevaluations is completely consistent with the overall responsibility “for the scope, objectivity, and content of the entire statement,” including “alternatives to the proposed action”. (42 U.S.C. 4332) (Return to Link 1)
As explained in the Overview section, CDOT and FHWA officials were fully informed of “new issues” concerning the objectivity of data and assumptions which prejudiced the selection of the preferred alternative. The necessity to examine these new issues was avoided by the self defined procedures of the reevaluation, a technique similar to the following example of selective interpretation used to bar public input.
The Code of Federal Regulations provides that, “Based on the reevaluation of project environmental documents required by §771.129, the FHWA and the State highway agency will determine whether changes in the project or new information warrant additional public involvement.” Emphasis added. The Program Engineer for the Reevaluation broadly construed this provision to mean that there could be no public input during the course of the process, effectively barring a primary source of “new information”. Although there are numerous requirements for public involvement at all levels of any NEPA process, the exclusion of the public was particularly unproductive in the context of an FEIS and ROD which had elevated Community Acceptability to the status of a Project Objective which “must be met”.
The updated Reevaluation table of the ten Project
Objectives notes in No. 5 “Community Acceptability” that, “the community
continues to express divided opinions on the solution to the State Highway 82
traffic problems. The City of
The Reevaluation uses 1994 as the starting year for the review of the Entrance to Aspen EIS, thereby excluding the larger context of the complete process. This effectively isolates the preferred alternative of the FEIS and ROD from any meaningful comparison with the original project purpose and need, or any reality checks between past traffic projections and current traffic volumes.
A tailored reevaluation process was outfitted with customized criteria which can be summarized as a “how to screen the data” checklist:
1. Constrain the time period from which base line information can be referenced for comparative purposes.
2. Interpret “entire project” to mean “preferred alternative”.
3. Reject data showing errors relevant to the selection of the preferred alternative over another alternative, citing interpretation of “entire project”.
4. Interpret “any changes” and “any new issues identified” as applicable to only a specific set of concerns: existing environment, impacts of project construction, changes in regulations.
5. Cite the ten Project Objectives as a basis for the choice of preferred alternative, but decline to respond to changes in the one objective (Community Acceptability) which could determine “whether the Preferred Alternative…can be implemented”.
However necessary it may be to determine that there have been no changes in regulations, etc. in the three or more years since the last major steps were taken to advance the project, it defies logic and principle to constrain a reevaluation so that it does not address the Community Acceptability problem which caused the three year delay – and ignores relevant factual comparative errors made known to project officials prior to the start of the process.
The Reevaluation notes that the easement through 4(f) land conveyed to CDOT allows for construction of a “two-lane parkway and a corridor for light rail,” and that, “Any other use of the ROW would need to be approved in a City of Aspen open space land use election.”
An election to approve a different use is working its way through the courts as the result of a citizen initiated ordinance – a petition process already completed. The only substantive difference between the initiated proposals and the current preferred alternative is that HOV lanes managed like those developed in the original EIS process – as built under the East of Basalt to Buttermilk ROD and in use today - will replace the exclusive bus lanes preferred by the Aspen city council.
Since capacity increases would be provided for all highway users, including general vehicular traffic, the voters of Aspen may approve an alternative which will better satisfy the original project purpose and need. In response to the potential vote, the CDOT Program Engineer was reported by the print media to estimate that, “a new supplemental environmental impact statement would need to be developed, which could take two years and cost $2 million.” When pressed for specifics on what aspects of the proposed alternative could require that level of review, a representative of the FHWA was reported to have said that, “even if the science portion of the review of the HOV alternative is fairly straightforward…a lengthy and complicated public involvement process would also be necessary.”
So, problems in Community Acceptability which could delay the project indefinitely did not warrant CDOT or FHWA consideration, but if the citizens of Aspen resolve the issue themselves, state and federal officials will move to delay the project for up to two years while they determine what the public wants.
(Return to Link 10)
(Return to Link 10)
The political decision to allow increased transportation capacity only with mass transit produced significant repercussions for the data and analysis found in two of the technical reports in the Reevaluation - System Management, and Traffic Characteristics and Safety. Planners were faced with the challenge of using projections of increased traffic as a rationale for continuing to limit highway capacity.
The Reevaluation did not acknowledge or repair the errors in comparative data contained in the Entrance to Aspen FEIS, even after those errors were brought directly to the attention of program officials. Aside from the false data, the potential for objective evaluation of alternatives in the FEIS was further damaged by excluded data.
As part of the comparative process followed in the Basalt to Aspen DEIS, 1989, tables were provided showing existing Level of Service (LOS) conditions, and expected conditions for the existing two lane highway based on year 2010 traffic projections. The study then provided a comparison of the LOS conditions in the year 2010 using the same projected traffic increases, but with two additional lanes in place to expand the highway capacity to four lanes.
That table (Table 11) has been reproduced as the
second graph which follows. Even assuming a 40%
peak hour traffic increase, without regard to transit services, the LOS for the
A new four lane Entrance to
The Entrance to Aspen FEIS and Reevaluation offer only one of the three tables - Existing Level of Service - provided by the original Basalt to Aspen DEIS process. The following graph provides the Reevaluation version of that table (Table 2-1).
Given the opportunity to compare a four lane alternative to current conditions, the following two tables make it clear that while existing peak traffic counts of up to 2400 vehicles per hour produces a LOS of E/F on a two lane road, a four lane highway, had it been built, would currently be operating at LOS B. This information is completely unknown to the general public, and probably most elected officials; apparently as intended. 
Table 2-1 from the 2007 Reevaluation showing existing conditions with the current two lane highway. No acknowledgment is made that this also indicates future conditions expected with the preferred alternative, which would continue to restrict general traffic to two highway lanes, and provides capacity improvements only for the mass transit system.
Table 11 from the East of Basalt to Aspen DEIS, 1989, showing improved Level of Service provided with two additional highway lanes. This information was withheld from the Entrance to Aspen EIS Process.
(Return to Link 9)
In addition to the missing data, the next most significant omission, specifically in regard to the Reevaluation, is the absence of any meaningful analysis of current traffic volume data and bus ridership information to evaluate the accuracy of past traffic projections made in the Entrance FEIS and ROD.
Vehicle counts have not increased between 1993 and 2005, and Reevaluation authors credit the Transportation Management (TM) measures designed to achieve that result. (Keeping in mind that traffic congestion is not a TM measure, there is still no clear explanation as to why there is any need to preserve that congestion in order to maintain the desired traffic volumes.)
The interaction between vehicle counts, transit ridership, and TM measures is absolutely central to every assumption relating to the choice of the preferred alternative, and especially the presumption that a “critical” need exists for “dedicated rights-of-way” which would exclude general traffic. An updated analysis to support the belief that TM measures are the reason for the unfulfilled traffic volume projections is not provided, perhaps because a shift to mass transit as a possible explanation is only partially supported by bus ridership numbers.
The Appendix contains the Exercise 1 worksheet (Link 2) in which it becomes apparent that there were at least 4935 missing daily vehicle trips in 2005 which cannot be accounted for by the assumption that TM measures have maintained traffic volumes by converting vehicle trips into transit riders.
After accounting for the impact of transit ridership, EIS traffic projections from 1987 were too high by about 300%, but that has not resulted in any reconsideration of more recent estimates.
Applying recent historical data and reasonable assumptions to develop a basic updated traffic projection, this case study finds a potential 5.7% Average Annual Daily Traffic (AADT) increase of 1370 vehicles per day by 2015, resulting in an adjusted figure of 25,270 AADT for that year, not the approximate 34,000 trips proposed by the 1997 FEIS. In the context of the virtual flat line performance of both vehicle counts and transit ridership numbers at the Entrance to Aspen during the decade from 1995 - 2005; this represents a true high growth scenario.
In contrast, after crediting transit ridership with 2405 “diverted vehicle trips” per day for 2005 AADT, and adding that number to the actual 2005 AADT vehicle count, the FEIS will require an additional 7,695 vehicles per day - or the person trip equivalent of 12,312 daily bus riders - to materialize from somewhere in order to satisfy the official projection for growth in transportation demand by the year 2015.
Even a projection of zero or declining growth in Castle Creek Bridge (CCB – the point of highest vehicle and transit ridership counts) crossings for 2015 would be far more plausible than the projections provided in 1997 by the FEIS and ROD. For example, adjusted by the listed modifiers, the CCB bus routes’ annual total riders dropped by 195,583 passengers between 1995 and 2005, and a much touted jump in ridership in 2006 only restored about two thirds of that decline.
A 5.7% increase in vehicular traffic would be barely noticeable if the highway were expanded to four lanes. If the community of Aspen wishes to continue to divert all entrance traffic growth to mass transit, it will need to accommodate an additional 2,192 daily riders, a 35% increase for the bus routes crossing the CCB.
Whatever was expected to transpire by 2015 to fulfill the 1997 projection for a 187% increase in bus ridership on CCB routes, or whatever the explanation as to why there was no sign of such an increase by 2007, it is of no concern to the Reevaluation, which simply notes that, “Traffic demand was prepared using CDOT growth factors that indirectly account for reduced traffic growth due to implementation of the TM program.” The Reevaluation adjusts the year 2015 traffic forecast from the 1997 FEIS upward by a modest 6.5% (from 42,000 to 44,800 vehicles per day), and then extends the planning horizon out to 2030 as the means to reach that projection.
The techniques used to insure that each step in the EIS process reaches and preserves its predetermined conclusion are not limited to missing data or traffic projection targets transported 15 years into the future. Uncritical use of impossible claims, and erroneous claims from presumptive supporting studies, are also employed.
The public has been told repeatedly that RFTA provides 37% of peak hour person trips at the Entrance to Aspen. This information turns up again in the Reevaluation, with the added qualifier that the claim may only be applicable to a specific winter morning peak hour in 1992, but still without the key information needed to provide the true context. Exercise 2 (Link 3) in the Appendix shows that this statistic, as it is generally applied, is a physically impossible feat even if the social conditions existed to provide the ridership. What might have been a minor detail from 1993 is significant in the context of consistently misused data, and especially because, for any professional familiar with mass transportation performance, the 37% figure should leap off the page as obviously impossible in all but the most limited circumstances.
Stepping back and using the broadest indicators available - total annual CCB bus ridership and total annual vehicle trips - RFTA accounted for 12% of the vehicle trips and 10% of the person trips at the CCB in 1992. Without the contribution from skier shuttles, the percentages drop to 9% of vehicles and 7% of person trips – somewhat beyond the high end of actual counts taken in the summer of 1992, and therefore a reasonably good fit for an annual average.
The 2005 numbers, subject to the same assumptions, show a RFTA share of 17% of vehicles and 14% of person trips at the CCB. Minus the skier shuttles, the numbers drop to 13% of vehicles and 11% of person trips.
Even a general claim of a 35-40% person trip share for any mass transit system is far beyond any acceptable range of error or embellishment, and the indifference on the part of public officials to correct this media myth strongly contributes to the appearance of willful deception.
Local residents have been left to believe a drastically inflated perception of the value and effectiveness of their current transit system, and its potential to impact traffic congestion problems.
The various Highway 82 FEISs, RODs, and the Entrance Reevaluation are closely related to the West Glenwood Springs to Aspen Corridor Investment Study (CIS). Cross quotes between the documents are a source of support for the conclusions reached, even though none may actually supply verifiable data as the original basis for those conclusions. Selective application of the data in each document seems determined to induce a massive expansion of an already enormous mass transit system as an end in itself.
The Reevaluation tells us: “Travel demand forecasts for both the CIS and the…Basalt to Buttermilk EIS concluded that, without an improved transit system, such as that included in the Preferred Alternative, the new four-lane highway will experience peak-hour congestion as early as the year 2009. Traffic analysis for the current reevaluation validates this conclusion.”
Contrary to the impression created in the Reevaluation quote above, the CIS predicted seriously congested conditions in the year 2009 for Highway 82 only at those locations which were already congested at the time the study was released in 2003. More significantly, the CIS predicted about the same level of decline in LOS conditions at various points along the corridor regardless of any improved transit system - in direct contradiction of the Reevaluation interpretation.
For its base case comparisons the CIS assumed the construction of the preferred alternative at the Entrance to Aspen and a new bridge in south Glenwood Springs as part of its “No-Action” alternative, and rated existing conditions with an LOS letter grade at 19 different highway locations along the corridor.
The “Build” alternatives ranged from Bus Rapid Transit (BRT) to Light Rail, with BRT costing the least at about $128 million in capital costs and $12 million annually in additional RFTA operating and maintenance costs. BRT was the recommended near term option despite the fact that the LOS conditions projected to exist in 2025 with BRT were better than the “No-Action” option at only one of the 19 graded locations.
A study driven by the stated concern to solve future traffic congestion, and which claimed huge transit ridership increases as a result of reduced travel time, did not consider whether both of those goals could be reached with highway improvements. The “Technology options” developed for the CIS managed to include “automobiles on new lanes” on the same list as “jet packs”, “dog sleds”, and “automobiles on flatbed trucks”. These options were then treated equally by dismissing them all with no further comment. The brainstorming list was unable to imagine anything beyond "passenger cars or trucks using Highway 82 in its present configuration," despite the potential for capacity increases at specific congestion points which would be effective even without additional lanes.
The CIS set out to show that, "The region's growing traffic congestion cannot be solved with just one mode of transportation or by highway expansions alone," but like the Entrance EIS, ended up confirming the exact opposite. The CIS reported no congestion improvement, even with unrealistic projected transit ridership increases, in the absence of added highway capacity and/or efficiency.
In both the CIS and the Entrance EIS, planners attempted to solve the inherent contradiction in rejecting highway improvements as a response to congestion by projecting traffic increases so enormous they could only be handled by the mass capacity of mass transit. Highway users in the Aspen area have now endured extreme congestion for an additional and unnecessary 15 years, only to see the day of reckoning envisioned by alarmist traffic projections pushed back by another 20 years.
There is no case to be made for the continued transcendence of speculative data over immediate needs. It would be more appropriate to deal with the existing problem, and that problem is a lack of adequate highway capacity.
NOTE: Quotes in italics are taken from the Reevaluation, and individual comments are separated.
Though not always specifically identified as “Conclusions”, the Reevaluation and Technical Reports contain numerous declarative statements which have the quality of being the final word on a particular subject.
“As shown by Figure 1-1, the rate of [transit ridership] growth slowed and was generally stagnant between 1996 and 2004, attributed to such factors as limited existing transit system capacity, delayed improvements in transit, major fare increases, and the overall downturn in the economy. However, transit ridership has been on the incline since 2004. The total number of rides provided on all RFTA services was 3.7 million in 2005, with 1.7 million of these being provided by the commuter services. Ridership numbers as of September 2006 are up 10 % over 2005 levels and, therefore, total annual ridership for 2006 is anticipated to exceed 4.0 million, attributed to improvements in the economy, increasing employment levels, and rising fuel prices. Since 1995, the implementation of paid parking and other TDM [TM] measures in Aspen have also provided incentives to use transit. While slight ridership increases have been occurring, jumping to the next level of ridership (such as that shown in Figure 1-1 between 1994 and 1996) will require major improvements to the transit system to accommodate additional capacity.”
The economic downturn assertion as an explanation of flat transit ridership growth is unsupportable.
As one measure of area economic health, Eagle and
Bus ridership increases since 1996, clustered in the most recent years, are largely irrelevant to a discussion of the Entrance to Aspen. RFTA inaugurated an extension (Grand Hogback route) of the Valley Route (which serves the Highway 82 corridor), 26 miles beyond Glenwood Springs on Interstate 70. Also, ridership on the Ride Glenwood Springs system within that city has increased significantly since 1995. Less these two ridership gains, the remainder of the RFTA system carried 79,000 fewer riders in 2006 than it did in 1996, and as previously discussed, bus routes relevant to the Entrance to Aspen have accounted for most of that decline.
There has been no shortage of new population to provide potential new customers regardless of their economic circumstances, and, as in the cited example of gas price increases, economic hard times are generally expected to enhance the attractiveness of a perceived cheaper alternative to the automobile.
The Aspen segment of the Valley Route has been losing market share, not impoverished riders.
The failure of area population increases to translate
into proportional growth in traffic going into Aspen is also relevant to the city’s
innovative disincentive tool – intentional congestion. The peak hours of congestion are Monday
through Friday, inbound morning, outbound afternoon, about six months of the
year. This provides numerous
opportunities to access
The overwhelming impression created by all the data
is that traffic volumes at the Entrance to
As noted, RFTA did need to raise fares due to a reported 87% increase in operating expenses from 1995 to 2005, while increasing its service miles by 10%. Part of the underlying rationale for increased transit service seems to assume that if RFTA buses had excess capacity which could allow affordable fares with the income from increased ridership, they would then be able to offer lower fares and attract that ridership. One of the reasons given for lagging ridership - “limited existing transit system capacity” - suggests the need to increase service miles, and that will be the effect of the BRT project. However, given the ratio between service miles and operating costs, increasing service miles is not likely to help the fare structure.
Undoubtedly, the spike in gas prices in 2006 resulted in increased bus ridership, but that event did not restore historical ridership levels, which had declined despite significant population growth in the service area. Long term planning based on this one indicator is not recommended.
The source of past transit ridership increases is no
mystery. Expansion of service into new
geographical areas, and increased frequency of service, can be matched to the
years which show substantial ridership gains.
One exception is 1995, when expanded parking controls and entirely new
parking fees were imposed in the City of
The point of diminishing returns for expansion into new geographic areas has been met with the Grand Hogback route, an additional 52 mile roundtrip service which netted 67,392 riders in 2006. In similar fashion, the improvement in frequency between one hour and half hour headways is a significant advantage for riders, but considerably less so when the improvement is from every 30 to 15 minutes.
Parking fees have already reached $16 per day for eight hours of on-street parking in Aspen, and expansion of the paid zone would have a fraction of the impact of the original launch. Exercise 3 (Link 4) in the Appendix evaluates the effectiveness of the program at inception; the maximum reduction in 1993 traffic attributable to paid parking was about 5%.
Another source of new ridership is new development,
with the expansion of Aspen Highlands contributing an additional 300 transit
riders per day on the only Aspen Metro area CCB route to experience such growth
in the last decade. Consequently, the
single biggest potential source of growth in new RFTA ridership in the upper
valley will come from
The flat growth in bus ridership since 1996 is the
profile of a mature business that has tapped its primary market and must now work
to find a few percentage points of new clientele. This description is equally apt for either
RFTA or the City of
Consequently - inspirational sports clichés notwithstanding - nothing regarding conditions in the Roaring Fork Valley suggests that there is any “next level” to which RFTA can jump.
“As stated in
Section 2.1.3, major capacity increases are needed to accommodate the next
level of increased ridership numbers.
Implementation of the bus lanes/LRT is a critical step in providing
additional transit system capacity. For
example, with the addition of the exclusive bus lanes, 5-minute headways could
be provided on a consistent basis for buses operating between
2030 traffic demand at
The relationship between transit ridership, vehicle trips, and TM measures is the essential nexus of the Reevaluation, and yet the two paragraphs above had to be extracted from two different Technical Reports. There is no additional material anywhere in the Reevaluation which further explains what is expected for 2030 traffic, or why.
The use of a peak hour transit ridership number is not found anywhere else in the EIS process, nor is this statistic provided by RFTA for current operations, making any comparative analyses extremely difficult.
Despite abundant credit paid to the current TM program for successfully limiting traffic to 1993 levels, the Reevaluation claims it won’t be enough to handle a projected 57% increase in future traffic. The predicted summer average daily traffic increase of 16,200 vehicles, equivalent to an additional 25,920 person trips, will require a drastic increase in mass transit capacity - operating in dedicated bus lanes - to accommodate the 413% transit ridership increase.
If a 50% average bus occupancy can be maintained throughout the day, the predicted 32,000 average daily riders can be served with about 1500 bus trips at the Entrance to Aspen. Since 1500 buses would be the equivalent of 20 straight hours of “peak hour” bus operation, perhaps the Reevaluation didn’t really intend to predict 32,000 riders per day, but that would mean their traffic projection is too high. Or perhaps planners expect a higher average ridership than 50%. There is no way to know, but it really doesn’t matter, because all of these numbers are absurd.
The Reevaluation projections have no shred of credibility, particularly in the context in which they are made:
The Reevaluation quotes a “low growth scenario
projection” from the FEIS that the population of the City of
The Intermountain Transportation Planning Region reported that commercial enplanements at the Aspen/Pitkin County Airport increased by 0% between 1994 and 2005.
One estimate suggests there might be a 20% increase
in visitors to
The City of
The Reevaluation went back to the West Glenwood
Springs to Aspen Corridor Investment Study (CIS) to find a prediction for a 40%
“The TM program
has succeeded in maintaining average annual traffic volumes to just below
1993/1994 levels. However, as predicted,
Or congestion could be eliminated - a far better outcome than just holding off further increases - with increased highway capacity.
”The updated traffic analysis validates the FEIS findings that dedicated transit components, in addition to roadway improvements, will be needed to serve future travel demand in the corridor.”
“Provision of dedicated rights-of-way included in the Preferred Alternative (for LRT, buses, or other high-capacity transit modes) will be critical to providing the transportation capacity needed to accommodate forecasted person trips in the years 2015 and 2030…”
Forecasted person trips for 2015 aren’t going to materialize, as explained in the Data section of this report.
Regardless, even if there were any credibility to the projections for 2030, the Reevaluation failed to substantiate its most basic premise - the necessity to reserve an entire highway lane for the exclusive use of 8 or 9 buses making a maximum of 37 trips per hour.
“Absent a viable travel model with which to
forecast 2030 traffic volumes, the methodology used for CDOT statewide planning
was adopted for this analysis, and 2030 traffic forecasts for the State Highway
82 corridor were prepared using the CDOT traffic database (CDOT, 2006c). The
CDOT database incorporates a traffic forecast calculator that uses growth
factors developed from trend analysis of current and historic traffic counts
included in the data base, including periodic traffic counts, as well as continuous
count station data for all state highway system facilities. Growth factors
derived from CDOT continuous count station data for
Whatever this paragraph is trying to say, the methodology is irrelevant if data is ignored, omitted or misapplied.
This case study uses the most basic form of projection – historical extrapolation, described above as “trend analysis of current and historic traffic counts”. Our results make it obvious that the Reevaluation did not follow any such procedure. Nor does any demographic information appear to have influenced the Reevaluation findings.
The traffic and transit forecasts of the Reevaluation perpetuated a series of fabrications designed to fulfill a need. The need was to sell a huge expansion of mass transit services on a dedicated right of way.
The EIS process for the Entrance to Aspen, and the West Glenwood Springs to Aspen Corridor Investment Study (CIS) (see Addendum A – Link 5), are inextricably entwined, even though the CIS specifically excluded the entrance from its traffic congestion projections. The methods employed to contort both processes into an endorsement for a mass transit response to traffic congestion reveals two separate sets of problems.
The EIS process promised a complete and objective analysis of all feasible alternatives, but lacking the necessary oversight, failed both initially and upon reevaluation. The intent to insure a complete process serves the interests of the State of Colorado, but if the state assumes that a federal agency will supervise the process, while at the same time the federal agency defers to state authority, there is ultimately no accountability above the level of program engineer.
The CIS was concerned with satisfying federal requirements for participation in the purchase of a pre-existing rail corridor, and with qualifying a mass transportation project for federal funding. There was no obligation under the federal process to assess anything other than transit alternatives, nor to show any positive impact on traffic congestion.
The Federal Transit Authority (FTA) does not prioritize transit projects based on potential for congestion reduction due to a long history of failed efforts to accurately model the impact of transit on highway traffic. In an urban environment, with combinations of streets and destinations that typically number in the thousands, the complexity of the variables involved have frustrated efforts to create a reliable computer model. Consequently, the consideration of the potential for highway expansion to outperform mass transit for both congestion relief and affordability is not required to qualify for federal transit funding - even in a rural environment where such analysis would be practical, prudent, and relevant.
Interacting with the transit-centric FTA process, federal legislators have a general inclination to eliminate some layers of regulatory burden for small projects, a pragmatic and sensible accommodation in most situations. However, this streamlined process in combination with the absence of any highway alternatives analysis has produced a compound effect on transportation planning in the Roaring Fork Valley which is very damaging to the state’s interest, and has led to a serious misapplication of taxpayer funds.
The mass transit element for the Entrance to Aspen, which was originally intended to be light rail, has evolved into the Bus Rapid Transit (BRT) system for the entire Roaring Fork Valley. RFTA recently qualified this system for funding under FTA Section 5309 Very Small Starts guidelines, despite stipulations which are expressly intended to block a project of this size from access to the less stringent oversight requirements of the program.
If the reader is inclined not to read the data analyses in the Appendix, or the evaluation of the CIS in Addendum A, it is strongly encouraged that Addendum B, Roaring Fork Valley Bus Rapid Transit Project, Citizen Comment to the Federal Transit Administration, (Link 6) not be skipped.
The FTA acceptance of RFTA’s BRT VSS grant request epitomizes the complete collapse of federal standards of review, and their abandonment of taxpayer protection. The Citizen Comment details the project’s violation of program entry guidelines, and provides specific operational data demonstrating the tangible negative consequences of deviating from those guidelines. These comments are fact based and irrefutable.
In keeping with what might as well be the official Department of Transportation policy for dealing with irrefutable challenges based on empirical fact, the complete defense offered by the FTA is comprised of a two sentence non-response from the FTA Region VIII Regional Administrator:
“The FTA appreciates your comments, and further encourages you to continue to voice your concerns locally as the RFTA BRT project continues through the public participation process. At this time, the FTA reaffirms the determination to approve and to proceed with the RFTA BRT based on the criteria established in the July 2007 Updated Interim Guidance on Small Starts.”
The regional administrator could just as easily have stated that the FTA reaffirms its decision in direct defiance of the criteria established in the Interim Guidance, so minimal is the level of concern that any governmental authority will ever enforce funding regulations, or hold any federal administrator accountable for ignoring them.
A NEPA EIS process for a state highway was misappropriated to satisfy the policy whims of a small town city council. In order to provide the statistical foundation to support a political preference unsupported by reality, the data in a federally mandated process were distorted and corrupted.
The abuse of the EIS process led to the preparation of a Corridor Investment Study which produced conclusions and projections which are impossible to reconcile with actual observations and real information.
Officials responsible for the Reevaluation of the original EIS ignored and excluded specific and irrefutable challenges to the accuracy of information used to legitimize the preferred alternative of the city council, despite the rejection of that alternative by the voting public.
The electorate of an entire region has been lured into approval of a tax increase for a mass transit system expansion which they almost certainly thought was a professionally prepared, officially reviewed, and factually vetted proposal which reflects actual needs and employs comparative studies - as evidenced by the availability of federal funding.
In fact, the BRT proposal is a continuing effort to rationalize reserving two lanes of highway at the Entrance to Aspen for the exclusive use of buses, and the inclusion of the project in the VSS grant program was for the purpose of avoiding any of the factual vetting which the public should rightfully expect from the federal government. In a further departure from federal fiduciary responsibility, the FTA has also accepted the Corridor Investment Study as a sufficient substitute for an Alternatives Analysis required by the grant program, despite the fact that the CIS did not analyze any alternatives.
For the State of Colorado, there exists a fundamental defect in using any transit oriented CIS as a basis for a Regional Transportation Authority (RTA) planning process. The enabling legislation which created the regional transportation authority concept has an exceptionally broad scope, and includes the ability to authorize funding for nearly every practical means of moving goods and people (Colorado Revised Statutes 43-4-602(16)). Planning processes for an RTA should be as broad based as the intent of the legislation. Under no circumstances should material from a Federal Transit Authority grant application be acceptable as a substitute for a comprehensive RTA transportation plan – the comprehensive plan must necessarily precede the specific transit grant request.
The deficiencies of process in the East of Basalt to Aspen EIS may have been an aberration caused by a unique set of circumstances and people. The subsequent collusion of data between the Entrance to Aspen FEIS, the CIS, and the Reevaluation in support of a major expansion of an already massive transit system is not as easily dismissed.
The forecasting excesses of the FEIS and Reevaluation for the Entrance to Aspen were matched by the CIS, which managed to project 3.46 million annual riders by 2008 on just the Valley Route served by a new BRT system. The real ridership number for that route was about half that amount in 2006, a discrepancy which could not possibly be closed with more frequent service.
Much like the transit-impact-on-highway-congestion problem which the FTA has yet to resolve, the problem of unmet transit ridership projections has plagued transportation planning for decades. Projects in major metropolitan areas may benefit from perpetual updates in modeling software, the most recent of which - SUMMIT 1.5, has had some success in reining in exaggerated transit projections. The RFTA BRT project is inappropriate for either Small Start or Very Small Start funding consideration (Link 7), but at least a Small Start designation would have required screening by SUMMIT. The potential for results unsatisfactory to mass transit interests no doubt played a major role in the misclassification of this project into the least stringent oversight regimen of all possible programs.
Whether transportation professionals are personally predisposed to favor mass transit elements over highway improvements, or mass transit vendors are exerting improper influence, or relationships and loyalties between public officials and private sector consultants make objectivity impossible, or whatever explanation might exist, it is beyond the realm of coincidence that the recently completed written reevaluation for the Entrance to Aspen could be so deficient and misleading in just those specific areas necessary to validate a predetermined transit plan.
The extraordinary inflation of traffic projections contained in the FEIS and Reevaluation does not require any transportation planning expertise to discover; it requires that someone consider it their responsibility to check. The assessment of the accuracy of past traffic projections provided in this case study is neither exact nor exhaustive, but is more than adequate to confirm that a massive problem exists.
Using very basic techniques, alternative traffic projections were created for this report to illustrate the relative ease of developing fundamental reality checks using real world data; and not incidentally this exercise provided a forecast which is far more likely to accurately predict conditions in 2015 than the official document being reviewed.
The impunity with which outrageous conclusions are prepared and published is endemic to a culture in which those in authority avoid any responsibility for the work being produced. However stunning the statement from the US DOT Office of Inspector General that “generally, we are not in the position to review for accuracy the EIS or ROD of a specific transportation project,” it was matched in the same letter by the observation that, “judicial and political avenues are available to you to pursue your ultimate goal of approval of the Entrance-to-Aspen project.” Emphasis added.
There may be a political solution to the need to obtain voter approval for a change of use of 4(f) open space land, but there is no political solution for missing data, false assumptions, or the purposeful manipulation of a public process. That the final message from a federal investigative office was the literal embodiment of the sentiment, “So sue us,” could not be more appropriate in summing up the level of concern in the federal bureaucracy for the waste and possible fraud being perpetrated on the people of Colorado. 
All avenues of redress from the federal government have been exhausted. The State of Colorado must tend to its own interests and that of its citizens, and that will require protection from the malfeasance of federal government oversight.
Colorado state law establishes the Transportation Legislation Review Committee (TLRC), and provides the committee with broad powers of “guidance and direction” over all phases of the operation and planning of state transportation systems and projects, including “any phase of operations of any regional transportation authority”. In addition to guidance and review, the committee may “require financial or performance audits to be conducted” and conduct a “postoperation review” of the “planning and construction of highway projects”.
The TLRC is the last line of defense for the people of Colorado in all matters relating to transportation, and every aspect of the Entrance to Aspen/Roaring Fork Valley BRT project should be a priority issue for the committee.
In some respects, much of the damage of BRT has already been done. RFTA recently banked approximately $25 million in bond proceeds for capital expenditures that will subsequently result in more operating and maintenance costs - which will further increase annual budget obligations in addition to the debt service. However, RFTA therefore does have the resources needed to satisfy a TLRC demand to fulfill performance audits and cost benefit analyses which should have been a prerequisite to entry into a federal grant process.
If the first round of $20-$24 million in federal grants is ultimately awarded to RFTA for BRT, the citizens of the Roaring Fork Valley will find themselves with an even larger annual tax burden to support operating expenses for what promises to be one of the most inefficient and wasteful bus systems in the nation. At minimum, the TLRC should require RFTA to answer the question posed (Link 8) in Addendum B: How many people will be riding the local corridor bus route if BRT is introduced?
The lingering problem of traffic congestion by design at the Entrance to Aspen can also be positively affected by the TRLC, both by its own action, and in conjunction with the Colorado Department of Transportation (CDOT).
For immediate action:
A. CDOT should propose that, in the event the electorate of Aspen approves an alternative for the Entrance to Aspen, the project will be restored to the list of Strategic Projects, the so-called 7th Pot funding category. Highway 82 from Basalt to Buttermilk was built under this designation, and the final segment into Aspen was removed only due to delays caused by public controversy regarding the implementation of the preferred alternative. The end of that controversy as signaled by voter approval of a new alternative should be the basis for restoring priority funding.
should make a proactive outreach effort to the citizens of Aspen to inform them
of the Level of Service data which was withheld in the Entrance to Aspen EIS
process (see Table 11 - Link 9). Voters have a right to the information
necessary to make a fully informed decision, including the expected congestion
relief derived from increased highway capacity.
That outreach effort should include further information developed in the
East of Basalt to Aspen DEIS which addresses additional questions regarding the
impact to downtown
C. A highway alternative other than the preferred alternative could be approved for construction by the electorate of the City of Aspen by the grant of a change of use on 4(f) property at the Entrance to Aspen. To remedy prejudicial remarks made regarding that decision (Link 10), CDOT should take immediate action to develop a reliable estimate of the time and expense necessary to issue a new Record of Decision (ROD) pursuant to 23 CFR PART 771.127 (b), in consideration of the following factors:
1. There are no critical physical differences between the alignments of the preferred alternative or either of the proposed citizen initiated alternatives. None of the findings contained in the Reevaluation of the State Highway 82 / Entrance to Aspen Final Environmental Impact Statement and Record of Decision, June 2007, or the Technical Reports, April 2007, which pertain to physical alignment, would be significantly different. The following portions of the Technical Report contain findings of physical impacts and mitigation measures which would be largely or completely unaffected by either of the proposed citizen initiative alternatives:
a. Water Quality
e. Wildlife and Threatened and Endangered Species
f. Wild and Scenic Rivers
h. Archaeological Resources
i. Paleontological Resources
k. Noise and Vibration
l. Visual Resources
m. Potential Hazardous Waste Sites
n. Historic Resources
2. The City of Aspen has adopted policies designed to limit traffic to 1993/1994 levels by the use of Transportation Management (TM) measures, none of which are dependent on highway design. The traffic goal itself is not binding on CDOT or any future city administration, nor required by any environmental law. Consequently, the Technical Report findings which relate to this objective will either be unchanged as a result of maintaining the TM measures, or rendered moot by abandonment of the goal. Subject matter which relates to this consideration can be found in the following reports:
a. Purpose and Need and Project Objectives
b. System Management
c. Traffic Characteristics and Safety
d. Social Environment and Community Character
f. Air Quality
3. The Section 4(f) Resources Technical Report may experience a revision of the estimate of affected acreage in the event that the Direct Connection, a design option without a cut and cover tunnel, becomes the new preferred alternative of the Aspen electorate. However, the mitigation already implemented far exceeds any additional impact.
Capital Costs Technical Report would either remain unchanged, or experience a
reduction in costs in the event the Direct Connection is the preferred
alternative of the
5. As the result of increased capacity for general traffic, major backups and significant delays caused by existing congestion would be eliminated with either of the proposed alternatives. The subject matter of the Technical Reports listed in item 2 would reflect numerous improvements in impacts over the conditions expected with the preferred alternative.
6. Ten Project Objectives contained in Purpose and Need and Project Objectives section of the Technical Reports Volume are policy statements which are similar in character to the goal of limiting traffic, described in item 2. These policies are not binding on CDOT or any future city administration, nor required by any environmental law. Regardless, all would be fulfilled as well or better by either of the proposed alternatives with the exception of Objective 2, Transportation Capacity, in which it is explained that, “Though the highway system will operate under congestion, this congestion is considered part of the disincentive for single occupancy vehicle (SOV) travel and will increase transit usage.”
Under Colorado law, a citizen initiated ordinance must by definition set new policy. Both of the proposed ordinances state that: “The City of Aspen acknowledges that implementation of this authorization requires abandonment of the policy described in the Entrance to Aspen Record of Decision, Project STA 082A-008, August 1998, which employs traffic congestion as a mass transit ridership incentive.”
7. Supplemental information regarding the operation of HOV lanes is not needed. HOV lanes have not just been thoroughly studied; they were actually built over 16 miles of the 18 mile route between Basalt and Aspen. There are no regulatory requirements for the remaining two miles of highway which were not satisfied by the design created in the East of Basalt to Buttermilk FEIS and ROD.
8. The major design features of the proposed alternatives passed the screening analysis of the FEIS, as described in the ROD:
Profile - “The remaining profile options were the at-grade and the cut and cover tunnel.”
Laneage - “The two general highway lanes were unrestricted and available for use by any driver with any vehicle occupancy. The two dedicated vehicle and/or transit lanes were reserved strictly for use by the mode and technology options surviving the screening process.”
Mode - The mode and technology options which survived the screening process are “HOV”, “Self-Propelled Buses”, “Electric Trolley Buses”, and “Light Rail Transit”.
9. The alternatives in the Entrance to Aspen DEIS which contain the combination of design features most closely matching the proposed citizen initiative alternatives were identified by assignment of the letters D and F. The FEIS explains that these and similar options were eliminated because, “they do not provide a detailed analysis a [sic] light rail system. The consensus of the community and the EOTC [Elected Officials Transportation Committee] was that further analysis into a light rail system was necessary.”
Whatever further analysis of light rail occurred which was sufficient for the current preferred alternative would be directly applicable to the proposed citizen initiated alternatives.
For near-term action:
E. The TLRC should participate with RFTA in the BRT planning process to insure production of an audit of ridership information, including the completion of an updated Boarding & Alighting survey by individual (see example – Link 11)
For longer-term action:
F. The core public obligation of an RTA should be that it function as a transportation authority as intended, and not simply as a mass transit operator. To that end, the Transportation Legislation Review Committee should develop legislation establishing the framework for RTA planning efforts, particularly those which seek or require increased funding. The process which the legislation defines should emulate the intent of federal Environmental Impact Statement directives to consider all reasonable alternatives – regardless of financial or jurisdictional partitions - in an objective manner which does not prejudice the selection of a particular alternative.
G. The Transportation Legislation Review Committee should develop and publish a checklist style guide to reviewing transportation plans, suitable for use by government officials or the general public. Everything from verifying that characterizations of public input match the actual public comment, to simple reality checks of major estimates and projections; basic tools for interested parties can be developed. The public at large is the best watchdog, but the sheer volume of planning material produced, arcane terms, etc. produce an intimidation factor that needs to be addressed.
The basic components of a standard evaluation process for effectiveness and efficiency of existing transit systems should be developed described and explained, standards of data collection established, and the results published on the CDOT website. For those transit systems not subject to state oversight, voluntary participation should be encouraged. The public, government staff, and elected officials should be given the tools necessary to make reasonable assessments of the cost effectiveness of mass transit operations and system expansions.
H. The CDOT Origin & Destination (O&D) study produced for the Roaring Fork Valley in 1993 & 1994 should be updated. This base line information, and the cost and effort of acquiring it, will be wasted without follow up data collection. Unique features of the valley, such as HOV lanes as part of a four lane highway, and the general evolution of land use planning philosophies, have created an open air laboratory situation which should be exploited, possibly in conjunction with educational resources.
I. Technology assessments should be ongoing to insure that the latest innovations in transportation modeling software and data collection are utilized as soon, and on the smallest scale, as practicable.
Appendix - Exercises 1-3
Vehicle Count to Person Trip Conversion Factor:
1994 CDOT O&D Survey – Lowest average occupancy recorded at Entrance to Aspen, winter or summer = 1.6 person trips per vehicle
Average Transit Party Size:
Unknown = >1 (Employed conversion factor of 1.3 riders to 1 vehicle to assign an equivalent number of vehicle trips to transit person trips – see Exercise 1)
Percentage of “Valley Route” Bus Riders Crossing Castle Creek Bridge (CCB) at the Entrance to Aspen:
Independent 2007 spot check – 46%
RFTA 1997 Boarding and Alighting Survey – 72%
Quantifying transportation numbers may be more art than science, though advanced technical degrees and lifelong careers are devoted to the task. Short of interviewing each individual as they leave their home, some compromises will always be made in determining what effect one mode of transportation has on another.
For advocates of mass transit, there seems to be an irresistible temptation to equate transit trips with vehicle trips, as though 5 million annual bus riders are equal to 5 million cars taken off the road. Converting ridership to vehicle trips is not nearly that easy, and is never exact.
In the three exercises which follow, an effort was made to be more precise than a simple one to one, bus rider to car trip formula; while not belaboring the issue or committing resources which would bankrupt the average citizen.
Distinctions between the ridership on the full RFTA bus system and that portion which impacts the Entrance to Aspen have been nearly non-existent, and most transit advocates rely on system-wide ridership figures during discussions of the entrance. Aspen residents almost certainly don’t know that ridership fell between 1997 and 2005 on those routes which impact the entrance, or that during those years most of the new ridership for the full RFTA system was the result of expanded service just within of the city of Glenwood Springs.
The Highway 82 corridor has the highest ridership, and the highest proportion of ridership which has no effect on the Entrance to Aspen. For this study, some effort had to be made to adjust the ridership numbers for this route to avoid a massive overstatement of the proportion of bus riders to private vehicles at the entrance. Some care also had to be taken to distinguish between the past “Valley Route” ridership numbers when comparing those with more recent “Highway 82 corridor” figures, as the former statistic included passengers between Aspen and Snowmass Village in the same category as riders between Aspen and Glenwood Springs.
Local routes in the immediate Aspen area have fewer riders, the annual totals have been more constant over the years, and a higher proportion of the ridership has some effect on entrance vehicle traffic. Rather than repeat the sampling described below for the Cemetery Lane route on all of the local routes, this study settled on a hybrid approach in which an adjustment was made for the Valley Route and Highway 82 corridor ridership numbers, but not for the other routes. While this approach overstates the actual CCB relevant numbers for transit, absent the significant skew which would have been introduced without an adjustment to the corridor figures, the proportion of change over time should be accurate to a fairly high degree.
Despite this disclaimer, there will still be an irresistible temptation for transit advocates to treat some of the enumerators in the following exercises as absolute numbers, i.e. “The adjusted 2005 annual average daily total of CCB riders is 6237, for a vehicle equivalence of 4798.”
Some of the factors which prevent the figures developed in this case study from being particularly useful in determining the absolute number of vehicle trips shifted to mass transit:
2. Any analysis which attempts to quantify the effect of transit trips on vehicle trips is complicated by “induced” trips which would otherwise not occur if the bus was not available. For example, in a RFTA survey from 2004, 37% of respondents answered “no car available” at the time of the trip as a main reason for taking the bus.
3. Because of the magnitude of the ridership on the Valley Route (1,724,507 in 2006) a few percentage points in the CCB crossing modifier yields a significant difference, but an estimate was made necessary by limited detailed ridership information from RFTA.
4. Because the average transit party size modifier is applied to total ridership, a minor adjustment yields a significant difference in the vehicle equivalent credit, but an estimate was made necessary by limited detailed ridership information from RFTA.
5. It is not possible to determine if HOV lanes have contributed to an increase in car-pooling, thereby increasing average vehicle occupancy and reducing total vehicle trips, because the 1993-94 O&D survey has not been repeated.
6. The inclusion of Ski Shuttle ridership in these figures may not be appropriate, as further discussed in Exercise 2 below.
Any refinement of the vehicle equivalent figures based on these observations would result in a downward adjustment of the transit share, and a lesser impact on traffic volumes.
As a further demonstration of the caution about using the numbers here for any other purpose than a general assessment of the accuracy of past traffic projections, or transit ridership proportions, consider the modifier used to estimate the number of passengers on the Highway 82 corridor who actually cross the Castle Creek Bridge.
Total Highway 82 Ridership, 2006 - 1,567,304 = 4294 per day
Adjusted by 60% modifier = 2576 Highway 82 riders crossing the CCB per day
Approximate number of bus trips = 107 per day
It requires an average of 24 people entering or leaving Aspen on every single Highway 82 corridor bus, every single day, year-round, from the earliest morning to the very last run, or the number of riders credited with reducing traffic volumes at the Castle Creek Bridge is too high. In other words, based just on this reality check of one assumption for one route, we are almost certainly assigning too high a value to the effect of bus ridership on diverted vehicle trips for the purpose of these exercises.
(Return to Link 2)
Projections: East of Basalt to
Traffic Counts: CDOT – 1987
CDOT - 1993
CDOT - 2005
Bus Ridership: RFTA
Determining the accuracy of vehicle count projections in the context of a transportation plan which has converted some of those trips into mass transit person trips requires conversion factors between the two. The CDOT O&D Study of 1992 and 1993 provided average occupancy (excluding buses) of vehicles traveling on Highway 82. This exercise uses the most conservative number reported: 1.6 persons per vehicle.
RFTA ridership information is not sufficiently detailed to provide average party size for transit riders, but because people regularly travel on buses in groups of two or more, the party size is >1. For this exercise, we split the difference with vehicle occupancy and used a conversion factor of 1.3, which means that for every 1.3 people on a bus we credit that bus with the equivalent of one vehicle trip.
RFTA ridership counts are available by route, allowing analysis of the effect at a specific location. In this case, the Castle Creek Bridge (CCB) in Aspen is the point of comparison because it provides the highest recorded vehicle trips and the greatest number of transit person trips. The CCB is the heart of the Entrance to Aspen.
However, although a bus route may cross the CCB, this does not necessarily mean that all the passengers do.
Our starting year for traffic data is 1987, and in that year the Highway 82 portion of the “Valley Route”  , which would account for the greatest future growth in bus ridership, terminated about 20 miles north of Aspen in El Jebel. This route was eventually extended to Glenwood Springs, a distance of about 42 miles. With each extension of the route, more opportunities were created for downvalley (DV) residents to use the bus for area trips completely separate from the Entrance to Aspen.
Boarding and Alighting Survey conducted by RFTA in 1997 found that 72% of the
A spot check of two full length, round-trip, Highway 82 corridor runs on August 23rd of 2007 found that 46% of riders crossed the Castle Creek Bridge. While the small sample size may require a fairly wide margin of error, the finding is very consistent with demographic trends toward population growth centered in the DV areas, and recent ridership increases on the Ride Glenwood Springs route. The difference was split between the current observation and the historical survey, and a 60% modifier was applied to Highway 82 ridership to reach a CCB crossing estimate.
Other routes (i.e. Highlands, Cemetery Lane, etc.) which are relevant to this exercise either offered limited options to disembark prior to the bridge, or showed little change in ridership since 1987. The numbers for these routes were used “full strength” without a percentage modifier – in other words, we assumed that 100% of the riders crossed the CCB because whatever error this represents would be consistent for the entire study period.
Every assumption made in this analysis is believed to favor a finding of a high degree of shift from vehicle trips to mass transit.
The adjusted 1987 annual average daily total of CCB riders is 3111, for an equivalent number of vehicle trips of 2393.
The adjusted 1993 annual average daily total of CCB riders is 4871, for a vehicle equivalence of 3747
The adjusted 1995 annual average daily total of CCB riders is 6773, for a vehicle equivalence of 5210
The adjusted 2005 annual average daily total of CCB riders is 6237, for a vehicle equivalence of 4798.
The resulting numbers above are useful as a trend analysis only, due to the many other factors which prevent the adoption of these figures as absolute numbers. In other words, the difference in the vehicle equivalent number between 1987 and 2005, which shows a 100% increase in the effect of transit ridership  on vehicle counts at the Entrance to Aspen, is probably about right, because both numbers incorporate the same type of error.
of actual 1987 traffic counts, and projections from the East of Basalt to Aspen
DEIS, 1989, provides a significant practical advantage. Projections for the
The projected traffic increase for 2010, evened out over 23 years at an annual increase of 530 vehicles per annual average day, and accumulated for 18 years, provides a projection of 31,240 vehicle trips for the year 2005.
Consequently, there is a shortfall of 7340 daily vehicle trips between projections for 2005 and that year’s actual AADT.
1987 traffic projections, when adjusted to account for mass transit ridership increases, overstated future traffic volumes by 4935 vehicle trips per average annual day for the year 2005. (7340 – 2405 = 4935).
1987 traffic projections were too high by about 300%.
In the 1997 FEIS there were no apparent adjustments to traffic projections to indicate that transportation planners recognized the error in the prior study, but changes to the study protocol do make it difficult to discover that failure. For example, projections were moved out from 2010 to 2015, and figures are provided for only Winter Average Daily Traffic (WADT) and Summer Average Daily Traffic (SADT) – not the average for the entire year.
However, we can still easily determine that the degree of error from 1987 was not repaired, but rather obscured. The winter and summer projections made in 1997 for 2015 bracket the 1987 projections for 2010 such that the Annual Average (AADT) total would be nearly the same. The 1997 decision to move the projections out to 2015 allowed more time for those predictions to be satisfied, but not to the extent necessary to reconcile the huge shortfall in predicted future traffic growth.
The number 2405 - the diverted daily vehicle trips attributable to increased bus ridership at the end of the eighteen year period from 1987 to 2005 – represents the traffic data relevant to the FEIS, ROD and Reevaluation. It is this missing calculation which should have resulted in an acknowledgement of error in prior traffic projections and a downward revision in future transportation demand.
The 2405 daily diverted vehicle trips at the end of eighteen years works out to an average growth in each of those years of 137 additional vehicle trips per day without the increase in transit ridership. The authors of the EIS documents should have used this actual transportation demand growth rate during the recent past to estimate future potential vehicle counts in the year 2015. This rate of growth applied to the remaining study period indicates a 5.7% increase (1370 vehicles per day), for a 25,270 AADT figure in 2015, not the 34,000 predicted by the EIS process.
(Return to Link 2)
(Return to Link 3)
Exercise 2: Has
RFTA ridership ever accounted for 37% of the person trips at the Entrance to
Aspen, even if only for a peak hour?
Traffic Counts: CDOT - 1993
Bus Ridership: RFTA
The simple answer is: No
The more intriguing question is how this particular urban myth got started, and why public officials are either perpetuating or failing to correct this obvious misconception.
The first step in dealing with percentages is to answer the question: Percentage of what?
If you know there are 40 individual people riding the bus, and 60 individual people riding in cars, the statement, “40% of total person trips were made on a bus,” is automatic, and the actual steps needed to solve the problem mathematically are not consciously employed.
The formal solution to the problem requires a two step process in which the two numbers are added together to find the total number of person trips. You then divide whichever group you’re interested in by the total:
40 + 60 = 100 40 / 100 = .4 or 40% bus 60 / 100 = .6 or 60% cars
If you mistakenly employ a one step process and simply divide 40 by 60, suddenly 40 percent of person trips made on a bus appear to swell to 66%. In reality you’ve calculated a completely different and largely meaningless proportion regarding the size of the bus rider group as a percentage of vehicle passengers.
If you commit that same error with more widely divergent numbers, i.e. 1,189 bus riders and 19,102 people in private vehicles, the error is less noticeable.
1,189 / 19,102 = 6.2%
1,189 + 19,102 = 20,291 1,189 / 20,291 = .0585 or 5.9%
The slightly lazy way of coming up with 6.2% as the percentage of total person trips on a bus proves to be 5.9% of total person trips on a bus when calculated correctly. You can see from these two examples that the higher the proportion of people on a bus – as in the 37% of our question - the greater the percentage error.
We know this type of error occurred in the 1992 summertime numbers gathered in CDOT’s O&D Survey, and reported in their 1993 report.
According to the 1992 Summer CDOT O&D Survey (March 1993):
The O&D survey was exclusively concerned with gathering vehicle data, which is why they reference RFTA for the transit figures. The 19,102 vehicle person trip number used in the math example above came from the O&D study. Rather than add 19,102 to RFTA’s 1,189 transit person trip number to learn the total person trip figure before doing the division, study authors made the one step math error to arrive at 6.2% rather than 5.9%.
Much of the problem with the “37%” claim is probably due to this same error, but we encounter a different problem in trying to prove the case.
According to the 2007 Reevaluation:
"Significantly, CDOT 1993 and 1994 origin and
destination (O & D) surveys also showed that 6% of summer trips and 17% of
winter trips using the State Highway 82 corridor were made on RFTA buses (CDOT,
1997). For peak hour operations affected by congestion, the RFTA person trip
share was even higher, with RFTA buses carrying about 37% of the winter person
trips across the
Unlike the summer survey, the 1993 Winter CDOT
O&D Survey (February 1994), does not provide actual bus ridership data, but
confirms that; “The Roaring Fork Transit Agency (RFTA) conducted an on-board
transit survey during the same time the roadside surveys were being done at
In other words, the winter O&D reconfirms that the two sources of data must be added together to arrive at total person trips, but then doesn’t supply the data. Neither the specific counts of transit riders nor the percentages are supplied in the winter survey as they were in the summer version. The 37% statement does not originate in the O&D Survey
In an effort to track the origin of the 37% figure, contacts were made with the Executive Director of RFTA, the former FEIS Project Manager, and an assistant to the Program Engineer for the Reevaluation. The source for the figures quoted in the Reevaluation is traceable to two pages of graphs (Pages II-6, II-7) in the Basalt to Buttermilk FEIS, but the source of information for the graphs is not known.
So, the effort to obtain the actual numbers necessary to test for the math error found in the summer survey hit a dead end, but the key phrase from the Reevaluation provides a clue to a completely different issue: “…RFTA buses carrying about 37% of the winter person trips across the Castle Creek Bridge during the a.m. peak hour…”
The most significant aspect of the various contacts with RFTA and CDOT is that all of these officials are directly involved with the collection and application of the data behind the “37%” claim, but not one of them volunteered the fact that this percentage, whatever the actual number it generates, could only potentially be accounted for by skier shuttle ridership.
Bus service to access three different ski areas from the town of Aspen were operated by ski area owners prior to the advent of a public transportation system. As part of the public policy discussion regarding the shifting of vehicle trips to mass transit at the Entrance to Aspen, the ridership on the ski shuttles has very little relevance. Not only does this ridership represent vehicle trips that have never been made, but they are also primarily contra-flow, with inbound morning congestion unaffected by the mostly outbound skier ridership, and vice versa in the afternoon.
The skew introduced by the skier shuttle numbers is substantial when averaged out over the whole year, but skier trips produce a particularly anomalous sample when confined to a winter “peak hour”.
The winter and summer O&D surveys provide peak hour vehicle trip information, with the observation that, “the peak hour value ranged from a low of 7.8% to a high of 9.8%” of the daily total vehicle count. The Entrance FEIS uses 8.5% of the daily vehicle total to estimate peak hour traffic volumes.
The 554,465 Aspen Skiing Company riders reported in 1993 were all carried during eight to nine hour periods about 140 days out of the year. No peak period bus ridership information is available, but it can be safely assumed that most of the skier shuttle trips were clustered in the first and last two-hour segments of the ski day. A total of 560 peak transit hours over the course of a ski season works out to a slimly possible maximum of 990 passengers per peak hour. However rough this estimate may be, it provides the basis for a kernel of an explanation of how a 37% transit share was ever imagined.
The actual total of auto & truck person trips for Wednesday, March 20, 1993, was 34,509. Peak hour person trips (8.5% x 34,509) work out to 2933 people traveling in vehicles. If RFTA had accounted for 37% of the total peak hour person trips (transit and vehicle), 1,723 people would need to have traveled by bus during that peak hour. However, that number was not physically possible – there weren’t enough buses.
If RFTA only actually accounted for a number of riders that represents 37% of the vehicle peak hour person trips, as in our math error example, RFTA’s share drops to 1085 riders and 27% of the total person trips. It is likely that this accounts for 10% of the error in the “37%” claim.
Borrowing from the physically counted summer daily transit ridership numbers provided by the O&D study, 180 non-skier peak hour transit trips added to 900+ skier trips produces a peak hour person trip estimate in the 1100 range, and correlates nicely with the 1085 we get with the computation in the previous paragraph. Consequently, on the morning of March 20, 1993, RFTA may have accounted for 27% of the total peak hour person trips, about one sixth of which would have had any impact on traffic congestion.
So, while it may not be impossible that RFTA carried 27% of the total person trips during a winter A.M. peak hour, 83% of which were mostly outbound skiers  , RFTA most certainly does not carry 37%, or even 27%, of the total person trips which are relevant to traffic congestion.
Regardless, the 37% claim has taken on a life of its own, completely immune to a basic math check, and free of any qualifiers that would identify it, after the math is corrected, as a narrow phenomenon specific to the ski industry.
A newspaper article from October 1, 2007, perfectly illustrates the problem:
"According to a survey conducted by the Colorado
Department of Transportation in 1993 and 1994, of the people entering Aspen via
the Castle Creek Bridge, 20 percent did so on a bus. This year, RFTA
expects 35-40 percent of the people entering
Barring the appearance of something on the order of 278 inbound, fully loaded, 42 seat buses every winter day, there is no chance that 35-40 percent of the total inbound person trips to Aspen will be carried on a bus.
Stepping back and using the broadest indicators available - total annual Castle Creek Bridge routes bus ridership and total annual vehicle trips - RFTA accounted for 12% of the vehicle trips and 10% of the person trips at the CCB in 1992. Without the contribution from the ski shuttles, the percentages drop to 9% of vehicles and 7% of person trips – somewhat beyond the high end of actual counts taken in the summer of 1992, and therefore a reasonably good fit for an annual average.
The 2005 numbers, subject to the same assumptions, show a RFTA share of 17% of vehicles and 14% of person trips at the CCB. Minus the ski shuttles, the numbers drop to 13% of vehicles and 11% of person trips.
The 37% of person trips of local lore is off by about 26%, for an overstatement of about 336%. Local residents have been led to believe a wildly exaggerated perception of the value and effectiveness of their current transit system, and its potential to impact traffic congestion problems.
(Return to Link 3)
(Return to Link 4)
Exercise 3: How much effect did the 1995 paid parking program have on 1993 peak hour traffic at the Entrance to Aspen?
Traffic Counts: CDOT - 1993
Bus Ridership: RFTA
“The FEIS states that, during the 1993/1994 summer
and winter peak seasons, the entire section of State Highway 82 within the
study area operated at a Level of Service (LOS) of E or F for much of the
day. For 2005, this condition remains
relatively unchanged; increases in traffic volumes along most of the corridor
are relatively small compared with 1993/1994, largely due to TM measures
(restricted parking in
The spike in ridership for the years
1994 to 1996 is appropriately linked to “restricted parking in
592,948 = CCB route annual ridership increases from 1992
to 1996, less the increase in
592,948 / 365 = 1625 riders per day adjusted by 1.3 riders per equivalent vehicle = 1250 vehicles per day
1250 / 23800 (1993 Annual Average Daily Traffic) = 5%
The maximum impact of parking fees on traffic volumes during the first year of the paid parking program was a reduction of about 5%.
The disclaimer in Exercise 1 regarding the ability to assign an absolute number to vehicle trip reductions, particularly as the direct result of a policy decision regarding parking availability or transit alternatives, is amplified in this example.
Paid parking in
The parking fees also had the perhaps unintended consequence of expanding the perception of a desirable distance from one’s destination to include two or three blocks of the non-paid parking neighborhoods. The higher turnover of spaces in the core, and virtual addition of spaces in the neighborhoods, should have replaced some of the lost vehicle trips into the downtown area made by employees with new trips made by customers.
Working against the hopes of the business community, the Entrance to Aspen DEIS estimated that “Moderate TM” measures like paid parking would result in “trips not taken” in the range of 1% - 2%. It can be presumed that these would not be work related trips, but would be more likely to negatively impact commerce.
Despite the experimental nature of the paid parking program, there is no public record of either CDOT or the City of Aspen taking traffic counts in 1995 or 1996 in an attempt to quantify the result of their experiment. There may have been little agreement on the meaning of those counts if they had been made, but the one outcome regarding availability of spaces in the core was apparently sufficient to win public support to continue the program.
The potential for reduced traffic has only recently been revived as a possible benefit of an expanded paid parking program. Whether reduction in vehicle trips at the entrance is worth the inconvenience and negative commercial impact of more paid parking, the available data is completely unsupportive and more definitive data are not available.
As with the example from Exercise 2, the proportions of the interaction between transit and vehicle trips are the most revealing factor, and the broader the context the more relevant the comparison becomes. Service expansions and the imposition of parking fees in Aspen led to significant growth for RFTA, creating a 39% ridership increase on the CCB routes from 1993 to 1995. Regardless, the most liberal accounting leads to an estimate of a 5% impact on vehicle counts at the Entrance to Aspen.
Similarly, the raw number for total ridership for the entire RFTA system, at 4.5 million for 2007, seems very impressive. However, using the national average for trips per day per person applied to the population of the RFTA service area, the transit share of total person trips falls into a range between 2 and 4 percent.
(Return to Link 4)
Annual Average Daily Traffic (AADT), 1987: 21,700
Winter Average Daily Traffic (WADT), 1987: 24,100
Summer Average Daily Traffic (SADT), 1987: 25,200
AADT, 1993: 23,800
WADT, 1993: 24,800
SADT, 1993: 28,600
AADT, 2005: 23,900
WADT, 2005: 24,900
SADT, 2005: 28,700
1987 Traffic Projections for 2010:
1997 Traffic Projections for 2015:
2007 Traffic Projections for 2030:
Case Study Computations:
RFTA ridership crossing Castle Creek Bridge, 1987: 1,135,642
RFTA ridership crossing Castle Creek Bridge, 1993: 1,777,816
RFTA ridership crossing Castle Creek Bridge, 1995: 2,472,112
RFTA ridership crossing Castle Creek Bridge, 2005: 2,276,529
(Return to Link 12)
(Return to Link 5)
WEST GLENWOOD SPRINGS TO
CORRIDOR INVESTMENT STUDY (CIS)
(Submitted during CIS public comment period – August, 2003)
(Revised and expanded for clarity – not updated – August, 2009)
Basalt, CO 81621
With the Assistance of:
Wendell Cox Consultancy
PO Box 841 Belleville, Illinois 62222 USA
The Roaring Fork Railroad Holding Authority (RFRHA) prepared a comprehensive plan as a condition of purchase of the former Denver and Rio Grande Western rail corridor in the lower Roaring Fork Valley. That obligation was satisfied in 1999; there is no necessity or requirement for the adoption or implementation of the plan described in the Corridor Investment Study (CIS).
The findings presented in the CIS make it clear that Roaring Fork Transportation Authority (RFTA) Resolution No. 2002-05, “Adopting a Long-Term Transit Development Strategy”, was based on an incorrect set of assumptions regarding the appropriate way forward. The intention to revisit those assumptions upon completion of the CIS should now lead to a thorough reevaluation. The CIS should not be adopted by the RFTA board in its current form for future planning under any circumstances.
Failure to provide a remedy for the identified project need and significant omissions of viable alternatives are the primary deficiencies. Existing condition information is inadequate, and frequently no comparable data points are provided to allow assessment of projected outcomes, depriving policy makers and the public of any meaningful context.
A. FAILURE TO SATISFY PROJECT NEED
Even with current Highway 82 investments, traffic congestion on the completed four-lane highway will reach Level of Service (LOS) F between 2009 and 2015, according to RFTA and CDOT studies. (CIS Page S-2)
However, CIS Table I-1 indicates two locations along Highway 82 which are at LOS F (“gridlock”) now, neither of which is projected to improve under either the inaccurately named “No Action/Committed Projects” alternative or any “Build” alternative. In fact, for 2008, Tables IV-14 through IV-29 indicate six locations out of eighteen where LOS quality would deteriorate from existing conditions under “No Action”, and seven with any of the Build options.
Table #1 below uses the traffic count locations from CIS Table S-5 in comparison with similar Section IV LOS Table locations* to show the difference with and without Build alternatives. In each case, whether 2008 or 2025, there would be no LOS difference between the No Action and Build alternatives.
Levels of Service: Highway 82
Traffic Count Point
Highway 82 & 133**
*Section IV Table locations are similar to Table S-5 in only four cases. There are no LOS projections for the Entrance to Aspen, or Main Street, anywhere in the CIS.
**Table I-1 Reports existing conditions at this location as LOS C/D
Furthermore, the CIS analysis of LOS at 19 specific locations, with and without new transit projects, shows no significant difference (Table #2). In a small number of cases (3), the No Action alternative is superior to the Build alternatives. In an even smaller number of cases (1), Build alternatives are superior to the No Action alternative. In no cases are the Build alternatives superior to No Action where LOS is F (or even E).
Derived from Tables IV-14 through IV-29
The lack of responsiveness to the stated problem - current and future congestion - calls into question the underlying strategy, not just particular alternatives.
While these LOS estimates are useful as a general indication of highway conditions, a more comprehensive analysis requires going outside the CIS. For example, to fully understand the nature of the differences between year 2003 existing conditions and 2008 performance estimates for the No Action alternative, transit ridership figures from RFTA are needed.
In 2002, RFTA “Valley Service” reported ridership of 1,567,000. The No Action/Committed Projects CIS alternative is projected to achieve 1,510,000 riders on “Regional Transit Services” in 2008, a number which “includes some select local routes which serve regional as well as local trips along the corridor.” While showing a ridership decline, whether these two numbers are directly comparable cannot be determined from the CIS; one of the major study deficiencies.
B. INVALID BASE CASE
The No Action/Committed Projects category should have been two different alternatives, and an actual No Action base case should have been defined. The two future transit elements under study, “Bus Rapid Transit (BRT-Bus)” and “Bus Rapid Transit connecting to Light Rail Transit (BRT-LRT)” are listed as separate alternatives despite being nearly equivalent. Both transit elements are extended versions of “Committed Projects” which would require major action to implement despite being lumped together with “No Action”. By conflating a “no-action” alternative with major transit expansions which contain elements of the other two “alternatives”, the CIS was structured so that it effectively compared three slight variations of the same bus system to a light rail alternative - which also includes elements of that same bus system.
The true No Action null hypothesis should be to simply maintain the current bus system at a 3.5% inflation multiplier through 2008, for an annual operating budget of $18,000,000. The CIS alludes to such an option on Page VIII-20, where it proposes a very wide funding range for the No Action/Committed Projects: “…if we assume between $2 million and $15 million in average annual additional local funding.”
A low end estimate of $2 million in additional funding could not have been anticipated with Committed Projects in mind. Those projects include a “new regional trunk service described in the RFTA IGA”, which alone will require $15 million in annual operating and maintenance costs (Table VIII-2), as part of a total Committed Projects budget of $25.5 million. It is not credible to propose this range as a single “alternative”, given the substantially different operational characteristics which that amount of funding should provide.
Continuing the same quote from Page VIII-20, in apparent reference to the $15 million end of the proposed range, the CIS goes on to say: “However, it is questionable whether this amount of additional local funding would be committed to bus service if there is not a significant improvement in service or travel times relative to current operations.” This statement would seem to confirm an expectation of flat ridership numbers (discussed in the last paragraph of the preceding section). Only be piecing together these fragments does it become apparent that an additional $15 million in annual expenditures for Committed Projects is not expected to show “significant improvement in service or travel times relative to current operations”.
Although authors of the CIS did not pursue whatever option an additional $2 million per year would buy, a true No Action base case is both viable and realistic, and would serve as a valuable comparative tool to evaluate the Committed Projects, BRT, and Rail alternatives, given that:
1. As noted above, the increased regional trunk service on the Committed side of the No Action/Committed Projects option appears to have little expected effect on ridership, despite the $25.5 million cost.
2. The significant disconnect between ridership and congestion reduction is illustrated by the lack of improvement in LOS conditions despite assumptions of enormous ridership gains with the Build alternatives.
3. Concerns over the willingness of voters to provide additional funding are not allayed by the promise of improved service or travel times. It may be difficult just to secure additional tax increases to provide Committed Projects trunk service, given that much of that service was assumed to be the benefit promised by tax increases included with the creation of the Regional Transportation Authority (RTA).
C. THE MISSING ALTERNATIVE - HIGHWAY IMPROVEMENTS
The region’s growing traffic congestion cannot be solved with just one mode of transportation or by highway expansions alone. (CIS Page S-2)
The CIS provides no evidence that there is any alternative to expanding highway capacity. Quite the contrary, the CIS provides significant evidence of the absolute necessity of increased highway capacity to respond to congestion problems. Most new demand is for personal vehicles, and that demand can only be accommodated by expanding highway capacity (or increasing capacity on existing roadways).
The Build alternatives make only very small differences in traffic volumes. According to projections, LOS F will be achieved in various additional locations by the end of the planning horizon (2025) or sooner (2008), with or without the Build alternatives. Moreover, the information in Tables IV-14 through IV-29 indicates that long segments of Highway 82 will not be at LOS F in 2025 even with the No Action alternative.
Thus, it is clear that the traffic congestion problem is not corridor related, but rather point or segment related. Those segments are the Entrance to Aspen, downtown Glenwood Springs, and the major intersections at Carbondale, El Jebel, and Basalt. Congestion problems along Highway 82 are local rather than corridor, and segment improvements can be used to solve the problem.
The major intersections need to be grade separated, but this work is being delayed due to a shortage of state highway money.
The City of Glenwood Springs
has proposed a highway bypass for downtown, but is having difficulty persuading
the State of
The only solution for
congestion at the Entrance to
The combined cost to upgrade or expand the highway at the congested segments is in the range of $170 - $190 million. The CIS identifies local funding sources for up to $235 million in bond proceeds as a consequence of efforts to establish financial feasibility for rail.
We know from recent experience that local tax sources can be used for highway construction until state funding catches up, at which time local transit coffers can be augmented or restored.
Unlike all other alternatives, highway capacity expansion would show LOS improvements at every congested location. Unlike all other alternatives, travel time improvements would benefit everyone, and by amounts competitive with those claimed only for transit passengers under the Build options.
The highway improvement alternative satisfies the fatal flaw screening analysis except for the prohibition on any solution which costs more than $10 million per mile. There is no rational basis for this criterion. It would be far easier to understand the elimination of alternatives with annual operating costs over $10 million.
It would also be expected that a fatal flaw screening analysis would automatically eliminate alternatives which do not satisfy the project purpose and need. In the absence of that screening standard, the creation of the public perception of a predetermined outcome is nearly inescapable.
Highway improvements are not
subject to obsolescence within the planning horizon. The population share of the 10 zip code areas
served by RFTA is about 61 percent of the populations of Eagle,
The value and necessity of heated transit stations is greatly diminished if the bus system runs on time, an operational attribute which could be realized with highway improvements. There should be no sense of obligation to provide facilities for a rail alternative which may not be built for generations, if ever.
As soon as it was decided to include bus based transit alternatives in the CIS, improvements to the infrastructure on which those buses operate should have become a study alternative. The absence of a fully developed highway improvement alternative is such a fundamental flaw; this omission alone invalidates the entire study process.
D. THE MODEL PROBLEM
The most extensive effort to
model traffic changes in the valley occurred as part of the EIS process for the
From the 1970’s on,
The impact on traffic patterns was easy to see, as traffic growth turned to traffic stability at the Entrance to Aspen. The process of localization of services will continue as new commercial growth occurs in places like Willits Lane and Carbondale. Even the new Snowmass Base Village is predicated on the proposition that it will help keep guests in the village for more of their stay, thereby capturing more of the visitor dollars which are currently escaping to Aspen.
The CIS has this to say about the phenomenon: “The towns of Basalt, Carbondale, Silt, New Castle, and unincorporated areas have now zoned land for both community and regional commercial uses. While additional community-oriented commercial opportunities could relieve some transportation demand as residents shop closer to home or become passer-by trips, additional regional commercial opportunities in other communities are likely to alter transportation patterns. At this time, there is not enough information available to quantitatively predict or assess the effect of those potential changes.”
Increased commercial opportunities also equal increased employment opportunities, which can reduce commuter Vehicle Miles Traveled (VMT) to the same extent as increased development of affordable housing in the Aspen Area. The admitted inability to model what may be the most significant trend in the valley is clearly a deterrent to heavy reliance on conclusions derived from computer modeling.
Another aspect of the model problem relates to the attachment of many local residents to the concept of “Induced Travel”, the belief that highway improvements are self defeating, causing traffic to grow by a greater margin than the increased highway capacity. This belief may be the only explanation for the otherwise inexplicable statement in the CIS that highway expansion alone cannot solve congestion problems.
Although an article of faith for years, recent studies of the induced traffic concept provide such a wide range of estimates, definitions, and variables that at least one jurisdiction gave up efforts to separately account for the impacts. After requesting a meta study (5 Mb file) of the available literature, the Washington Metropolitan Council of Governments determined that none of the examples surveyed in the draft report were sufficiently similar to local conditions to warrant preparation of a final draft. Needless to say, none of the studies focused on rural areas, nor do there appear to be any studies of a highway segment expansion shorter than eight miles in length.
Regardless, the draft study was extremely helpful in establishing a context for the induced traffic discussion. Estimates of induced travel as a percentage of total traffic volume cover a wide range in the surveyed reports, with the most recent estimates falling somewhere between 5 to 11 percent. Whatever the correct proportion, one researcher reports that, “It is concluded that the role of highway capacity expansion in increasing highway travel has been small relative to other factors. Highway capacity expansion interacts with far more important variables such as population, household and employment growth, personal income and auto ownership increases, regional economic growth and fuel price changes as determinants of total travel demand.”
Comment on the feeder bus route system is somewhat difficult from the information provided, but the overall service seems remarkably Aspencentric.
Recent RFTA boarding and alighting surveys indicate significant ridership between intermediate points in the valley, and CDOT traffic projections reflect a bulge in VMT in the area between Basalt and the outskirts of Glenwood Springs. Table IV-3, and the text on the following page (IV-5), makes it appear that many or most trips within the middle two thirds of the valley will require a transfer with a BRT system. Reported travel times (Table IV-4) do not include time spent on feeder buses, but it is total travel time which matters to passengers using that service, not just the corridor portion of their trip.
The communities of Basalt and
All other considerations aside, it is not intuitively clear why Carbondale is slated to receive both a feeder bus and two different bus stations - one of which is easy walking distance in the heart of downtown, while the other is apparently designed to attract drivers.
The proposed trail would be much more expensive with the rail alternative (Page VIII-3), yet the trail does not appear as a line item in total capital costs (Table VIII-1). It appears that the total capital cost of the Rail alternative should be $336.6 million, not $306.6 million as shown.
Regardless, even that higher cost
of Rail may be optimistic. It is quite normal for capital costs of projects to
increase as they proceed further in the planning process. However, the severity of the cost overruns may
be dramatically different depending on the type of project. A study of this phenomenon found that in
The six RFTA jurisdictions
Given the available information, elected officials have no moral, fiduciary, political, or practical obligation to continue to support any further study or capital expenditures for this alternative.
As noted in Table #1, the inevitable implementation of the light rail alternative at the Entrance to Aspen became an assumption incorporated into the West Glenwood Springs to Aspen Corridor Investment Study, and that assumption is therefore inseparable from the federal funding request arising from this process.
The CIS further assumes that a
Bus Rapid Transit (BRT) system will precede the construction of a light rail
line along the full 42 mile length of the project corridor. Much of the funding is therefore intended to
provide infrastructure improvements which will subsequently serve the LRT. This eventuality apparently explains the
otherwise peculiar locations of the
In support of spending $128 million for an expansion of a BRT/LRT mass transit system along a rural corridor, the CIS claims that the travel time improvement in the BRT system, approximately 11 minutes, will result in ridership increases of about 175 percent. The ridership projection is so completely beyond the range of possibility; it was first necessary to confirm its authenticity. In an email (July 30, 2003) from Roger Millar, Principal with Otak Inc., the primary consultant on the CIS, it was confirmed that they stood by their estimate.
The huge ridership increase is projected for the single largest fare generating route in the entire bus system. So, while an influx of federal funds is typically considered a windfall, in this instance the dramatically increased operating costs of this expanded system ($12 million annually – 2003 dollars) will be a significant burden to local taxpayers, especially in the absence of projected increased fare income.
It seems obvious that highway segment improvements could provide bus travel times competitive with, or superior to, the program proposed in the current CIS. However, highway improvements provide the additional benefit of improving the travel times of the entire public, not just transit users.
Cost estimates for the various highway segments which would establish the basis for a fully developed Highway Improvements alternative are already available, and could be refined as necessary with little additional work.
The Regional Transportation Authority statute, under which the Roaring Fork Transportation Authority was formed, specifically names highway improvements as an allowed application of tax proceeds which may be collected by the Authority.
The simple availability of a secure funding source may be all that is necessary to move forward with the repair of the Entrance to Aspen EIS, and to initiate an EIS for the Glenwood Springs Bypass.
A ballot proposal to fund the Highway Improvements alternative, with appropriate caveats regarding final design approvals within specific jurisdictions, should be prepared after a revision of the CIS has been completed. As called for in the CIS, voters should have an opportunity to make a fully informed choice as early as November, 2004.
The RFTA board should adopt no plans, and pursue no funding commitments, until and unless a specific alternative is approved by the electorate of the entire RFTA district.
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Roaring Fork Valley Bus Rapid Transit Project
Citizen Comment to the Federal Transit Administration
Despite its current expansion to a regional scope, the Bus Rapid Transit (BRT) project for the Roaring Fork Valley is fundamentally the mass transit component of the State Highway 82 Entrance to Aspen Record of Decision (ROD), dated August 1998  .
In response to the request of the City of Aspen to forego construction of additional highway lanes, the Federal Highway Administration (FHWA) and State of Colorado agreed to substitute a mass transit element, originally proposed to be light rail, to satisfy the need for increased transportation capacity. In the absence of community support or sufficient funding for light rail, the transit element could also be satisfied with “exclusive bus lanes”, and it is these lanes which are referenced in the Section 5309 Very Small Starts (VSS) funding application now under review by the Federal Transit Administration (FTA). A short section of these exclusive lanes has not been completed due to a lack of community support, resulting in an extraordinary level of congestion for both general traffic and mass transit services.
The Entrance to Aspen plan may be the only example of a federally approved highway design where inadequate lane capacity is purposely preserved so that the resulting congestion will influence travel choices. Any presumption that congestion reduction is a criterion for federal transit funding assistance is particularly forsaken in this context, as there is no intention or expectation that any level of transit service will substantially impact congested conditions, even assuming eventual completion of the remaining section of exclusive bus lanes.
Accommodating the transit based preference of City of Aspen officials required an initial step which may be unique in the history of the Environmental Impact Statement (EIS) process. The Entrance to Aspen EIS was extracted from the larger East of Basalt to Aspen EIS document just prior to its completion, in order to separately address this short segment of the Highway 82 corridor. The project reviewed in the original EIS process has since been successfully completed, and incorporates the HOV lanes referenced in the current application.
Consequently, from its inception, the Entrance to Aspen EIS was tailored to reach a predetermined conclusion. The ROD, a Corridor Investment Study (CIS) completed five years later, and the Reevaluation of the ROD completed in April 2007, all contain inflated traffic projections and/or transit ridership projections developed in part to validate the presumption that transportation demand will require a level of transit service which can only be accommodated with exclusive, dedicated lanes.
A separate report titled Failure of NEPA Process Oversight, Colorado State Highway 82 East of Basalt to Aspen EIS, A Case Study, details the extent of the manipulation of the information contained in the ROD and CIS documents cited by the Roaring Fork Transit Authority (RFTA) in the VSS application. Further problems discussed in the report extend to scoping and comparative failures in the CIS. RFTA’s assertion in the BRT Project Management Plan (August 28, 2008) that “The CIS did not incorporate an official environmental clearance document (EIS or EA) and represented an Alternatives Analysis” should not be accepted by the FTA without significant review.
The FHWA responded to the problems identified in the Entrance to Aspen Final EIS and ROD with assurances that they would be addressed in any subsequent reevaluation, but the Colorado state officials who produced that reevaluation refused to do so. There has never been any procedural step which could be used to cure problems with the CIS - it remains as a wholly unacceptable substitute for an Alternatives Analysis suitable for an FTA grant request.
Citizen Review of the RFTA Bus Rapid Transit VSS Funding Application
1. Unavailable and Erroneous Data
Numerous efforts were made during the public discussion of the recent RFTA funding referendum to obtain current basic bus operational information in order to assess the potential merits and benefits of the BRT proposal. In some cases the requested information mirrors the FTA questions directed at RFTA’s first “Make the Case Document”, while other more general statistical information does not appear to have been requested by the FTA. The absence of key data needed to make reality checks against national benchmarks (i.e. future per capita ridership and expenditure figures); or to assess before and after costs per revenue miles and revenue hours, before and after occupancy estimates, etc. has left the public and overseers without any basis on which to develop a level of confidence in the BRT plan. Effort to obtain or generate this additional information is either entirely unsuccessful, or reveals major deficiencies in RFTA data collection and analysis, or leads back to the discredited studies referenced above.
2. Designing to the Grant
The decision by RFTA to package a scaled down BRT Phase I version of the project in order to qualify for VSS funding appears to have been prompted by less stringent documentation requirements rather than by an appropriate fit between the project and the grant program.
The full BRT project is far too large for the VSS program intent, so the phasing of this BRT system directly violates the FTA prohibition on subdividing projects to satisfy program cost parameters.
Specifics of the BRT operational plan are more suited to the requirements of the grant program than the transportation needs of the Roaring Fork Valley.
Concerns Specific to the Make the Case Document
Note: Items selected for comment in this section follow the heading titles and chronology of the “FTA Comments on Initial RFTA Make the Case Document”, and retain the numbering sequence from that review. RFTA quotes are taken from their revised submission.
Current Conditions in the Corridor
8. A few references are made to increases in supply that would result from the project, e.g. 17 bus trips per morning peak hour to 28 bus trips per morning peak hour, but no explicit mention of how demand meets this supply is provided.
RFTA conducted the West Glenwood Springs to Aspen Corridor Investment Study (CIS) (completed in 2003) to assess future transit demand and evaluate options for increasing transit service levels and capacity. The CIS projected 1,510,000 annual transit boardings on RFTA’s valley services in 2008 assuming no major investment in transit in the corridor. RFTA estimates that actual 2008 boardings will exceed 2,000,000. The CIS recommended that BRT be implemented in the corridor, and it forecast that RFTA valley ridership would increase to 4,780,000 boardings in 2008 and 8,740,000 boardings in 2025 if BRT was implemented. Based on the findings of the CIS, the implementation of BRT would have the potential to increase transit ridership to double current levels in the short-term and to four times current ridership by 2025. The transit service plan assumed for 2013 and beyond in the BRT plan accommodates as much of this potential demand as possible within the limits of available and anticipated funding.
There is nothing in the RFTA response which is directly applicable to the BRT plan as illustrated in Fig. 1 of The Case for the Roaring Fork Valley BRT Project.
Application of the cited figures for any purpose is frustrated by the obliqueness of the CIS. Both the CIS and current RFTA documents use the terms “Valley” route, “Regional” route and “Corridor” route with no clear differentiation, and neither source maintains comparative consistency in regard to the CIS distinction between boardings and trips: “A trip using transit could have more than one boarding if a transfer is required between transit routes to complete the trip.”
For example, the “1,510,000 annual transit boardings”, cited by RFTA as the CIS projection for the “no major investment”, “valley services” category for 2008 is the same statistic described as the “no action” “Regional Transit Services” in Table IV-9 of the CIS. On the previous page of the CIS, Table IV-8 credits the same regional service category with 9,300 “daily boardings”. This number is far too high to represent the average ridership on a weekday, which is the usual definition of “daily boardings”. There is no further explanation of the potential two million boardings difference (365 days x 9,300) between the daily and annual projections, i.e. there is no indication in the text that the daily boardings number might represent an estimate for a weekday high season peak.
Of greater concern than the arithmetical inconsistency, both tables state that the figures "include some select local routes that serve regional as well as local trips along the corridor". In short, the actual ridership projection for the specific route slated for BRT expanded service is not provided as a clear and separate statistic anywhere in the CIS.
In a step by step process of Q&A with CIS Project Manager Roger Millar in July of 2003, it was determined which ridership projection for BRT for 2008, stripped of “select local routes”, could be used as the equivalent figure for comparison to the actual passenger trip counts reported by RFTA in their 2002 “Highway 82 Corridor” statistic.
In 2002, actual ridership on the Highway 82 Corridor was reported by RFTA as 1,253,229 annual passenger trips. The CIS estimate (per CIS Project Manager Millar) for the same route in 2008 with BRT was 3.46 million annual boardings, for an additional 2.2 million trips/boardings per year within six years. This 176 percent increase, for an additional 6,046 daily trips (or boardings?) on this single route, was projected for a service area with a population in the upper range of 75,000 people.
As a point of reference, in the 24 year period between 1983 and 2007, the era which includes the first time introduction of bus service for most of the highway corridor, a growth in annual ridership of 1.52 million trips was developed by the existing system. The proposed BRT project would be an incremental improvement to a mature system in a highly served area, so whatever factor is needed to rectify the difference between boardings and trips cannot credibly repair a projection for a 2.2 million trips/boardings ridership increase in the span of six years.
In contrast with the CIS citation, RFTA has developed new ridership figures as part of the current BRT planning process. The new estimate has not been made widely available, over a stated concern that the “travel demand model is not calibrating accurately,” and does not appear to have been used in the FTA grant request. However, the calibration problem has been described as relating to "trip distribution" problems in which the model "was over-estimating travel to Aspen and underestimating travel to mid-Valley areas like Basalt and Carbondale", so the new estimate should be reasonably useful for an analysis of total trips. Similar to the CIS figures from 2003, the latest ridership projection also has the problem of being a composite number, combining the relevant Highway 82 corridor ridership with a non-BRT route between Snowmass Village and Aspen.
Use of RFTA’s latest growth assumption applied to the appropriate Highway 82 corridor route yields an estimate for a BRT related ridership increase from 1.63 million actual annual trips for 2007 to about 2.46 million estimated trips ten years later, an expected increase of 829,000 trips per year by 2017. The contrast between this estimate and the prior CIS projection of a 2.2 million boardings increase during the six years leading up to 2008 is an especially striking downward adjustment considering the higher population expected by 2017.
The new RFTA projection might be interpreted as a more realistic expectation for this transit saturated market. However, in order to dispel any perception that the current estimate represents a significant reduction from prior projections, RFTA has explained that, “Due to funding limitations, RFTA is not able to increase service as quickly as demand is likely to increase.” The need to retract an overestimation has thus been averted by a claim of too little money, not too few riders, to maintain past projections.
2. Please address whether increases in transit capacity can be accomplished with increases in local or express bus service, as well as BRT.
The purpose of the BRT project is to make transit service more competitive with private automobiles by improving transit travel times and enhancing travel time reliability. This would increase transit ridership among commuters making trips of 15 miles or more along SH 82, thereby reducing the rate of increase in vehicular travel in the corridor. The project also is intended to attract new riders by making RFTA’s services easier to understand and more attractive through branding of the service and provision of real time bus arrival information and other amenities at BRT stations. The primary market for BRT services is commuters making long trips from affordable housing to employment sites largely in Pitkin County, but also to destinations such as Carbondale, Basalt and Glenwood Springs. By improving the access to affordable housing for workers in areas with high living costs, the project will support continued economic growth in the Roaring Fork Valley. The branding of the BRT service and the provision of real time transit information would make the service more attractive and easier to use for occasional users as well as commuters.
Before inquiring as to alternate means to supply additional capacity, the FTA should first delve more deeply into the question of whether there is any demonstrated need for that capacity.
The first version of the Make the Case Document to which these FTA comments apply, and to a less obvious extent the updated revision, is focused on peak period ridership demand. Peak periods represent less than ten percent of RFTA’s annual service hours, and outside the context of peak periods, there is no data to suggest a need for increased transit capacity.
RFTA has never developed average occupancy figures for the Highway 82 corridor route. Estimates based on RFTA provided figures for average riders per trip and average trip length, and a small-sample Boarding and Alighting (B&A) survey conducted privately, indicate an average occupancy in the low to mid thirty percent range. With only one third of seats filled on average, the latest 50 percent ridership increase estimate for 2017 is easily absorbed with existing capacity. The supposition that this full ridership increase is only possible with the increased frequency and improved travel times of BRT may be true, but the inefficiency of doubling service for the sake of achieving an incremental improvement over the background ridership growth rate is extreme.
The most recent projected ridership increases are well within the capacity of existing services, perhaps moving average occupancy up to the 50 percent level. Notwithstanding the potential need for additional peak period service, RFTA’s intention to increase frequency throughout the service day to 15 minute headways has no apparent impetus other than the need to satisfy this particular requirement of the VSS grant program.
Merits of the Proposed Project
2. Regarding the statement: “… local bus riders would enjoy peak period travel time savings of 13 minutes with the implementation of the project.” With the availability of express bus service, would anyone actually ride the local bus from Glenwood Springs to Rubey Park?
Some current local bus riders would use local buses to travel to BRT stations and transfer to BRT services. Others, especially those making shorter trips, could elect to remain on the local bus even though traveling via BRT would be faster.
Concern over whether there would be enough riders left after implementation of BRT to warrant the continued operation of the local bus as a duplicate service along the entire corridor was the original motivation for conducting the aforementioned private B&A survey. Four full length transits of the Highway 82 Corridor bus route were monitored in August, 2007, and the pick-up and drop-off points for each individual rider were recorded. RFTA has conducted B&A surveys over a full day, but those lacked the specificity needed to determine travel frequency to and from non-BRT stops.
BRT is proposed to originate from the south side of the town of Glenwood Springs. Glenwood has a city shuttle system which will serve as a feeder system to the BRT stop, and the existing valley local bus will continue to serve some unique Glenwood stops not part of this Glenwood city route. However, expanding the city shuttle route could be a more practical alternative, as there may be little reason for the valley local to proceed beyond the south Glenwood BRT stop. In the sample B&A survey, of the 17 passengers picked up at valley local stops within Glenwood Springs, 5 riders might someday prefer continuing onward on the local bus for the sole advantage of being able to disembark at one of the two non-BRT stops within the town of Carbondale. No other riders from this group of 17 were going to a non-BRT stop anywhere along the corridor.
Of the 38 bus stops between the BRT station in south Glenwood Springs and downtown Aspen, 12 will be served by BRT, and 10 are within a few blocks to a mile of a BRT stop. The 16 other local stops accounted for just 7 percent of the total 358 boarding and alighting movements made by passengers in the sample B&A survey.
Taking into account all of the non-BRT stops, including those in the town of Glenwood Springs and those within walking distance of BRT, the percentage of boarding and alighting movements made at those stops climbed to 32 percent. However, half of the trips made by these passengers exceeded the 15 mile trip length RFTA has targeted for improved travel time, so they would presumably transfer to BRT at the first opportunity. The remaining half posted an average trip length of 7.3 miles on a 48 mile route. The valley local bus service left in the wake of BRT has the potential to be extraordinarily inefficient, with an average occupancy well under 20 percent.
Certainly the samples on which these observations are made are not a sufficient basis for a thorough analysis of a multi-million dollar transit expansion proposal, but RFTA’s inability to provide more complete information is even less a basis for fundingBRT.
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Guidelines for Small Starts and Very Small Starts grants reveal a primary qualification that “The additional operating and maintenance costs of the project are less than 5% of the agency’s operating budget,” but BRT Phase I will increase RFTA’s operating and maintenance costs by 50 percent, and those expenses will double with the full BRT plan.
Project guidelines also state that, “All phases of a proposed project in a single corridor must meet the eligibility criteria for a Very Small Start when evaluated as a single project.” A phasing strategy is expressly prohibited by the FTA when the total capital costs of all phases exceed the limitation set for a single VSS project. Total capital costs for the full BRT plan have been estimated by RFTA at $180 - $190 million, far exceeding the $50 million cap for VSS projects.
Based on the above factors, RFTA BRT should not be eligible for consideration as either a Small Starts or a VSS project by the FTA, and it is likely that any federal assistance may be appropriate only as part of a consolidated State application under a Section 5309 Bus and Bus Facilities Discretionary Program Grant. Whatever accommodation is being made to circumvent these basic incompatibilities between project and program, the effort to do so is completely inappropriate in the face of far greater problems.
The BRT project is founded on a serious abuse of the Environmental Impact Statement process, compounded by three subsequent iterations (including the subject grant request) of unreliable and unsubstantiated ridership projections. RFTA has promoted a multi-hundred million dollar expansion proposal using anecdotal peak period overcrowding reports, but without describing or quantifying current overall occupancy patterns or explaining the future ridership characteristics of the existing service as it becomes largely redundant. Although there are numerous problems with the RFTA VSS grant request, the absence of rudimentary operational data should itself be fatal to any federal participation.
Recent tax increases have provided RFTA with the means to respond to peak period service demands in the near term, and to acquire an automated ticketing system with the capability to remedy the information deficit. It would be a public disservice to provide any further funding at any jurisdictional level until a need for additional service has been established based on verifiable facts.
Submitted 12/04/2008 by Jeffrey Evans, Box 324, Basalt, CO 81621
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Glenwood Springs to Aspen, Colorado
Citizen Comment to the Federal Transit Administration (FTA)
October 14, 2010
An Environmental Assessment (EA) is a less rigorous process than a full Environmental Impact Statement (EIS), and is used in situations where it is expected that there are no significant impacts to the environment. In some cases an EA may lead to a recommendation for a complete EIS, but this Bus Rapid Transit (BRT) proposal is not sufficiently complex to require an expanded review.
The Roaring Fork Transportation Authority (RFTA) Board of Directors Agenda for September 9, 2010, reported the following:
1. RFTA is on the verge of submitting all of the required plans and documents necessary for it to receive a $25.973 million grant from the FTA.
2. FTA recently authorized RFTA to publish the Environmental Assessment for the project and after a 30-day comment period staff anticipates that FTA will issue a Finding of No Significant Impact (FONSI). Once the FONSI has been issued, RFTA can begin acquiring right-of-way for the project and incurring other project costs.
3. RFTA's project funding is currently included in both the House and Senate version of the FY 2011 Transportation, Housing and Urban Development appropriation bill.
4. Therefore, it is anticipated that FTA will award RFTA's $24.973 million grant in December or early in 2011.
This Environmental Assessment is therefore presumed to be the final step in the release of nearly $25 million in federal funding for a BRT project which should never have been proposed, and for which there is absolutely no demonstrated need.
Many of the assumptions in the Environmental Assessment depend on the reliability of information contained in the following documents:
State Highway 82 East of Basalt to Buttermilk Ski Area EIS (1993)
State Highway 82 Entrance to Aspen EIS (1998)
West Glenwood Springs to Aspen Corridor Investment Study (CIS) (2003)
State Highway 82 Entrance to Aspen Re‐evaluation (2007)
This citizen comment references expanded discussions contained in more comprehensive reports available above, and provides links to specific sections of “Failure of NEPA Process Oversight – A Case History”. Table of Contents
Use your "Back" button to return to this report.
Purpose and Need
The 1993 State Highway 82 EIS was an outgrowth of the East of Basalt to Aspen Draft EIS (DEIS) begun in 1987. Based on studies conducted in 1986, the DEIS reported that “2010 traffic on State Highway 82 is forecasted to increase between 52 and 58 percent from 1987 volumes.” A segment of the highway at Castle Creek Bridge at the entrance to Aspen was shown to have an Annual Average Daily Traffic (AADT) count of 21,700 vehicles, which was predicted to grow to 33,900 by 2010. In comparison to reality, the Colorado Department of Transportation (CDOT) reports that the AADT for 2009 at Castle Creek Bridge was 21,400 vehicles, not 33,000 as predicted in 1987.
If the lower traffic volumes were maintained as a result of the huge increase in bus service developed during the intervening years, buses crossing the bridge would needed to have carried an additional 6.8 million passengers in 2009. The actual number of additional bus passengers at this location was closer to 1.5 million, so clearly, traffic projections from the earlier planning document were wrong by a very wide margin.
The current EA states in Section 1.2 “Purpose and Need” that “CDOT estimates that overall traffic volumes on SH 82 are expected to increase by 53 percent between the present and 2030 if no further transit investments are made.” Though not specific to a short stretch of highway at the Entrance to Aspen, this projection, probably taken from the 2007 Re-evaluation, is far less credible than the 1987 traffic estimate for 2010. It is a consistent condition of the studies cited by the EA that prior estimates and projections are never acknowledged to contain errors and corrected, but rather the same or similar projections are carried forward to some new target year – in this case moving the erroneous 1987 prediction for 2010 out into the year 2030.
Similar problems exist in regard to transit usage projections, but it is sufficient to note that the full route which will be subject to the BRT expanded service was inaugurated in 1993, and grew to an annual ridership of about 1.3 million by 1996. Over the following 13 year period up to 2009, through spikes caused by higher gasoline prices and slumps related to bad economic conditions, ridership levels on the proposed BRT route have averaged about 12 percent higher than they were in 1996. BRT will more than double the available bus service.
Suggestions that ridership growth has been stunted by limited bus capacity would require consideration of average occupancy figures to determine the number of available seats, a statistic which is apparently not required under the minimal documentation needed for this “Very Small Starts” FTA grant request, but which has been independently estimated as somewhere in the mid-30 percent range. For the foreseeable future increased transit demand, assuming any exists on the project corridor, can easily be absorbed with the 60 to 70 percent of seats which are still empty.
The EA commits a blatant falsehood in its description of the West Glenwood Springs to Aspen CIS/DEIS, 2003, stating that “The Corridor Investment Study (CIS) was a comprehensive evaluation of transportation options for the SH 82 corridor.” (Section 1.4.3 Related Studies) The CIS was no such thing because it contained no evaluation of highway improvement options. The CIS was a biased document designed solely to provide a rationale for the massive expansion of transit service in the Roaring Fork Valley. It is not suitable for use by any federal agency for any purpose.
The CIS and EA share a similar characteristic in that both documents include a discussion of traffic congestion as the basis for the project purpose and need, both propose a project which will have no impact on congestion, and neither include any claim that the project will, or is intended to have, any impact on congestion.(1) The implication and impression that BRT is somehow related to the “project need” to reduce congestion is ever-present, but the actual link is never made, as though the study authors were trying to insulate themselves from accusations of fraud.(2)
The inadequacy of the CIS as a comprehensive evaluation which investigated all options, and the shift of purpose from solving traffic congestion to expanding transit service as an end in itself, is perfectly illustrated in two sentences from the same section (1.4.3 Related Studies) of the EA:
“The CIS was completed after five years of study and concluded that BRT along the SH 82 corridor could meet the region’s future transit needs at a substantially lower cost with greater cost effectiveness than a rail system over the next 20 years.” (Emphasis added.)
“Based on the results of the CIS, the RFTA Board of Directors…agreed in 2003 that a BRT system as a preferred alternative would meet the increasing demand for convenient and reliable transit service in light of growth and traffic congestion in the SH 82 corridor.” (Emphasis added.)
It is not sufficient to say that the evidence does not support the “Purpose and Need” for the BRT system, especially once reduction in traffic congestion is eliminated as a potential benefit. On the contrary, all of the available evidence, whether demographic or operational, or whether developed by public or private entities, confirms that there is absolutely NO NEED FOR THE BRT SYSTEM as a transit element. However, neither is it sufficient to merely note that the need for the system does not exist. All the available evidence also makes it absolutely clear that at no time in the near or distant future will the system be able to achieve the doubling (or more) of ridership necessary to match the efficiency and affordability of the existing standard bus service, and that the implementation of BRT will therefore have a MASSIVE NEGATIVE IMPACT on that efficiency and affordability.
Grant Application and Financial Considerations
The “Very Small Starts” FTA grant program contains some very specific criteria for qualification; a dollar limit for the project ($50,000,000) which includes a prohibition against breaking a project into phases in order to remain under that limit, and a proportional standard that “The additional operating and maintenance costs of the project are less than 5% of the agency’s operating budget”. The Roaring Fork Valley BRT violates both standards, though previous indifference to that fact has been replaced by obfuscation.
The EA claims the downsizing of the original BRT proposal to $50 million was not for the purpose of fitting under the Very Small Starts limit, but because “it became clear during the project development process that available revenues and local community concerns required the Preferred BRT Alternative to be scaled back.”
One of the single largest expenditure categories under the original BRT plan (total project estimated at $180 - $190 million in capital costs) was the land acquisition and construction of park-and-ride lots to serve persons arriving at BRT stops by private vehicle. Elimination of these facilities also removed a point of community concern for citizens who did not want massive parking lots on prime property. However, the financial implication is dire, because the BRT plan assumes increased fare income from increased ridership to help offset the operation and maintenance (O&M) costs of the new system. By their own original assumption, RFTA cannot achieve their hugely optimistic ridership projections without the park-and-ride facilities.
Previous O&M cost estimates indicated that BRT would increase this budget item by 50 percent, but the EA has now reduced that to 12.5 percent, or an actual dollar amount of $2.5 million beginning in 2013. As context, in 2010 the base O&M expenses (without taking into account such costs as depreciation or facilities) reported by RFTA was $21.5 million for the entire system.
The existing Highway 82 corridor bus service, which BRT will operate alongside and in addition to, currently accounts for about 64 percent of the total miles driven for the entire bus system. So, $21.5 million x 64 percent = $13.8 million as the share of O&M which can be assigned to the highway corridor bus service. This estimate is somewhat high because the Highway 82 route is cheaper by mile to operate than the city bus routes, but not by any margin sufficient to explain how the BRT, which will generate more miles driven than the existing corridor service, can be funded with $2.5 million, or 12.5 percent of the O&M budget.
In contrast, the CIS reported in 2003 that “O&M costs for this alternative [BRT-bus originating from West Glenwood, not South Glenwood as called for in the current plan] are projected to increase from the baseline of $13.0 million during 2002 to $20.9 million in 2008 (without debt service) in constant 2002 dollar amounts.” The gap between the additional $8 million for BRT in 2002 dollars in the CIS and the $2.5 million in 2013 dollars in the EA might be explained by the specific wording: “The estimated incremental system‐wide cost to operate and maintain the proposed BRT service on opening day in 2013 is approximately $2.5 million dollars,” (Emphasis added.) If a partial year or limited inaugural service is being used for the O&M estimate, the effect is nothing less than deceitful regarding grant qualification requirements and the public’s right to complete information. However, no other explanation is readily available. Perhaps it was a typo.
The EA should not be accepted and finalized prior to preparation of an alternate plan to finance full year operating and maintenance costs of BRT in the event of unmet ridership estimates and dwindling sales tax collections. Area taxpayers are facing the prospect of a substantial need for increased taxation to support a worst case scenario, and they deserve to be told how much more RFTA will require, and at what tax rate.
In November of 2002, a group of Federal Highway Administration (FHWA) and CDOT officials were informed of significant errors of data and assumption in the State Highway 82 Entrance to Aspen EIS.
In July of 2005, the FHWA “agreed to consider your [this author’s] concerns in the context of a re-evaluation…at such time as CDOT is prepared to move forward with the State Highway 82 Entrance to Aspen Project."
In 2006, the CDOT program manager in charge of the State Highway 82 Entrance to Aspen Re‐evaluation refused to acknowledge or rectify the prior errors in the Entrance to Aspen EIS, despite that being a major purpose of the reevaluation process.
In October of 2006, an extensive protest of the manner in which the reevaluation was being conducted was filed with the FHWA Colorado Division Administrator. No response or acknowledgement of receipt was ever provided.
The extreme delay between the notification of serious factual problems in 2002, and the assurance of action in 2005, had led to a complaint being filed with the Government Accountability Office (GAO) FraudNET service in May of 2003, who forwarded my complaint to the Department of Transportation, Office of Inspector General (DOT/OIG). A letter from the DOT/OIG in November of 2006 informed me that “generally, we are not in the position to review for accuracy the EIS and ROD of a specific transportation project.”(3)
The inadequacy of the Inspector General’s response led to a return to the GAO, where I was directed to the Integrity Committee, which oversees the operation of Inspector Generals. Both the GAO FraudNET officer and the Integrity Committee have referred my complaints back to the DOT/OIG.
March, 2009: FTA is notified that the Roaring Fork Valley BRT project violates the standards established for a Very Small Starts federal grant.
May, 2009: FTA cites the regulations being violated as the authority for acceptance of the project into the grant program.
October, 2010: We await the election of a new Congress, to see if they will have an interest in repairing the complete collapse of federal oversight of transportation funding.
No one knowledgeable in transportation issues who has worked on any of the planning documents discussed in this comment, or anyone charged with the oversight of their preparation, could possibly be unaware of the extraordinary waste this project represents, or the almost certain financial debacle which will follow its implementation. Looking through the seemingly professional tables and illustrations, and reading through the list of preparers, it is striking that such clearly competent individuals could so easily commit sins against the taxpayers of their own country, the individuals who reside in the Roaring Fork Valley, and the profession which presumably provides them with a comfortable living.
It is a sin of opportunity that could only be avoided if everyone involved had the confidence to believe they could just as easily prosper by doing the right thing, by stopping this and similar misguided efforts early in the process - in spite of their immediate self interest.
The opportunity to sin has been provided by a profound structural inadequacy of the federal process of review. The National Environmental Policy Act (NEPA) was enacted in 1969, and established a review process to allow decision makers, including the public, to assess the environmental impacts of proposed federal actions and projects. The Council on Environmental Quality (CEQ) was established to administer and make rules for the process. The Environmental Impact Statement has become the most publicly visible result of the NEPA, and most people now perceive the EIS as the authoritative basis on which planning and funding decisions are made.
However, because of the design of its original scope and intent, NEPA is woefully inappropriate and inadequate as an arbiter of rational application of federal funding, and cannot be relied upon to perform any of the functions the public imagines is being provided regarding the determination of a "best" choice or the most affordable option.
The reason for this mismatch between performance and expectation is easily explained by looking through the CEQ guidelines, which contain not a word about cost effectiveness, operational efficiency, or financial prudence, but explain that “The NEPA process is intended to help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore, and enhance the environment.”
“The regulations that follow implement section 102(2). Their purpose is to tell federal agencies what they must do to comply with the procedures and achieve the goals of the Act.” And so, the extent of the responsibility of federal agencies is to ensure that the procedures of the Act are followed in regard to identifying environmental impacts. In all likelihood every EIS contains every component required, diligently cataloged and accounted for, and unless there is an omission of something as tangible as a species of frog, there is little basis on which to challenge the actual content.
There are certainly federal laws regarding the use of false or misleading information to obtain a government contract. But when government relies on a process in which its own employees and consultants are charged only with achieving the “goals of the Act”, and uses that process for the purpose of securing government funding for a government project, who is assigned ultimate accountability?
Answer: It is not assigned at all.
The perfect example of this self-fulfilling government created feedback loop is the fact that these comments are being submitted to the two agencies that prepared the BRT EA – the Roaring Fork Transit Authority and the Federal Transit Administration.
It is probably too late for the people of the Roaring Fork Valley - they are about to be saddled with a transportation albatross of major consequence.
The value of this EA is the same as the value of all the manipulated documents that have gone before - they were prepared for a very small project that over a period of time has acquired an exceptional amount of historical data. That circumstance has created a textbook example of the extraordinary shortcomings in the evaluation and approval process for the funding of federal projects, and clearly illustrates the need for an extensive overhaul of the system.
Basalt, CO 81621
The aforementioned significant errors of data and assumption in the State Highway 82 Entrance to Aspen EIS, which were brought to the attention of state and federal officials in 2002, have resurfaced in a new form in the Environmental Assessment for the BRT. The prior EIS had developed artificially low highway traffic projections for a two lane highway in conjunction with a light rail system, and then proposed that the air quality “budget” for particulates would be based on that amount of traffic. The idea was to make it appear that only the preferred alternative for light rail could legally be built, as every other option would violate air quality conformity standards.
No such thing occurred. The air quality budget was based on levels necessary for human health, which turned out not to exclude any of the options, including expanding the highway to four lanes.
According to the EA:
3.9 Air Quality
No‐Action Alternative – If the proposed BRT service is not implemented, air quality conditions would degrade as population in the area increases, contributing to increased traffic volumes and thus, increases in particulate matter. The No‐Action Alternative would not support Aspen’s PM10 Maintenance Plan, which includes implementing transit measures to maintain the PM10 NAAQS as a contingency, should the area revert to nonattainment.
BRT Preferred Alternative – The BRT Preferred Alternative is expected to benefit air quality in the region overall and would support Aspen’s PM10 maintenance plan by contributing to the reduction of individual private vehicles traveling on SH 82, thereby reducing the level of PM10 in the air. Although the addition of new buses operating in the BRT system would increase PM10, the number of private vehicles that are expected to be removed from the highway would more than offset PM10 contributions from the BRT service. If diesel buses are used, anti‐idling policies may be implemented at transit stations where diesel vehicles may congregate for extended periods of time.
The particulate problem in Aspen was solved by changes in the winter street sanding program before a single bus was ever added to the fleet. If RFTA disappeared tomorrow and not a single bus was running, Aspen would not be in violation of air standards, so small is the aggravation of particulate problems by traffic running on clean streets. As alluded, particulate levels would more likely drop as the result of the elimination of the diesel buses.
None of the proposed benefits of BRT or the supposed misfortunes of its absence would be measurable in terms of particulates. This entire fabrication is preposterous.
(1) An apparent slip occurs in Table ES‐1: Summary of Potential Impacts and Mitigation Measures, which states as a potential benefit of BRT that “Reduction in traffic and congestion levels will allow emergency services to more quickly respond to emergency situations.” However, since the CIS did report one location on the 42 mile length of Highway 82 where congestion would be improved by BRT over the “No Action” alternative, it may be that emergency vehicles will be able to respond more quickly at that one location near the Buttermilk Ski Area.
(2) A notable exception is discussed below in the Addendum.
(3) On the contrary, a recent article in an online magazine for the same office reported that “During the past 5 years, special agents from the U.S. Department of Transportation's (USDOT) Office of Inspector General (OIG) have spent approximately 40 percent of their time investigating allegations related to contract and grant fraud involving highway, transit, and airport infrastructure projects and activities.” Efforts are continuing to challenge the credibility of the claim that the OIG is “generally” unable to “review for accuracy” documents related to a specific transportation project, given that grant fraud cannot possibly be investigated any other way.
In 2008, did RFTA need voter approval of additional sales tax collections just to maintain current operations, regardless of whether federal funding launches an expansion plan that will eventually result in a full BRT system?
The likelihood that additional tax revenue is needed to simply keep running in place, with no new service expansion, is illustrated by actual trends:
Between 1997 and
2007, RFTA operating expenses increased by 130%.
Population in the RFTA service area grew by 38%.
RFTA Ridership grew by 21%
Total Mileage increased by 7%
During the campaign to secure voter approval for the BRT system, consultants prepared graphs for public presentation, one of which illustrated a “Baseline” financial forecast indicating that RFTA is solvent through 2019, reaching a spending level that year of about $40 million.
However, a “Likely Trends” graph line, apparently intended to predict what RFTA will need to do to keep pace with increasing ridership demand in the absence of a BRT system, showed a deficit beginning the following year (2009), and growing to $6 million per year by 2025.
A Likely Trends scenario developed in May of 2008 assumed a fleet expansion of 10 vehicles (buses?) - scaled down from an estimate of 22 a month earlier! This sudden downward adjustment did not lend much credibility to whatever ridership projections were being used to estimate service demand in 2025.
Further contributing to the sense that the definition of Likely Trends was highly flexible were those items on the budget that went up in price even after the number of buses went down. The line item “ITS/Transit Priority”, a key technology feature of the BRT system, appeared on the Likely Trends budget for $12.3 million, as did a maintenance facility expansion at $10.25 million – only $0.5 million less than would be required to accommodate “BRT Phase 1”.
RFTA’s Likely Trends scenario slowly became indistinguishable from BRT Phase 1, a significant evolution from its original function as a number representing the response to projected incremental ridership growth. The conclusion is that BRT is a fait accompli - even if the sales tax increase to support it is more urgently needed just to maintain the current system.
The real “likely trend” is that RFTA will continue to grow beyond its revenue base, evidenced by the fact that if they do successfully secure a federal grant for $21 - $25 million in addition to the higher sales tax revenues just approved, it is projected that the system will need another round of tax hikes as early as 2013.
A significant peculiarity in RFTA financial reporting has to do with the aforementioned $10 million maintenance facility expansion. In a presentation to Aspen and Pitkin County officials in April, 2008, RFTA indicated that existing maintenance facilities were already operating beyond design capacity by about 19 vehicles.
Why then did RFTA develop a Baseline financial forecast that didn’t indicate a budget shortfall for maintenance expansion and the associated operating and maintenance costs? Federal financing rules may provide the answer.
As explained by CEO Dan Blankenship and consultant Kristin Kenyon to the RFTA board: “FTA doesn’t want the VSS/SS program to be used by transit agencies for supplementing funding for existing services…” The message is clear - if you want federal financial assistance you need to be creating a new and expanded service, not just shoring up an existing system.
The appearance that the perpetual expansion of service is a strategy to obscure a persistent underreporting of financial reality is disturbing. Neither local taxpayers nor federal regulators should be subjected to a scheme to finesse unmet financial needs under the cover of an entirely new service proposal. If RFTA cannot maintain existing operations at current tax levels, they need to address that situation head on, and completely separate from any new service proposals. Consolidation should precede further expansion.
Aspen Daily News, August 14, 2009:
“The RFTA board voted Thursday to raise bus fares by a dollar and to cut some levels of service in the face of a $1.6 million 2009 budget shortfall.”
“In November, voters approved an increase in sales tax revenue for RFTA, but RFTA CEO Dan Blankenship explained that the revenue from the sales increase was being put aside to pay for the new VelociRFTA bus rapid transit system now in the planning stages.”
RFTA was able to report their budget shortfall as only $1.6 million in part because the maintenance facility expansion – which was apparently necessary to the continued operation of the current system – is now budgeted under the BRT service expansion. Of course, there wouldn’t be any budget shortfall if recent tax increases were applied to actual needs.
The most disturbing aspect of the recent press report is that current services are now being cut in order to preserve the grand illusion this report has chronicled.
 A subsequent election in May, 2007, did obtain voter approval for exclusive bus lanes for a portion of the alignment, but not for the complete project.
 The first few responses from the Washington DC FHWA had been so unsatisfactory that contact was made with the Government Accountability Office (GAO) FraudNET service to request their assistance. The GAO sent a referral to the Department of Transportation, Office of Inspector General (DOT OIG), who did nothing.
With the assistance of the US Congress Member for the Aspen area at that time, the opportunity was created to speak in person to a Special Agent from the OIG – who had no trouble understanding the serious shortcomings of the EIS and ROD. This meeting did result one year later in the only acknowledgement of receipt of the information provided in the numbered paragraphs above by any federal official at any time. However, this acknowledgement came in the same letter from the DOT OIG which evaded any responsibility to investigate that information by claiming, “…we are not in the position to review for accuracy the EIS or ROD of a specific transportation project.”
Similarly unknown to Aspen residents is that the East
of Basalt to Aspen DEIS also addressed concerns regarding the potential for
peak hour traffic volumes to overwhelm the carrying capacity of city streets,
finding that: “Travel paths into the
City of Aspen have been studied to ensure that forecasted traffic on State
Highway 82 could be accommodated adequately in Aspen itself. These travel paths indicate a diffuse
tree-like pattern with the western end of Main Street serving as the ‘trunk’ of
the tree and cross streets serving as the ‘branches’….Because of the diffuse
traffic pattern and the excess capacity on Main Street, the traffic growth
forecasted for State Highway 82 is not expected to create undue congestion
within Aspen itself.”
 As previously noted, it required a full year for the DOT OIG to generate a letter disavowing any responsibility to investigate the false information and assumptions in a “specific” federal transportation funding process. Throughout the conversation with the OIG, reminders were given that the situation had come to them as a referral from the GAO, and that their response should therefore be copied to that agency. Upon receipt of the OIG letter, an attempt was made to contact the responsible official to request a copy of the DOT Special Agent’s original report, and the name of the copied recipient at GAO FraudNET. Telephone contact was refused, and the OIG official, through his secretary, demanded that any such request be made in writing. A Freedom of Information Act request was immediately filed, and it then took another 26 months for that arm of the DOT to report that the requested file was "inadvertently misplaced and cannot be retrieved". A FOIA appeal was filed March 23, 2009, to which there has been no response.
 A RFTA reporting category which used combined ridership statistics for both the Highway 82 corridor and Snowmass Village/Aspen bus routes. Data for the two routes are reported separately in recent years.
 The doubling of transit effectiveness invites an immediate cost benefit comparison, but unfortunately RFTA was unable to provide Operating and Maintenance (O&M) expenses by route. The total O&M cost increase in the entire RFTA system between 1987 and 2005 was about 630%, from $2.4 to $15 million.
 Some small portion may have been inbound skiers, but RFTA could not provide that number. In any event, as noted, ski shuttles are not very relevant to the potential diversion of vehicular traffic to transit.
 DeCorla-Souza P & Cohen HS, Accounting For Induced Travel In Evaluation Of Urban Highway Expansion, Surface Transportation Efficiency Analysis Model (STEAM) White Paper, Session No. 9 http://www.fhwa.dot.gov/steam/doc.htm
 Heanue K, Highway Capacity and Induced Travel: Issues, Evidence and Implications, Transportation Research Circular No. 481, 1998 Abstract: http://188.8.131.52/sundev/detail.cfm?STARTROW=501&ANNUMBER=00748098&Print=y
 Flyvbjerg B, Skamris M, Buhl H & S, Underestimating Costs in Public Works Projects: Error or Lie, APA (American Planning Association) Journal, Summer 2002 http://www.planning.org/japa/pdf/JAPAFlyvbjerg.pdf
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