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 Outdated EIS - Federal support for this poorly conceived project is contingent upon an Environmental Impact Statement developed in 1995-2001.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 The EIS is 15 years out of date.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 In 2009, recognizing that the EIS was outdated, KDOT retained a consultant to prepare a report to support their position that a re-evaluation of the EIS was unnecessary.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 KDOT is attempting to maintain the validity of an obviously flawed and outdated EIS by informal exchanges of emails and letters with various agencies as areas of vulnerability are identified by opposition groups KDOT is currently preparing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.