stop the legacy highway

Comments on the Final Environmental Impact Statement
for the proposed construction of the Legacy Highway

EVALUATION OF THE TRAVEL DEMAND MODELING IN THE LEGACY PARKWAY FINAL ENVIRONMENTAL IMPACT STATEMENT

for the Friends of Great Salt Lake, Future Moves,
Great Salt Lake Audubon Society, HawkWatch,
League of Women Voters of Salt Lake, and
Sierra Club Utah Chapter

by

Caroline J. Rodier, Ph.D.
Robert A. Johnston, Professor
Department of Environmental Science and Policy
University of California
Davis, CA 95616

August 2000

EXECUTIVE SUMMARY

On July 14, 2000, the Utah Department of Transportation and the Federal Highway Administration issued the Legacy Parkway Final Environmental Impact Statement (FEIS). The FEIS relied on the travel demand forecast made by the Wasatch Regional Council (WFRC) to conclude that the Legacy Parkway highway is needed to meet the future travel demand in the North Corridor. The authors reviewed all of the documentation of the Wasatch Front Regional Council (WFRC) travel demand model, the computer files and programs of the model, and simulated the FEIS alternatives with the model. Based on our reviews and simulations, we made the following conclusions.

The travel demand forecasts used in the FEIS are critically flawed and unreliable, and fail to meet some of the basic criteria for model validity.

The travel forecasts for the alternatives evaluated in the FEIS are inconsistent with the basic economic theory used to develop travel demand models. For example, when the supply of travel is increased in the model, speeds decrease and less travel is demanded or speeds increase and less travel is demanded. To be considered valid and reliable, the model must produce results that are consistent with the theory upon which the model is based.

The sub-models within the WFRC travel demand modeling system produce conflicting results about the effect of the highway alternatives on travel speeds and vehicle miles traveled. As a basic test of consistency, sub-models within a travel demand model should not produce conflicting results.

The results obtained from the authors' simulations of the FEIS alternatives, using the travel demand model that was provided by WFRC, are inconsistent with the results documented in the FEIS. Moreover, the computer file results from the WFRC simulations that were sent to us are also not consistent with the results documented in the FEIS. Replicability of results by independent reviewers is another basic test of model validity.

Because the FEIS uses different versions of the model for different purposes, it is impossible to evaluate the validity of the conclusions reached in the FEIS. Two versions of the WFRC model are used to forecast future travel demand, one version for the No Build alternative and one version for the I-15 and Legacy Parkway alternatives. It is impossible to determine whether the results obtained for the alternatives are due to differences in the travel demand models or differences in the transportation systems represented in the alternatives.

The travel speeds predicted by the WFRC travel demand model are unreasonably low. Predicted speeds are inconsistent with the empirical literature and 20-year forecasts of regions that are larger than the Salt Lake City region.

The FEIS incorrectly states that the WFRC travel demand models used in the analysis of alternatives meet the immediate term recommendations of the 1999 peer review. Only approximately half of the immediate term recommendations were implemented in the WFRC travel demand models used in the FEIS. As a result, the WFRC travel demand model cannot be characterized as state-of-the-practice.

The WFRC travel demand model is biased in favor of highway alternatives and biased against transit and no build alternatives. For each of the following reasons, the WFRC travel demand model would tend to underestimate vehicle miles of travel (VMT), emissions, and congestion in the highway alternative compared to the no build or transit alternatives:

In some cases, an increase in the supply of transportation facilities decreases the demand for travel. In other cases, even when this relationship changes in the correct direction, the magnitude of the change is low.

A single set of land use projections is used in the analysis of FEIS alternatives. Thus, the analysis does not account fully for additional trips induced by construction of the highway. Formal methods are reasonably available (with respect to both time and cost) to project the land use and transportation interaction of the proposed alternatives. One such method was recommended as an immediate improvement by the peer review process but not adopted by WFRC. Research findings suggest that this omission may be significant for the alternatives evaluated in the FEIS.

The model does not evaluate the effect of changes in accessibility on auto ownership and thus the number of auto trips taken. As a result, the model would not represent additional non-work trips that may result from highway alternatives.

The WFRC travel demand model uses separate trip generation models for different areas of the region and thus the internal and external trips that are work trips will not be included in the feedback process from traffic assignment to trip distribution. As a result, the WFRC travel demand model would tend to underestimate the length of those auto trips in the highway build alternatives.

One version of the model uses an unreliable method of feedback of travel times from traffic assignment to trip distribution. As a result, it is possible that auto trip lengths are underestimated in the highway build alternatives.

The model does not make use of its mode choice sub-model in its evaluation of alternatives. As a result, the model would tend to overestimate average vehicle occupancy (passengers per car) in the highway build alternatives.

The model does not consider the tendency of travelers to shift their trips to the beginning or end of congested peak traffic periods. As a result, congestion reduction resulting from the highway build scenarios would be overestimated.

As a result of these serious flaws, we can only conclude that the WFRC travel demand model used to evaluate the alternatives in the FEIS is insufficiently accurate for plan or project analysis, or to properly support the analysis and conclusions in the FEIS.

HISTORY OF THE REVIEW PROCESS

In the Spring and Summer of 1998, the Sierra Club asked Caroline Rodier and Robert Johnston at the University of California, Davis, to review the Wasatch Front Regional Council (WFRC) travel demand model used in the Legacy Parkway Draft Environmental Impact Statement. Dr. Rodier and Professor Johnston found a number of significant limitations in the WFRC travel demand model, many of which could bias the evaluation of transportation alternatives in favor of highway alternatives and against no build and transit alternatives (see Rodier and Johnston, 1998). Of particular concern were the use of a flawed method of feedback of assigned travel times to trip distribution, the inconsistent application of the mode choice model, crude representation of congested travel times, the failure to simulate land use and peak spreading effects, and incomplete documentation of the model.

In May of 1999, the Federal Department of Transportation convened an impartial panel of travel demand modeling practitioners to review the WFRC travel demand model with respect to the current state of the practice. This peer review was convened as part of their normal review process and to help WFRC answer questions raised by the Sierra Club about the adequacy of the WFRC model for the analysis of the proposed Legacy Parkway and I-15 North Corridor projects (Wasatch Front Regional Council, 1999; Rodier and Johnston, 1998). The recommendations of the peer review were largely consistent with those suggested by the Sierra Club (in Rodier and Johnston, 1998). The reviews differed only with respect to the timing of some improvements and the peers added more recommended improvements than suggested by the Sierra Club.

The peers recommended that the following improvements be made to the WFRC model immediately:

  • Combine the Salt Lake City and Ogden models into one unified model;

  • Conduct a Delphi Review of land use allocation for socioeconomic and land use projections;

  • Implement a feedback mechanism to trip distribution using the successive averages approach for convergence;

  • Use AM Peak, PM Peak, and mid-day trip tables to create input skims for trip distribution;

  • Improve highway assignment in the mode choice model to eliminate the "floor" on bus speeds in the mode choice model;

  • Create peak period (multi-hour, AM, and PM) and mid-day traffic assignments;

  • Include modified delay functions for freeway links and define link capacities as possible capacities, not "level of service C" capacities, in the network;

  • Prepare adequate documentation of the travel demand model assumptions and validation; and

  • Establish travel demand model steering committee.

In their general comments, the peers also recommend that WFRC "execute the full model set for each alternative analyzed." In addition to the immediate recommendations, the peers recommended that many other significant improvements be made to the model in the short- (2002) and long-terms (2005).

The immediate recommendations (January 2000) constituted a dramatic revision of the 1998 WFRC travel demand models. These improvements cannot be construed as merely a "fine tuning" of the existing model. For example, the implementation of a feedback mechanism to trip distribution using the successive averages approach for convergence could alter the rank ordering of no build and highway alternatives with respect to vehicle miles traveled (VMT). In addition, the Delphi Review of land uses for no build and build alternative could significantly affect the magnitude of change for the results of the highway and transit alternatives compared to a no build alternative.

It is also important to point out that the 1997 version of the WFRC was used for the evaluation of transit potential in the corridor and for the evaluation of air quality impacts. It is important to note that these models did not include any of the recommendations of the peer review committee. Moreover, it is disturbing that the 1997 model, which projects lower VMT than the December 1999 or May 2000 versions of the model, is used for the air quality analysis and the later versions of the model are used to demonstrate need in the FEIS. WFRC needs to address the discrepancies among the models and explain why different models were used for different purposes.

In the FEIS, it is stated that "the Peer Review panel found that WFRC is utilizing standard travel modeling procedures" (pg. 1-30). This statement is hardly an endorsement of the WFRC model. It is well recognized that the standard travel modeling procedures in the U.S. are seriously lacking (National Academy of Sciences/National Research Council, 1995). These models are insensitive to policy and investment alternatives, and their forecasts are typically inaccurate. Harvey and Deakin (1993), in their report for the National Association of Regional Councils, lay out acceptable modeling practices for regions of various sizes. The scope and depth of the peers' recommended immediate improvements and our August 1998 review are evidence that the 1998 WFRC travel demand model does not meet the standard of acceptable modeling practice.

In the FEIS (pg. 1-30), it is stated that WFRC implemented all of the immediate improvements during 1999 and 2000. This statement is incorrect. Final documentation of the WFRC travel demand model was released in March of 2000 in two documents (Wasatch Front Regional Council Travel Model Documentation 1999, March 2000, and Summary of Travel Model Changes, March 2000). A CD of the WFRC travel demand model was provided to Dr. Rodier on May 15, 2000, and necessary documentation of the files and programs included in the CD was provided on June 12, 2000.

The results from two versions of the WFRC travel demand model were used in the FEIS. The first version was the December 1999 WFRC travel demand model, and the second was the May 2000 WFRC travel demand model. Note that the tables in the FEIS that present travel demand figures document both of these models as their sources. The CD provided to Dr. Rodier included the May 2000 WFRC travel demand model.

The following improvements are included in the December 1999 WFRC travel demand model:

  • An auto ownership sub-model that includes urban design and accessibility variables; however, the accessibility variables do not change from the no build to the transportation investment alternative;

  • A merged Salt Lake City, Ogden, and Provo trip distribution sub-model, but not a merged trip generation sub-model;

  • Include modified delay functions for freeway links and define link capacities as possible capacities, not "level of service C" capacities, in the network;

  • Adequate documentation of the travel demand model assumptions and validation; and

  • The establishment of a travel demand model steering committee.

Thus, less than a half of the immediate improvements recommended by the peers are included in the December 1999 WFRC travel demand model. Again, results from this model are included in the FEIS.

The following additional improvements were included in the May 2000 WFRC travel demand model:

  • A feedback mechanism to trip distribution using the successive averages approach for convergence; and

  • Peak period (multi-hour, AM, and PM) and mid-day traffic assignments.

Thus, approximately half of the immediate improvements recommended by the peers were included in the May 2000 WFRC travel demand model.

The following improvements are not included in the May 2000 WFRC travel demand model based on the documentation provided to the authors:

  • Combine the Salt Lake City and Ogden trip generation models into one unified model;

  • Conduct a Delphi Review of land use allocation for socioeconomic and land use projections;

  • Use AM Peak, PM Peak, and mid-day trip tables to create input skims for trip distribution; and

  • Improve highway assignment in the mode choice model to eliminate "floor" on bus speeds in the mode choice model.

In sum, it is incorrect to characterize the WFRC travel demand model as state-of-the-practice. The FEIS falsely states that WFRC has implemented all the immediate term recommendations of the Peer Review. Moreover, it is misleading to characterize standard practice in travel demand modeling as acceptable travel demand modeling practice.

BRIEF INTRODUCTION TO TRAVEL DEMAND MODELING

Travel Theory
Travel theory, upon which the traditional four step travel demand model is based, predicts that demand for travel is derived from the amount and location of economic activities and the time and cost of travel by various modes. See Ben-Akiva and Lerman, 1985, and Small, 1992. The amount and location of economic activities is typically projected outside the travel demand model; however, transportation variables such as travel time and cost can affect the location of economic activities (see discussion below). The effect of changes in the supply of the transportation system (e.g., a new highway or light rail line) on travel time and costs are typically estimated within the travel demand model.

The relationship between the demand for travel and the price of travel (i.e., the time and cost of travel by mode) is derived from economic theory. Basic economic theory predicts that as the supply of a good increases and its price is lowered, the consumption of that good will increase; and that as the supply of a good diminishes and its price is increased, the consumption of that good will decrease (all else being equal). In other words, there is a positive relationship between the supply and the demand for a good and a negative relationship between the price and the demand for a good.

Take, for example, a new highway that is being simulated in a travel demand model in a 20-year time horizon. To simulate the highway alternative, the new highway lanes would be added to the no build roadway network to examine the effect of the new lanes on travel speed. New highway lanes would be expected to reduce the price of travel by increasing auto travel speeds and decreasing auto travel times. The reduced cost of auto travel would be expected to produce an increase in the amount of auto travel (i.e., VMT), all else being equal.

The Four-Step Travel Demand Model
Travel demand models are typically developed with travel behavior surveys, socioeconomic data (i.e., population, employment, household size, auto ownership, and income), and the characteristics of the transportation system (e.g., traffic counts on roads) for a base year.

Traffic analysis zones are the geographic units used by travel demand models. Zones contain area-specific information (e.g., households and employment) and are the location at which trips begin and end in a model. The size of zones range from a quarter mile to several miles, and models typically use between 500 to 2000 zones.

The network of a travel demand model represents the roadways and transit lines of a region with a series of links connected by nodes. All the links in the models are described in terms of key variables (e.g., type of road, speed, and number of lanes).

Travel demand models generally include the following steps to answer key questions about future travel patterns:

  • Trip Generation: How many trips will be made?
    The trip generation model estimates the number of trips that begin or end in a zone. The number of trips are typically determined by the location of household and employment activities, other socioeconomic variables (e.g., income and auto ownership), land use variables (e.g., pedestrian amenities), and travel time and cost variables (which generally influence non-work trips through auto ownership).

  • Trip Distribution: Where will the trips begin and end?
    The trip distribution model links the trips from trip generation in an origin-destination pattern. This is typically based on variables that capture the ease of traveling to a destination by mode (e.g., travel time and cost).

  • Mode Choice: What modes will be used to make the trip?
    Mode choice models predict the probability that a traveler will chose a particular mode from a range of available modes generally as a function of modal attributes (e.g., time and cost), traveler or household characteristics, and the quality of the urban environment (e.g., pedestrian amenities).

  • Traffic Assignment: What routes or roads will be used to complete the trip?
    In the traffic assignment step, trips are assigned to routes with preference given to the fastest routes. More specifically, "traffic assignment is based on (or determined by) the simultaneous interaction of link travel times (or speeds); the capacity of the link; and the volume assigned to the link, considering other paths in the network" (Harvey and Deakin, 1993). The outputs from traffic assignment are link volumes, link speed, VMT, and vehicle hours of delay (VHD). These outputs play an important role in the evaluation of travel effects of transportation alternatives and are key inputs to emissions analyses of transportation alternatives.

REVIEW OF THE TRAVEL DEMAND FORECASTS IN THE FEIS

Simulation Procedures
On approximately May 15, 2000, Mick Crandall provided Dr. Rodier a CD with files and procedures that WFRC used to generate the May 2000 traffic estimates included in the FEIS. This CD, however, lacked sufficient documentation necessary to identify and analyze the input and output files and the programs. Therefore, we requested that Mr. Crandall provide us additional documentation. One June 12, 2000, Mr. Crandall provided Dr. Rodier with the requested documentation, which allowed Dr. Rodier to analyze and operate the WFRC travel demand model. From June 12, 2000, to the end of July, 2000, Dr. Rodier analyzed and ran the May 2000 WFRC travel demand model.

Dr. Rodier used the basic instructions provided by Mr. Crandall (written documentation with some adjustments based on telephone conversations) as well as instructions from the TP+ manual to operate the May 2000 WFRC travel demand model.

Evaluation of the WFRC Travel Demand Model Simulations
As a preliminary matter, the FEIS includes travel forecasts from separate WFRC travel demand models, the December 1999 WFRC travel demand model and the May 2000 WFRC travel demand model. As discussed in the section above, the December 1999 model and the May 2000 model are very different travel demand models. In Chapter 1, Purpose and Need for Action, most of the tables show the December 1999 WFRC travel demand model as the source of the travel forecasts for the no build alternative. However, in Chapter 2, Alternatives, the tables show the May 2000 WFRC travel demand model as the source of travel forecast for the future highway alternatives. It is not acceptable practice to use two different models to evaluate competing alternatives. This is because such a practice makes it impossible to determine whether the change in the travel forecasts are due to the difference between the models or the differences between the transportation alternatives simulated with the models. Essentially, the analysis is confounded.

However, in Appendix P, 2020 Travel Demand Analysis, most of the analysis, including both the no build and the build alternatives, is conducted with the May 2000 WFRC Travel Demand Model. The May 2000 WFRC Travel Demand Model is the model that was provided to us by WFRC, and it is the model that we will evaluate in this section of the report.

At a minimum, for a simulation model to be deemed reasonable or acceptable, it must produce results that are consistent with the theory on which the simulation model was developed, both at the regional and at the sub-regional or corridor level. In addition, the sub-models within a model must represent consistent relationships.

The results of the May 2000 WFRC travel demand model, documented in Table P-11 of Appendix P, are evidence that this model's forecasts of speed and VMT at the regional level are inconsistent with basic travel theory and that the sub-models within the model system produce inconsistent results.

Table P-11 is reproduced below as Table 1 of this report. Note that there are two sections in Table 1. The first section represents the results of the full daily travel demand model. This model distributes work trips to origin and destination locations using congested auto travel times (represented by some percentage of daily traffic volumes) and non-work trips using free flow auto travel times. The second section of the table presents the results of the peak period assignment model. This model is executed after the full daily travel demand model to obtain more precise projections by time of day. The peak period model assigns some percentage (based on survey data) of the daily traffic projections from the full travel demand model run to the roadway network for each time period (i.e., AM peak, PM peak, and mid-day).

The results in Table 1 show that for the daily WFRC travel demand model when new highway lanes are added to the No build network in 2020, travel speeds actually decline, and thus congestion increases in the highway alternatives. These results are inconsistent with the goal of congestion reduction in the FEIS.

Table 1. Reproduction of Table P-11 in the FEIS,
Region Vehicle-Miles of Travel (VMT) and Vehicle Hours of delay (VHD) (2020).

Daily WFRC Travel Demand Model No BuildLegacyI-15
Daily VMT48,560,00048,760,00052.390,000
Daily VHTa2,560,0004,240,0006,690,000
Average Speed (mph)19.011.56.7
Peak Period Assignment ModelNo BuildLegacy I-15
AM-Peak
AM VMT9,447,8709,232,3408,776,770
AM VHT544,000333,000377,000
Average AM Speed (mph)17.426.424.5
PM-Peak
PM VMT14,770,00014,570,00013,500,000
PM VHT2,008,0001,586,0001,121,000
Average PM Speed (mph)7.412.09.2

Source: May 2000 WFRC Travel Demand Model

In addition, for the daily model, when the cost of travel increases (i.e., travel speeds decrease and thus the time cost of travel increases), the quantity of travel demanded (i.e., VMT) increases. The model represents a positive, as opposed to negative, relationship between price and quality demanded. This relationship is inconsistent with basic travel theory, as outlined above. Moreover, the I-15 alternative, which includes fewer lane miles of highway than the Legacy alternative, is projected to increase VMT more than the Legacy alternative.

When the results of the AM and PM peak models are compared to the results of the daily model, we can see that the peak and daily sub-models within the WFRC travel demand model produce inconsistent results. The results of the peak period models indicate that that the highway alternatives increase average travel speeds and thus reduce congestion. The results of the daily model obtained the opposite result.

In addition, for the AM and PM peak models, when the cost of travel decreases (i.e., travel speeds increase, and thus the time cost of travel decreases), the quality of travel demanded (i.e., VMT) decreases. Again, this model represents a positive as opposed to negative, relationship between price and quantity demanded. Again, this relationship is inconsistent with basic travel theory, as outlined above.

The differences between the relationships and results obtained between the two sub-models cannot be explained by the different time periods captured by the models (i.e., AM and PM peak vs. daily travel). The direction of change should be the same in both sub-models, but it is reasonable to expect that the magnitude of change would be greater during the peak periods.

In addition, we note that for the daily WFRC travel demand model, there appears to be an error in the calculation of VHT. We believe that these figures represent vehicle minutes of travel. Note that the results for the AM and PM peak period are almost equal to the daily VHT. This could not be correct because the AM and PM peak period only represents a fraction of total daily vehicle travel.

With respect to the traffic volumes reported in Table P-9 to Table P-10c, it is difficult to understand why the total volumes for the I-15 build alternative is lower than the total volumes for the No Build scenario. With the added lanes in the I-15 scenario, travel theory would predict that volumes would increase compared to the No Build scenario.

Next, we compared the results reported in the FEIS (Table 1 above) to the output files from the WFRC travel demand model runs for the No Build alternative, the Legacy alternative, and the I-15 alternatives (included in the CD sent to us by WFRC). Table 2 presents the regional daily travel results from these output files.

First, it is apparent that the travel results presented in Table 2 are not consistent with the travel results presented in Table 1. We asked Mr. Crandall about this, and he informed us that the output files he gave us were the same results used in the FEIS. Obviously, this cannot be correct. It is disturbing that WFRC cannot produce the output files that were used in the FEIS.

Table 2. WFRC's travel demand model results (2020) from output files provided in the CD.

Daily WFRC Travel Demand ModelNo BuildLegacy% changeI-15% change
Total Lane Miles12,64712,7380.72%12,6670.16%
Daily Trips5,619,5285,584,162-0.63%5,568,477-0.91%
Daily VMT48,560,00048,760,0000.41%48,550,000-0.02%
Daily VHTa4,266,6677,066,66765.63%7,216,66769.14%
Average Speed (mph)11.46.9-39.37%6.7-40.89%
Elasticity VMT/Lane Milesb  0.57 -0.13
Elasticity VMT/VHTc  0.01 0.00
Peak Period Assignment ModelNo BuildLegacy% changeI-15% change
AM-Peak
AM Trips881,668867,982-1.55%864,063-2.00%
AM VMT8,926,0468,784,684-1.58%8,763,670-1.82%
AM VHT607,272529,713-12.77%554,580-8.68%
Average AM Speed (mph)14.716.612.83%15.87.51%
Average AM Travel Time (minutes)41.336.6-11.4038.5-6.82
Mid-Day
Mid-Day Trips2,036,6312,032,070-0.22%2,027,819-0.43%
Mid-Day VMT16,537,71316,439,067-0.60%16,445,889-0.56%
Mid-Day VHT674,916652,889-3.26%662,694-1.81%
Average Mid-Day Speed (mph)24.525.22.76%24.81.28%
Average Mid-Day Travel Time (minutes)19.919.3-3.05%19.6-1.38%
PM-Peak
PM Trips1,510,2041,499,518-0.71%1,495,315-0.99%
PM VMT13,652,17513,578,713-0.54%13,478,764-1.27%
PM VHT2,096,9521,835,514-12.47%1,866,618-10.98%
Average PM Speed (mph)6.57.413.63%7.210.91%
Average PM Travel Time (minutes)83.373.4-11.84%74.9-10.10%
Daily for Peak Period Model
Elasticity VMT/Lane Miles  -1.11 -6.9
Elasticity VMT/VHT  0.08 0.13
  1. VHT is vehicle hours of travel.
  2. Elasticity of VMT/Lane Miles is elasticity of VMT with respect to lane miles.
  3. Elasticity of VMT/VHT is elasticity of VMT with respect to VHT.
The results presented in Table 2, however, share many of the same problems pointed out in Table 1. The daily travel demand model predicts that travel speeds will decline and that average travel times will increase in the Legacy and I-15 build alternatives compared to the No Build alternative. Again, these results are inconsistent with the stated goals of the FEIS. Another problem in the daily travel model results is that VMT is predicted to increase despite slower speeds in the Legacy alternative compared to the No Build alternative. Again, this is also contrary to travel theory, which predicts that slower auto speeds will result in reduced VMT.

The results from the peak period assignment model produce speed and travel time results that are consistent with the goals of the FEIS. However, the direction of change from the No Build to the build alternatives is not consistent with travel theory (i.e., speeds increase but VMT decreases). Again, note the counterintuitive signs on the elasticity results. Moreover, the results of the peak period model are not consistent with the results of the daily model.

Table 2 indicates that the WFRC travel demand model uses speeds that are unreasonably low and average commute times that are unreasonably long. This is a mid-sized region that is not highly congested. These results do not correspond to the empirical literature and to future projections for other mid-sized regions. USDOT's "Our Nation's Travel: 1995 NPTS Early Results" (1997) finds that average work trips are 11.5 miles, average work travel time is 20.7 minutes, and average speed is 33.6 mph. The following is a reproduction of a table in the USDOT report that documents the average commute speed by size of metropolitan area.

1995 NTPS Summary of Travel Trends:
Table 26 Average Commute Speed by MSA (metropolitan statistical area) Size 1983, 1990, 1995 NPTS (miles per hour).

MSA size Not in MSALess than 250,000250,000 to 499,999500,000 to 999,9991 to 2.9 million3 million and over
198331.9727.2030.0928.5228.1124.32
199038.3432.8534.2234.8431.8930.99
199539.1135.6735.7234.7634.8932.29

In 2020, WFRC predicts that the region will have a population of almost 2 million. The commute speeds from the WFRC travel demand model are significantly lower than the AM and PM speeds reported in the FEIS for a comparable metropolitan areas. The Sacramento, CA, region, which forecasts a population of 2.8 million in 2015, projects average AM travel speeds of 39 mph in the year 2015. The Houston-Galveston region, a large metropolitan area, projects average speeds of 39 mph in 2022.

It also seems odd that the PM peak hour speeds are so much slower than the AM peak hour speeds. WFRC needs to explain why the two are so different.

We attempted to replicate the results obtained by WFRC (presented in Tables 1 and 2 above) by simulating the scenarios with the travel demand model that they provided to us in the CD in May of 2000. Replicability is a critical element of credible scientific methods. Table 3 presents the results of our simulation. The results indicate that we could not replicate the WFRC travel results presented in Tables 1 or 2. Both the actual values and the direction of change with respect to critical outputs differed between the WFRC simulations and our simulations. Again, we find inconsistencies between the results for the daily travel demand model and the peak period assignment model, and many of the results are not consistent with travel theory. These results suggest that the WFRC travel demand model provided to us was different from the WFRC travel demand model used in the FEIS analysis. As described above, we followed the procedures provided to us by Mr. Crandall and provided by the TP+ manual. Again, it is disturbing that WFRC cannot produce the WFRC travel demand model used for the FEIS analysis.

Table 3. The authors' simulation of alternatives with the WFRC travel demand model (2020).

Daily WFRC Travel Demand ModelNo BuildLegacy% changeI-15% change
Total Lane Miles12,64712,7380.72%12,6670.16%
Daily Trips5,588,1395,591,2870.06%5,567,827-0.36%
Daily VMT48,440,00048,030,000-0.85%48,690,0000.52%
Daily VHTa4,300,0003,850,000-10.47%7,333,33370.54%
Average Speed (mph)11.312.510.74%6.6-41.06%
Elasticity VMT/Lane Milesb  0.00 0.00
Elasticity of VMT/VHTc  0.08 0.01
Peak Period Assignment ModelNo BuildLegacy% changeI-15% change
AM-Peak
AM Trips875,923870,495-0.62%863,837-1.38%
AM VMT8,863,5148,783,686-0.90%8,763,878-1.12%
AM VHT579,430523,972-9.57%548,604-5.32%
Average AM Speed (mph)15.316.89.59%16.04.43%
Average AM Travel Time (minutes)39.736.1-9.01%38.1-4.00%
Mid-Day
Mid-Day Trips2,028,7622,033,2580.22%2,027,707-0.05%
Mid-Day VMT16,449,53316,509,7120.37%16,429,201-0.12%
Mid-Day VHT660,171666,8701.01%659,175-0.15%
Average Mid-Day Speed (mph) 24.924.8-0.64%24.90.03%
Average Mid-Day Travel Time (minutes)19.519.70.79%19.5-0.10%
PM-Peak
PM Trips1,502,0741,501,651-0.03%1,495,127-0.46%
PM VMT13,588,78513,568,388-0.15%13,535,132-0.39%
PM VHT2,058,2591,845,782-10.32%1,902,237-7.58%
Average PM Speed (mph)6.67.411.34%7.17.77%
Average PM Travel Time (minutes)82.273.8-10.30%76.3-7.15%
Daily for Peak Period Model
Elasticity VMT/Lane Miles  -0.14 -2.81
Elasticity of VMT/VHT  0.01 0.08

a VHT is vehicle hours of travel.
b Elasticity of VMT/Lane Miles is elasticity of VMT with respect to lane miles.
c Elasticity of VMT/VHT is elasticity of VMT with respect to VHT.

In previous comments, we have expressed to UDOT and WFRC our concern about using two different percentages of daily traffic volumes to represent congested auto travel times for work trip distributions in the No Build and in the Legacy and I-15 build alternatives. The No Build alternative used 12%, and the build alternatives used 10%. The use of these two different factors is documented in the output files provided to us in the CD. Essentially, different models were used in the No Build and build alternatives, which would confound the results of the analysis; that is, with such an analysis, it would be impossible to separate the effect of the different factors from the effect of the new highways on the travel results. We ran the WFRC travel demand model with consistent percentages of daily traffic volumes to represent congested auto travel times across all the alternatives. The hope was that this would correct some of the problems found in the model results in Tables 1, 2, and 3. Table 4 documents the results of the simulation with consistent 10% factors of average daily traffic volumes across alternatives to represent congested auto travel times.

Table 4. The authors' simulation of the alternatives with the WFRC travel demand model
     using consistent percentages of daily traffic volumes (10%) to represent congested auto travel times (2020).

Daily WFRC Travel Demand ModelNo BuildLegacy% changeI-15% change
Total Lane Miles12,64712,7380.72%12,6670.16%
Daily Trips5,549,6835,591,2870.75%5,567,8270.33%
Daily VMT47,880,00048,030,0000.31%48,690,0001.69%
Daily VHTa4,100,0003,850,000-6.10%7,333,33378.86%
Average Speed (mph)11.712.56.83%6.6-43.15%
Elasticity VMT/Lane Milesb  0.44 10.67
Elasticity of VMT/VHTc  -0.05 0.02
Peak Period Assignment ModelNo BuildLegacy% changeI-15% change
AM-Peak
AM Trips862,277870,4950.95%863,8370.18%
AM VMT8,773,9188,783,6860.11%8,763,878-0.11%
AM VHT586,392523,972-10.64%548,604-6.44%
Average AM Speed (mph)15.016.812.04%16.06.77%
Average AM Travel Time (minutes)40.836.1-11.49%38.1-6.61%
Mid-Day
Mid-Day Trips2,022,4432,033,2580.53%2,027,7070.26%
Mid-Day VMT16,373,20316,509,7120.83%16,429,2010.34%
Mid-Day VHT658,971666,8701.20%659,1750.03%
Average Mid-Day Speed (mph)24.824.8-0.36%24.90.31%
Average Mid-Day Travel Time (minutes)19.519.70.66%19.5-0.23%
PM-Peak
PM Trips1,490,6901,501,6510.74%1,495,1270.30%
PM VMT13,528,98913,568,3880.29%13,535,1320.05%
PM VHT2,081,7301,845,782-11.33%1,902,237-8.62%
Average PM Speed (mph)6.57.413.11%7.19.49%
Average PM Travel Time (minutes)83.873.8-11.98%76.3-8.89%
Daily for Peak Period Model
Elasticity VMT/Lane Miles  0.67 0.85
Elasticity of VMT/ VHT  -0.05 -0.02

a VHT is vehicle hours of travel.
b Elasticity of VMT/Lane Miles is elasticity of VMT with respect to lane miles.
c Elasticity of VMT/VHT is elasticity of VMT with respect to VHT.

The results in Table 4 are more reasonable than those presented in Table 1, 2, and 3, but there are still significant problems. The direction of change from the No Build to the Legacy and I-15 alternatives is consistent with travel theory for the peak period assignment model. For the full daily travel demand model, the results of the Legacy alternative is consistent with travel theory. However, the direction of change for the I-15 alternative from the No Build scenario is counterintuitive; the addition of highway capacity reduces travel speed and thus increases congestion.

We can only conclude that the WFRC travel demand model used in the FEIS is critically flawed and that its results are unreasonable and unreliable. The results presented in Tables 1, 2, 3, and 4 above are evidence of serious errors in the application of the model (i.e., use of inconsistent percentages of average daily traffic to represent congested auto travel times) and in the model itself (e.g., human errors in programming of the model). The results in Table 1, the regional travel forecast for the No build and build alternatives, indicate that the daily travel demand model and the peak-period model produce conflicting results and that each sub-model produces results that are inconsistent with travel theory. The results presented in Table 2, which include the results of the output files for the alternative simulations provided in the WFRC model CD, are not the same as those presented in the FEIS; however, these results share the problems described for Table 1. It is disturbing that WFRC was not able to produce output files consistent with the results presented in the FEIS. The results presented in Table 3 indicate that the travel results used in the FEIS cannot be replicated with the WFRC travel demand model provided to us by WFRC. Again, it is disturbing that WFRC cannot produced a travel demand model that is capable of replicating the results of the FEIS analysis. The results presented in Table 4 indicate that even when one of the many possible sources of error is corrected (i.e., use of inconsistent percentages of average daily traffic to represent congested auto travel time), there are still significant errors in the model.

BIASES IN THE WFRC TRAVEL DEMAND MODELS

Induced Travel
Reviews of the literature by leading transportation and environmental professionals in the U.S. have found that the weight of the empirical evidence supports the induced demand hypothesis.

In the National Academy of Sciences/National Research Council report, "Expanding Metropolitan Highways: Implications for Air Quality and Energy Use" (1995), the principle of induced travel is acknowledged:

Highway capacity additions that reduce travel time and the day-to-day variability in travel time will induce increased highway use as long as travel times are shorter and the reliability of motor vehicle time is improved, all else being equal.

Induced travel effects include changes in land development and the location of households and employment, the number of trips made (trip generation), destination choice (trip distribution), mode choice, route choice (traffic assignment), and departure time choice (Transportation Research Board, 1995; Transportation Research Circular, 1998).

The U.S. Environmental Protection Agency (EPA) recently conducted a review of the induced travel literature for their Science Advisory Board and concluded that this research "has not only built a strong case for the existence of induced travel effects, but in some cases suggests that a large fraction of growth in VMT is directly attributed to increases in road capacity" (2000).

One of the difficulties of testing the induced travel hypothesis has been controlling for confounding economic activity variables such as population, income, and other demographic trends. Much of the recent induced travel research, however, has attempted to controll for these variables and has not been able to reject the hypothesis of induced travel (Goodwin, 1996; Hansen and Huang, 1997; Noland and Cowart, 2000; Chu, 2000; Fulton et al., 2000; Noland, 2000). The results of this research have yielded fairly consistent long-term elasticities of VMT with respect to roadway lane miles. See Table 5 below.

Table 5. Long-term elasticities of VMT with respect to roadway lane miles.

 
SOURCEGeographic regionElasticity range
Hansen and Huang, 1997County and metropolitan area 0.3 to 0.7 (county)
0.5 to 0.9 (metropolitan)
Noland and Cowart, 2000Metropolitan area0.8 to 1.0
Fulton et al., 2000County0.5 to 0.8
Noland, 2000State 0.7 to 1.0

Thus, for example, a 10% change in highway lane miles would be expected to result in a 5% to 10% increase in VMT for a metropolitan region in a twenty year time horizon.

As described in the section above, the results of WFRC travel demand model (May 2000) in many cases have negative elasticity of VMT with respect of lane miles and positive elasticity of VMT with respect to travel time. Again, this is inconsistent with travel theory and the evidence for induced travel.

In some cases, however, the elasticity of VMT with respect to lane miles and travel time was consistent with travel theory and the evidence for induced travel. In the cases of the elasticity of VMT with respect to lane miles, the results are consistent with low estimates in the empirical literature. However, the elasticity of VMT with respect to travel time is significantly lower than the figures found in the empirical literature, which reports a range between –0.3 and –1.0.

The latent demand analysis in the FEIS (pg. 1-38) is irrelevant. It is the job of transportation planners to assist in planning for and directing travel demand so that the values and goals of the community can be met in a cost-effective manner. It would be financially impossible and irresponsible to provide unlimited transportation facilities to the community.

The FEIS also suggests that induced demand would not be an important factor in the North Corridor because it is so congestion (pg. 1-38). The theory of induced demand predicts that elasticities will be larger in very congested regions. Thus, the effects of induced demand would be greater in corridors that experience significant congestion.

In sum, the incorrect representation of induced travel in the WFRC travel demand model would result in the underestimation of VMT, emissions, and congestion in the highway alternatives compared to the No build alternative.

Land Use Effects
The National Academy of Sciences/National Research Council (1995) concluded that

Highway capacity additions can improve access to developable land in outlying areas of a metropolitan area. The improved access makes these areas more attractive for future development and influences the location decisions of residents, employers, and shopping facilities. Shifts in the location of residences, jobs, and shopping opportunities affect trip distances and the potential for trips to be made by modes other than the automobile.

A report in the U.K that is equivalent to the above report, Trunk Roads and the Generation of Traffic by the Standing Advisory Committee (SACTRA, 1994), concluded that "the land-use changes consequent on improved access are likely, in turn, to lead to changes in the patterns of travel, car dependence, and the volume of traffic."

The U.S. Environmental Protection Agency (EPA, 2000) recently conducted a review of the literature for their Science Advisory Board. The review cites evidence from Gordon and Richardson (1994):

…various long run effects can have a significant impact on total VMT growth. Long run effects occur due to changes in relative accessibility within an urbanized area and can result in the spatial reallocation of activities. If speeds are higher, many residences and businesses will tend to relocate over time, often resulting in longer distance trips.

All of these reviews cited above were conducted to address the issue of induced travel resulting from new highway capacity expansion. Each review found compelling evidence for induced demand and concluded that the land use and transportation interaction may be a significant contributor to induced travel.

It is also important to note that a U.S. District Court Case in the Chicago, Illinois, region has held that the National Environmental Policy Act requires the consideration of land development changes when a new freeway segment is analyzed in an environmental impact statement (Sierra Club, et al. v. U.S. DOT et al., No. 96 C 4768, U.S. Dist. Ct. for the N. Dist. of Illinois, E. Div., Jan. 16, 1997).

A single set of land use projections is used in the analysis of the alternatives for the FEIS. Because the analysis does not account for the land use and transportation interaction, it would tend to underestimate congestion and VMT in the highway capacity expansion alternative and overestimate congestion and VMT in the no build alternative. The analysis is biased in favor of the highway capacity expansion alternatives. The peer review of the WFRC model recommended that a Delphi Review of land allocations be conducted immediately to develop land use projections specific to transportation alternatives.

In response to our concerns about the land use projections used in the FEIS, UDOT and WFRC officials state that they have spoken to their local planners and that these planners told them that the highway alternatives in the FEIS would not have any land use effects. This position is documented in the FEIS. These officials informed us that they believe that this approximates a Delphi review of land use allocation and is a valid method to assess the land use effects of the proposed highway project.

First, we want to make clear that a Delphi review of land allocations is not the preferred method to represent the land use and transportation interaction. Formal land use models should be applied to evaluate the land use effects of the proposed transportation alternatives. One approach would be to use a land use simulation model, UrbanSim, with a greatly improved WFRC travel demand model. However, this model has not yet been implemented in the region and it is unclear when it will be. Alternatively, an integrated land use and transportation model such as MEPLAN or TRANUS could be used. Both MEPLAN and TRANUS have been implemented in several places in the U.S. and in many places throughout the world. MEPLAN or TRANUS could be calibrated and ready to use in less than six months. Given the magnitude and importance of the decisions at stake, and the amount of time and effort already invested, we believe that it is more than reasonable to apply formal land use models to the analysis of alternatives in the FEIS.

Second, UDOT and WFRC's assertion reflects a misunderstanding of the Delphi review method and of valid scientific methods of inquiry in general. The Delphi review method is described in the National Cooperative Highway Research Program (NCHRP) Report 423A (1999):

Experts provide their judgements about likely future events or the impact of potential transportation investments and programs by responding to several rounds of questionnaires. The Delphi moderator summarizes the results of each round and submits these summaries to the experts for reconsideration of their analysis. In this way the thinking of the experts are shared with each other to either arrive at consensus or clarify differences of opinion.

By definition, the method used to account for the land use effects of the alternatives in the FEIS is not a Delphi review.

Valid scientific inquiry requires the application of systematic methods to the question at issue (in this case, the effect of the transportation alternatives on land use patterns). Such an inquiry should employ valid instruments (e.g., formal interviews or questionnaires) and should allow for replication. The method applied and the results should be well documented. In this way, peers can evaluate the validity of the methods and results based on scientific standards.

The approach used to account for the land use effects of the alternatives in the FEIS fails to meet any of the specified criteria for valid scientific inquiry. The approach employed no replicable instruments (i.e., it used informal questions to officials) and was not documented. Thus, the "results" are invalid.

Officials reviewing the FEIS would not consider the results of informal interviews with local transportation planners as credible evidence of the travel and emissions effects of the proposed alternatives. It is difficult to understand how this could possibly be considered credible evidence of the land use effects of the proposed alternatives.

Methods to Address Land Use Effects and Potential Results
As discussed above, formal land use models should be applied to determine the land use effects of the alternatives in the FEIS. The MEPLAN model has been calibrated in the Sacramento, California, region by researchers at the University of California at Davis and a similar model, TRANUS, has been applied in Oregon, Baltimore, Maryland, and Sacramento. We briefly describe the MEPLAN model and provide the results of a study that suggest the potential significance of the land use effects of highway alternatives.

The basis of the MEPLAN modeling framework is the interaction between two parallel markets, the land market and the transportation market. Behavior in these two markets is a response to price signals that arise from market mechanisms. In the land markets, price and generalized cost (disutility) affect production, consumption, and location decisions by activities. In the transportation markets, money and time costs of travel affect both mode and route selection decisions.

In a recent study, Rodier, Johnston, and Abraham (2000) conduct sensitivity analyses using the Sacramento MEPLAN model to evaluate the potential importance of the land use induced travel effects in the Sacramento, California, region. The model is used to simulate a future base case scenario (low-build) and a beltway scenario for 25- and 50-year time horizons. The study found that the implied elasticity of vehicle miles traveled with respect to lane miles in the Sacramento MEPLAN model compared well to the empirical literature. The study found that the land use effects accounted for approximately half of the elasticity of VMT with respect to lane miles.

As a fair compromise on our part, we suggested that a Delphi review of land allocation be conducted for the alternatives in the FEIS. This is not the preferred option. As stated before, this was also an immediate improvement recommended by the peer review. This is a relatively inexpensive and quick method to account for the land use and transportation interaction.

The NCHRP 423A (1999), Land Use Impacts of Transportation: A Guidebook, provides a good description of the Delphi method and its potential application to evaluate the land use effects of highway alternatives. Our discussion is based largely on this source.

The Delphi review is a systematic method to use expert opinion. The Rand Corporation developed the method for defense purposes in the 1950s. In the 1960s the method was made available to the public, and since then it has been used relatively frequently for the purposes of forecasting and policy analysis.

The Delphi method is generally described as follows:

The Delphi process differs from a panel meeting face-to-face in that participants are anonymous, the process is done iteratively with controlled feedback, and a statistical group response is reported. Anonymity allows participants to focus on the issues, not the personalities of the participants. The repeated rounds with feedback from the moderators allow participants to reconsider their responses in light of new information but prevents lobbying for any point of view. The statistical group response gives the range of opinion as well as the most common response. This helps clarify how strongly people agree or disagree (Linston and Turoff, 1975, Cavelli-Storza, 1982; ctd. NCHRP, 1999).

The Delphi panel should consist of 8 to 12 people who encompass a wide range of opinions on the subject of the land use and transportation interaction (i.e., experts on land use policy and market conditions). More specifically, Bajpai (1990) recommends that the panel include "local government officials, land use and transportation planners, utility company representatives, school district officials, neighborhood and citizen group members, private consultants, academics, and business representatives" (NCHRP, 1999).

The NCHRP report describes many successful applications of the Delphi method by metropolitan planning agencies that are not published in the literature (but contact people are provided). We briefly describe the results of two studies that have been reported in the literature. The first is the a study in San Jose, California, that used the Delphi method to project the land use effects of three transportation alternatives (highway, bus, and rail) (Cavelli-Storza, 1982). The results indicated that the land use effects varied reasonably by alternative (i.e., development was more defused in the highway scenarios compared to the bus and rail scenarios). The second was conducted in Edinburgh, U.K, to examine the land use effects of a road pricing and light rail (Still, 1997). Again, the land use results varied by alternative; however, the variation was small compared to the results of simulations with land use models. This may be explained by the fact that the Delphi method was stopped after the second round because of resource limitations (this was a Ph.D. dissertation project).

Another relatively inexpensive and quick method to address the land use effects of alternatives would be the use of a rule-based urban growth model that runs in geographic information system (or GIS). Such a model can allocate several land uses, according to the user-set rules, and uses commonly available data layers. It permits users to run a variety of scenarios testing policies for new roads or rail lines, urban growth boundaries, and compact growth incentives. Rules could be set using the Delphi method described above. But if they were not, at least the assumptions used in the model to allocate land uses would be applied systematically and described to the public with documentation. This would be a big improvement from WFRC's current method. This type of model has been applied in New Mexico.

The Sierra Club has sponsored the application of such a model (UPLAN) to evaluate the FEIS alternatives. The application of the UPLAN urban growth model in the Salt Lake region showed that future growth in the region tended to locate near existing development and transportation networks. When the proposed Legacy Parkway (South Davis section) was included in the model it showed increased development (approximately 14%) in Southern Davis County (especially near and along the proposed highway alignment).

In sum, there are reasonably available methods to account for the land use and transportation interactions of the proposed alternatives in the FEIS. Moreover, the application of these methods indicates that the land use effects of transportation alternative may be a significant component of travel and emissions analyses.

Auto Ownership and Trip Generation An auto ownership sub-model has been added to the WFRC travel demand model. It was borrowed from Portland, Oregon, and includes an urban design variable, accessibility variables (retail employment within one mile and jobs within 30 minutes of transit access), and other socioeconomic variables (household size, income, and workers per household). However, the accessibility variables are held constant from the No Build to the build alternatives. The revised WFRC model would not represent increased auto trips due to highway project alternatives that reduce the travel time and cost of auto use. As a result, the model would tend to underestimate VMT and emissions and overestimate congestion reduction in the build alternatives.

The peer review committee recommended that the trip generation and trip distribution models for the separate areas of the region be merged. WFRC has merged trip distribution, but it has not merged trip generation. Internal-external trips are not included in feedback from traffic assignment to trip distribution (see discussion below). However, many of these internal-external trips are work trips that should be included in the feedback process. As a result, the model would tend to underestimate VMT, emissions, and congestion from the No Build to the build alternatives.

Trip Distribution
The trip distribution model in the travel demand modeling process requires estimates of travel time in order to estimate the destination of trips. However, travel times depend on the level of congestion on streets in the network. The level of congestion is not known until later model steps are executed (i.e., assignment of traffic on the roadway network). Thus, it is important to feed travel times from the traffic assignment step back to the trip distribution step. This process of recycling travel times once from traffic assignment to trip distribution is commonly called an iteration. Many iterations of a travel model may be required to ensure that the input travel times in trip distribution are consistent with the output travel times from traffic assignment. Modelers must employ criteria to determine when to stop iterating the model. They are called convergence criteria.

The Travel Model Improvement Program's guidance document "Incorporating Feedback in Travel Forecasting" (COMSIS, 1996) recommends and describes several convergence criteria. Some of these include:

  • 5% or less change in average system-wide speeds within an iteration
  • 95% of the functional classes (or roadway types) by area have a change in speeds of 5% or less within an iteration
  • 95% of the links have a change in volumes of 5% or less within an iteration.

The report recommends the use of more than one criterion to determine convergence. Volumes on links and average speeds on links are the two most important variables for determining equilibrium (Stopher, 1993). This is because travel demand models directly relate volume and speed through a functional relationship. Thus, convergence with one of the variables usually implies convergence with another of the variables (Stopher, 1993).

In the U.S., travel modeling studies in the Salt Lake City, Nashville, and Sacramento regions suggest that changes in trip distribution may be a significant effect of induced travel with respect to magnitude of change from the base case and ranking ordering of alternatives (COMSIS, 1996; Johnston and Ceerla, 1996; Rodier, Abraham, and Johnston, 2000). If a travel model is not fully equilibrated on travel times, then its simulations may underestimate VMT and emissions for a transportation plan that includes highway capacity expansions.

The peer review committee recommended that the successive averages approach for convergence be implemented as the feedback mechanism to trip distribution because it is known to consistently converge and it is an efficient feedback method. In this approach, the volumes on each link and each origin destination flow are averaged with previous results.

In the December 1999 WFRC travel demand model, the method of successive averages for feedback was not implemented; instead, the direct method of feedback was used, which is known not always to converge.

The direct method of feedback used in the December 1999 WFRC travel demand model is known not to always converge. We have reported on WFRC's failure to apply formal criteria to determine whether their model has converged (Rodier and Johnston, 1998). We applied several convergence criteria recommended by the Federal Highway Administration's (FHWA) Incorporating Feedback in Travel Forecasting (1996) and found that the model did not meet 2 of 3 convergence criteria (Rodier and Johnston, 1998). FHWA recommends the application of more than one criterion to demonstrate convergence. When a model does not converge, its theoretical validity, and thus its results, are questionable. Convergence of the December 1999 WFRC travel demand model results must be documented to verify their validity.

We have also reported that the direct feedback method has also been incorporated in the WFRC model in an unsystematic fashion (Rodier and Johnston, 1998). The model was programmed to iterate only once; however, this iteration required an input network that contained the results of traffic assignment from a previous model run. This input network could be the product of anywhere between one to four model iterations. If this loaded network is not a product of sufficient runs, then it is likely that the model will not have converged. It is unclear how the feedback mechanism was formalized in the December 1999 WFRC travel demand model. This information must be documented to verify the validity of the results of the December 1999 WFRC travel demand model.

The May 2000 WFRC travel demand model does include the method of successive averages to implement feedback from traffic assignment to trips distribution, as recommended by the peer review. However, the May 2000 WFRC travel demand model does not use AM peak, PM peak, and mid day trip tables to create inputs skims for trip distribution, which was recommended by the peer review committee. To estimate peak period travel times, the revised WFRC model still assigns a daily trip table to the highway network and uses a single peak hour factor, 10% or 12% of average daily traffic, to all links in the region.

In their manual of best modeling practices for metropolitan planning agencies, Harvey and Deakin (1993) state that the use of 12% average daily traffic is a "crude estimate of total bi-directional peak hour travel." Furthermore, "this procedure yields only a rough approximation of link-or corridor-level peaking" and should only be used by smaller MPOs "where the duration and intensity of congestion are limited." Despite this recommendation, WFRC continues to use the 12% factor in a medium-sized region that is using their model for the purpose of addressing growing congestion. Therefore, the use of the 12% factor is clearly not appropriate for use in the revised WFRC model, and AM peak, PM peak, and midday trip tables should be developed.

The use of the crude 10% or 12% factors as congested travel time in trip distribution may be one explanation for the counterintuitive results obtained by the model (described above) and the overly low travel speeds.

Mode Choice
The mode choice model included in the WFRC model set was not used in the evaluation of the alternatives in the FEIS. As a result, average vehicle occupancy is held constant across scenarios. In general, the addition of highway capacity would be expected to decrease average vehicle occupancy because of faster travel times by auto. As a result, the model would tend to underestimate VMT and emissions and overestimate congestion reduction in the build alternatives. The peer review recommended that the mode choice model be included in the WFRC travel demand model for all simulation studies.

Peak-Spreading or Departure-Time-Choice
A peak-spreading or departure-time-choice component is needed in the traffic assignment sub-model to represent how traffic congestion eases and disappears over time. The WFRC travel demand model would currently tend to overestimate congestion in the no build alternative and underestimate it in the build alternative because peak spreading is not represented. A peak-spreading model has been implemented by the San Francisco Bay Area Metropolitan Planning Commission for the Tri-Valley sub-area study. Departure- time-choice models have been implemented in Edmonton, Canada, and in Portland, Oregon.

Summary
In sum, the net effect of the limitations of the WFRC travel demand models would be to underestimate VMT, emissions, and congestion in the highway build scenario compared to no build and transit alternatives. As a result, the analysis of alternatives with the WFRC travel demand model would be biased in favor of the highway alternative and biased against the no build alternative or a transit alternative.

SUMMARY OF TECHNICAL CONCLUSIONS

On July 14, 2000, the Utah Department of Transportation and the Federal Highway Administration approved and issued the Legacy Parkway Final Environmental Impact Statement (FEIS). The FEIS relied on the travel demand forecast made by the Wasatch Regional Council (WFRC) to conclude that the Legacy Parkway highway is needed to meet the future travel demand in the North Corridor.

The authors of this report have reviewed the all the documentation of the Wasatch Front Regional Council (WFRC) travel demand model, the computer files and programs of the WFRC travel demand model, and simulated the FEIS alternatives with the WFRC travel demand model. Based on our reviews and simulations, we have made the following conclusions.

The travel demand forecasts used to determine the need for the proposed Legacy Parkway are critically flawed and unreliable. This conclusion is based on the following findings documented in this report.

  • The regional and corridor forecasts for the alternatives evaluated in the FEIS are inconsistent with the basic economic theory used to develop travel demand models (Ben-Akiva and Lerman, 1985, and Small, 1992). For example, when the supply of travel is increased in the model, speeds decrease and less travel is demanded or speeds increase and less travel is demanded. The results of alternatives must be examined to ensure that the model is producing results that are consistent with the theory upon which they are based.

  • The sub-models within the WFRC travel demand modeling system produce conflicting results about the effect of the highway alternatives on travel speeds and represent different relationships between travel speeds and vehicle miles traveled.

  • The results obtained from the authors' simulations of the FEIS alternatives with the travel demand model that was provided by WFRC are inconsistent with the results documented in the FEIS. It is disturbing that WFRC could not produce a travel demand model capable of replicating the results documented in the FEIS. Moreover, the computer file results from the WFRC simulations that were sent to us are also not consistent with the results documented in the FEIS.

  • The simulation of the FEIS alternatives is confounded. Two versions of the WFRC model are used to forecast future travel demand, one version for the No Build alternative and one version for the I-15 and Legacy Parkway alternatives. It is impossible to determine whether the results obtained for the alternatives are due to differences in the travel demand models or differences in the transportation systems represented in the alternatives.

  • The travel speeds represented in the WFRC travel demand model are inconsistent with the empirical literature and 20-year forecast of regions that are larger than the Salt Lake City region; that is, they are unreasonably low.

The FEIS incorrectly states that the WFRC travel demand models used in the analysis of alternatives meet the immediate term recommendations of the 1999 peer review. Only approximately half of the immediate term recommendations were implemented in the WFRC travel demand models used in the FEIS. As a result, the WFRC travel demand model cannot be characterized as state-of-the-practice.

The WFRC travel demand model is biased in favor of highway alternatives and biased against transit and no build alternatives. The WFRC travel demand model would tend to underestimate vehicle miles of travel (VMT), emissions, and congestion in the highway alternative compared to the no build or transit alternatives for the following reasons.

  • In some cases, the relationships that represent induced travel in the WFRC travel demand model change in the wrong direction; that is, an increase in the supply of transportation facilities decreases the demand for travel.

  • In other cases, when this relationship changes in the correct direction, the magnitude of the change can be characterized as low.

  • A single set of land use projections is used in the analysis of FEIS alternatives. Formal quantitative and qualitative methods are reasonably available (with respect to both time and cost) to project the land use and transportation interaction of the proposed alternatives. Moreover, research findings included in this report suggest that the land use and transportation interaction may be significant for the alternatives evaluated in the FEIS.

  • The WFRC travel demand model does not represent the effect of changes in accessibility among scenarios on auto ownership and thus trip generation rates. As a result, the model would not represent additional non-work trips that may result from the highway alternatives in the FEIS.

  • The WFRC travel demand model uses separate trip generation models for different areas of the region and thus the internal and external trips that are work trips will not be included in the feedback process from traffic assignment to trip distribution. As a result, the WFRC travel demand model would tend to underestimate the length of those auto trips in the highway build alternatives.

  • One version of the WFRC travel demand model uses an unreliable method of feedback of travel times from traffic assignment to trip distribution. As a result, it is possible that auto trip lengths are underestimated in the highway build alternatives.

  • The WFRC travel demand model does not make use of its mode choice model in its evaluation of alternatives and estimation of average vehicle occupancy. As a result, the model would tend to underestimate average vehicle occupancy in the highway build alternatives.

  • The WFRC travel demand model does not represent the tendency of travelers to shift the timing of their trips to the shoulders of the peak traffic period when those periods are congestion. As a result, congestion reduction resulting from the highway build scenarios would be overestimated.

As a result of these serious flaws, we can only conclude that the WFRC travel demand model used to evaluate the alternatives in the FEIS is insufficiently accurate for plan or project analysis, or to properly support the analysis and conclusions in the FEIS.

References:

Bajpai, J. N. (1990). Forecasting Basic Inputs to Transportation Planning at the Zone Level. NCHRP Report 328, Washington, DC, TRB, National Research Council.

Ben-Akiva, M.and S. Lerman (1985) Discrete Choice Analysis. The MIT Press. Cambridge, MA.

Cavalli-Storza, V. and L. M. Ortolano (1984). Delphi forecasts of land use: transportation interactions. Journal of Transportation Engineering, Vol. 110, No. 3, May.

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