lmp assessment by ed - Illinois Paddling Council

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AN ASSESSMENT OF LONGMEADOW PARKWAY
Longmeadow Parkway (LMP) is a six mile long, 50 mph, 4-lane road and Fox River toll bridge being
undertaken by the Kane County Division of Transportation (KDOT) with partial federal funding. This is a
renewal of a project originally proposed in the 1980’s when it was called the Bolz Road Bridge. The
original project was deferred in 1997 due to overwhelming public opposition, but it has re-emerged
under a new name.
KDOT’s public position is that LMP will relieve traffic congestion on existing Fox River bridges and serve
growth in Kane County. Facts now on the record that may not have been available when the EIS was
performed demonstrate that both of these positions are erroneous.
Outdated EIS - Federal support for this poorly conceived project is contingent upon an Environmental
Impact Statement developed in 1995-2001. It was published in 2001, and the Record of Decision was
issued in 2002. The EIS is 15 years out of date. Since the EIS was completed many changes have
occurred in the area. Many new homes have been built, parks, and environmentally sensitive areas
have been established, protected species have moved into the area, regulations and planning criteria
have changed, and the transportation network in the area has changed. Also, and perhaps most
significantly, the issues this project was intended to address have changed rather dramatically.
In 2009, recognizing that the EIS was outdated, KDOT retained a consultant to prepare a report to
support their position that a re-evaluation of the EIS was unnecessary. To insure that the consultant
reached the appropriate conclusion, KDOT limited the consultant’s scope such that the only item to be
evaluated was the addition of an environmentally benign toll booth to the LMP bridge. The consultant
dutifully produced the supportive report, and KDOT maintained that their duty to consider a reevaluation was done.
KDOT is attempting to maintain the validity of an obviously flawed and outdated EIS by informal
exchanges of emails and letters with various agencies as areas of vulnerability are identified by
opposition groups 
KDOT is currently preparing to authorize studies of several protected species that were not
addressed in the original EIS.

After opposition groups pointed out a hidden attempt to circumvent federal noise regulations,
KDOT is authorizing a new noise study.

When opposition groups pointed out that the road is bisecting a Forest Preserve that did not
exist at the time of the EIS, KDOT applied for a “de minimus” declaration from FHWA. This
implies that they can build a 4-lane expressway through one of the most pristine areas in the
state (their words) without any environmental impact. The contention is ridiculous on its face.

To meet the “public notification” requirements for the “de minimus” declaration KDOT
published a small notice in a Crystal Lake newspaper that has minimal circulation in Kane
County.
KDOT’s attempts to patch the many holes in the EIS in a matter designed to limit public inspection and
participation subverts the very nature of the environmental evaluation process and the protections
provided under NEPA.
Flawed Growth Projection Methodology – The planning for LMP is based, in part, on population
projections developed by the Chicago Metropolitan Agency for Planning (CMAP). According to their
website, CMAP does not use historical trends as a basis for their projections. Rather, they base their
projections on the realization of the development plans provided by the various municipalities. It is
assumed that transportation systems will be developed to support the development plans. Not only
does this approach lead to highly inflated population projections, it also provides a nonsensical basis for
transportation project planning. It is tantamount to saying, “If we build a new road development will
occur, and because development will occur we must build a new road”.
Outdated Growth Projections – LMP planning is based on data from the period 1990 – 2006, a period of
robust growth in Kane County. However, in the years after 2005 the growth statistics show that the
area has matured, and growth has slowed significantly. The decline in the growth rate has been
accelerated by economic conditions in Illinois, which is currently losing population in all but three of its
counties. Growth in Kane County is still positive, but at 0.6%, it is a small fraction of the rate that
prevailed at the time LMP was planned.
The minimal growth that is projected for Kane County will occur in areas that are not served by LMP
(Elgin, Huntley, etc.). Anyone looking at a map of the area will quickly see that the growth areas are
served by I-90, not LMP. This is well known to the ISTHA and it is the reason ISTHA is expanding I-90.
The lack of growth in the area to be served by LMP has had a direct, demonstrable impact on traffic
volumes on the Fox River bridges. It is declining. The following table shows traffic counts on the Rt. 62
Bridge in Algonquin. The figures are taken from IDOT’s published statistics; they show actual traffic
counts in vehicles per day:
YEAR
2005
2007
2009
2012
2013
TRAFFIC COUNT
41,800
42,600
41,800
40,400
37,100
It should be noted that the LMP planning basis, as shown in the Engineer’s report assumed that traffic
on this bridge in 2013 would be 49,500 vehicles per day, or 33% higher than the actual counts.
“de mininus” Impact on Traffic – As state above, the planning for LMP is flawed and out of date.
However, even with its fatal flaws, it still fails to support construction of this ill-conceived project. The
development of LMP is based on a report prepared by Wilbur Smith Associates and published in 2009,
after the ROD. It is titled “Longmeadow Parkway Bridge Corridor – Traffic Projections and Financial
Feasibility Study, Final Report of Findings” and it is available on the KDOT website. The heart of the
planning is the traffic projections summarized on pg. 60. They show the traffic reductions on the Fox
River Bridges under a variety of tolling scenarios that might be adopted for the LMP bridge. The figures
are the result of detailed, computer modeling of the traffic network. In the report the Engineer states
that the margin of error inherent in the modeling is +/-10%. For convenience of comparison, in the
following table we show the Engineer’s predicted reduction in traffic volume as a percentage so it can
be compared to the Engineer’s stated margin of error.
Reduction in Traffic Flow (%)
Passenger Car Tolls
(Peak/Off-Peak)
$0.50 / $0.50
$1.00 / $0.50
$1.50 / $1.00
(Recommended)
Rt. 62 (Algonquin)
12.7%
10.6%
5.3%
Main St. (Carpentersville)
5.6%
4.7%
2.3%
Rt. 72 (Dundee)
3.9%
3.1%
0.6%
Under the recommended tolling scenario the reduction in traffic on the existing bridges does not even
approach the 10% margin of error of the Engineer’s modeling. KDOT’s claim of significant traffic
reductions on the Fox River bridges is unsupportable.
Flawed and Arbitrary Traffic Planning – Not only is the traffic planning basis unrealistic, and predicted
traffic reductions “de minimus”, the modeling is flawed and out of date. The models used did not
include several key elements that will greatly impact traffic, and will make the “no build” alternative
much more feasible and prudent:

Algonquin Western Bypass – This is a newly opened, 4-lane road that routes traffic on Rt. 31
around the Village of Algonquin. Formerly the intersection of Rts. 31 and 62 in the center of
Algonquin was a major bottleneck. The bypass may have some marginal impact on the plan for
LMP, but it was not considered.

Algonquin Northern Bypass – This is a proposed new, 4-lane road that will connect Rt. 62 to Rt.
31 via a new bridge across the Fox River a short distance north of Algonquin. It will have a major
impact on traffic, and it will probably reduce the already pitifully low traffic projected for LMP to
a mere trickle. This proposed bypass is part of McHenry County’s 2030 Comprehensive Plan (pg.
107), yet it was never considered by the LMP planners. The EIS was based on an arbitrary
decision that Algonquin would be the northern boundary of the planning area; thus the new
bypass, located just north of the Village, could be ignored by the EIS even though it is an
obvious, feasible and prudent alternative to LMP.
In summary, Longmeadow Parkway will cost the taxpayers of Kane County in excess of $100 million. It
will disrupt residential neighborhoods, create a huge scar through a Forest Preserve, threaten the health
and wellbeing of residents in the corridor, threaten several protected species of flora and fauna, turn
hundreds of prized oak trees into chip board, and destroy a pristine riverfront in one of the most
valuable pieces of open land remaining in Kane County. It will do all of this while serving no purpose and
providing no demonstrable public benefit.
The EIS upon which the project is predicated is woefully out of date. The planning for the project is
flawed and has been overtaken by events. The “no build” alternative, rejected by the EIS, now appears
to be a very prudent and feasible alternative to the environmental depredations of LMP.
Our federal and local resources must not be wasted on this project until its utility and environmental
impacts have been thoroughly and properly evaluated.
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