Getting Involved in Transportation Planning

Transportation planning in each state and metropolitan area sets priorities for projects to be funded, determines how much money will go to transit vs. roads, and sets standards that will determine how your community's mobility for decades to come. The participation of mobility advocates in this planning process can make the difference between a mobile future or one in which the region is stuck in traffic.

Unfortunately, transportation planning has become a bewildering array of plans, such as the state implementation plan, long-range transportation plan, and transportation improvement plan; acronyms, such as MPO, CAAA, NAAQS, CMS, MIS, FONSI, and ROD; and agencies, including the EPA, FHwA, FTA, state agencies, metropolitan planning agencies, transit agencies, and county and city road departments. This makes it difficult for anyone other than professional lobbyists to get involved in the process. This paper will identify key points in the planning process where mobility advocates can have the greatest influence:

The Planning Process

State and regional transportation planning must follow a process established by Congress. As designed, this process has given anti-auto forces numerous opportunities to bias planning in their favor. In many cities, mobility advocates face an uphill job in reaching their goals and objectives.

Metropolitan Planning Organizations

Initially, the federal government required only that planning be done by a metropolitan planning organization (MPO) whose board members represented all of the people in an urban area. Every urban area with an overall population of 50,000 people or more must have a metropolitan planning organization, and some 400 such organizations exist.

The purpose of the MPOs was to locally determine the distribution of funds among cities and counties in each urban area. However, under pressure from people who favored regional land-use planning, several metropolitan planning organizations have gained significantly greater powers than just the distribution of federal funds.

Planning for Air Quality

The Clean Air Act Amendments of 1977 first tied transportation planning to the attainment of national air quality standards. However, the act did not define the planning process in detail. That was left for the Clean Air Act Amendments of 1990 and 1991 Intermodal Surface Transportation Efficiency Act (ISTEA).

The 1990 clean air amendments required each state to prepare a state implementation plan (SIP) describing how the state will improve or maintain its air quality. States with serious air pollution problems were required to develop plans to improve their air quality while states with marginal or no problems were required to maintain air quality.

Air pollution may come from major stationary sources, such as power plants; minor stationary sources (also called area sources), such as dry cleaners; and mobile sources, including cars, airplanes, and lawn mowers. The state implementation plan sets pollution reduction targets for each of these categories. Pollution may be traded off between categories, so if a major stationary source can easily clean its emissions, it might be possible to raise the targets for mobile sources.

The highest level of emissions allowed from mobile sources is called the emissions budget. Particularly in polluted regions, this budget becomes a major factor in the long-range transportation planning process.

Planning under ISTEA

The 1991 Intermodal Surface Transportation Efficiency Act (ISTEA) established a detailed transportation planning process that every state and urban area must follow to receive federal funds. Transportation planning and funding was tied to air quality standards, and regions with poor air quality had to go through more steps and had less flexibility in how they spent federal dollars. A number of modifications to ISTEA's planning were made by the 1998 Transportation Efficiency Act for the Twenty-First Century (TEA-21).

ISTEA and TEA-21 require both states and metropolitan areas to prepare two types of plans. The long-range transportation plans have a twenty-year planning horizon and identify major road, transit, and other transportation improvements needed during that time. The plan must be constrained by available funding, though it may be accompanied by an alternative, unconstrained or "visionary" plan that shows any additional facilities and services that could benefit the region.

The transportation improvement programs (TIP) have a three- to six-year planning horizon and detail exactly which projects are proposed for federal funding during each of those three years. The long-range plans must be revised at least every five years and the transportation improvement programs must be revised at least every two years.

The total pollution generated by all of the projects in the long-range plan must be within the state or region's emissions budget. Federal funds will be withheld if the state and metropolitan planning organization cannot show that their plans will meet the state implementation plan targets. This is called the conformity process: The metropolitan planning organization, state governor, Environmental Protection Agency, and secretary of transportation must all agree that transportation plans conform with air quality plans.

State and regional planners must coordinate with each other and consult members of the public. In particular, the law specifically states that "freight shippers, providers of freight transportation services, private providers of transportation, representatives of users of public transit, and other interested parties" must be given opportunities to comment on regional plans.

TEA-21 "streamlines" the ISTEA planning process by excluding the long-range and transportation improvement plans from the need to write environmental impact statements or, indeed, much judicial review under any federal law other than the Clean Air Act. Plans can be challenged for failing to meet air quality standards, but not for failing to meet the mobility needs of the people in the region.

Planning doesn't stop with the transportation improvement plan. Any major improvement called for by the plan, such as a new highway or adding new lanes to an existing highway, requires a project planning study. This study must consider alternatives and be accompanied by an environmental assessment. The assessment determine whether the project is a major federal action significantly affecting the environment; if it is, then draft and final environmental impact statements must be written.

Many states have additional planning requirements. For example, Oregon requires all major cities to write transportation plans that aim to reduce per capita driving by 20 percent. Most state planning rules are less draconian, but some states may have appeal procedures that allow citizens to challenge plans on grounds, such as mobility and congestion reduction, that the federal government would ignore.

Implementation and Monitoring

Actual projects are carried out and funds spent by state, county, or city transportation departments or transit agencies. However, ISTEA requires states and metropolitan planning organizations to develop several management systems for monitoring transportation assets and performance. States are to monitor pavement, bridge, and public transit assets as well as intermodal and safety performance. Metropolitan planning organizations are to monitor congestion.

The congestion management system is particularly important in urban areas with air quality problems. Such areas may not use federal funds on any new project that increases road capacities for single-occupant vehicles unless the project results from the congestion management system.

The congestion management system should both monitor congestion and identify ways to reduce congestion. The system should consider such strategies as high-occupancy vehicle lanes, value pricing (aka congestion pricing), growth management, travel demand management, transit improvements, and even adding new general purpose lanes to highways.

Problems with the Planning Process

Debate over federal transportation legislation will begin again in 2003. While Congress is not likely to change the transportation planning process until then, it is worth reviewing some of the problems in that process.

First, the process is extremely expensive and time-consuming. Indeed, auto-hostile groups may consider this a virtue, since time and money spent on planning will not be available to spend on road construction.

Second, the overriding role of air quality is misplaced. While clean air is important, so are mobility, economic efficiency, and many other goals. Cities and states should be allowed to consider trade offs between all their goals, not just some of them.

Third, several mandatory parts of the process are inefficient. For example, Congress requires cities with certain levels of air pollution to adopt expensive programs that studies have shown do not clean the air. These mandates should be removed.

Fourth, although the law gives plenty of ink to public involvement, in fact few members of the public will bother to get involved in any step other than studies of major projects. This means that the "public involvement" in a wide range of major decisions will mainly be the involvement of full-time lobbyists.

Finally, though the process also gives lip service to evaluating trade offs, in fact few state or regional long-range plans bother to evaluate any alternatives but the two required by ISTEA: the visionary alternative and the financially constrained alternative. Thus, major decisions are made without the benefit of evaluating whether other alternatives would result in less air pollution or greater benefits to urban residents.

Getting Involved in Planning

Given unlimited resources, mobility advocates should attempt to influence every stage in the planning process (table one). Most mobility groups, however, will not have the resources for such comprehensive coverage. Their efforts will be most effective if concentrated on three steps of the planning process: the regional transportation plan, major project studies, and the congestion management system.

Whenever possible, mobility advocates should seek multiple objectives when working on public involvement efforts. The most obvious objective is to influence the planning agencies. However, an equally important objective is to educate the public, which can be done by using public involvement, report writing, testimony, and similar steps to get media access. Public involvement can also be an organizing tool because it is easy to mobilize people around letter-writing campaigns, hearings, and related efforts.

For example, metropolitan planning organization boards generally include a period for public comment during each meeting. But merely offering dissenting comments at meeting after meeting can be time-consuming, frustrating, and fruitless. Instead, use such times to organize neighborhood residents to come and speak out for the protection of their neighborhood values. Having testified, the residents will be more likely to participate in planning efforts later.

Table One
The Transportation Planning Hierarchy

Long-Range Regional Transportation Plan

The long-range regional transportation plans make most of the crucial decisions about a region's future mobility (in rough order of importance):

Mobility advocates should attempt to influence all of these decisions. One of the most important things they can do, however, is insist that a wide range of alternatives be considered in the evaluation process. At minimum, three alternatives should be considered:

Federal agencies and most states have appeals processes that precede court challenges and do not require the expense of a law suit. Mobility advocates should consider appealing unsatisfactory long-range plans on one of several grounds:

The last claim is the only one that might succeed at the federal level, but any of them might succeed at the state level. Even if an appeal is doomed to fail, it is sometimes worth making because of the value for publicity and public education.

Outside of Portland and Atlanta, few regional planning agencies have the power to enforce land-use plans on the entire region. But many can withhold federal and state transportation funds from local communities that refuse to cooperate, as is being done in the Twin Cities. Thus, the planning process is important for both transportation and land uses.

Project Planning Studies

ISTEA required state or regional planning agencies to do a major investment study for important projects, such as highways or rail transit construction, for which they wanted federal funding. This particular requirement was removed from TEA-21, but agencies still have to write environmental impact statements for such projects. They may call these statements corridor studies or project planning studies or some similar name. This paper will call them major project studies.

Regional planning agencies usually do a major project study only when they have already determined to do a particular project. Yet the study gives mobility advocates the greatest opportunities to block wasteful projects such as rail transit programs. This is both because such studies receive more public attention and because they are subject to more citizen challenges than the long-range studies.

Agencies must write environmental impact statements for major projects that significantly affect the environment. Small projects, such as the construction of bike lanes, are excluded from this requirement.

For some projects, such as short extensions of existing rail lines, agencies may try to avoid the publicity and expense of writing an environmental impact statement. In this case, the lead federal agency must sign a "finding of no significant impact" (FONSI), saying that no environmental impact statement is needed. This decision can and should be appealed to try to force the agency to write an environmental impact statement.

If they do write an environmental impact statement, agencies may either:

Since the environmental impact statement is the part that the public sees and that receives the most publicity, mobility advocates should press hard to insure that agencies take the second option: simultaneous writing of the project study and environmental impact statement. Otherwise, the alternatives presented in the environmental impact statement are likely to be "straw men" ­­ designed only to make the agency's preferred alternative look good.

It is in the alternative comparison that the computer models developed during the long-range planning process become important. If the planning agency has a smart-growth agenda, it is likely to want models that exaggerate the effects of land-use planning, major transit investments, and other mobility restrictions on air quality and congestion.

Even if you lack the expertise to analyze transportation computer models, you can insist that the assumptions behind the models be made public. Models are more likely to be objective if they are based on census data, U.S. Department of Transportation data, or other real, observed data. Models are probably biased if they make up data out of thin air or if they assume:

While there are many opportunities to cook the books, most major project studies for such projects report that rail transit and land-use planning have insignificant effects on pollution and congestion. Yet the agencies writing the plans nevertheless propose to implement them and often claim they will significantly reduce pollution and congestion when their own data say otherwise. In such cases, mobility advocates will be more successful publicizing the agency's own result rather than challenging them.

Congestion Management System

Work on a region's congestion management system will be the least exciting part of the planning process since it is the least publicized and least likely to produce short-term results. Yet the data collected by the congestion management system feeds back into updates of the regional transportation plans, so the data collected and accuracy of that data will be especially important in the long run.

One danger is that agencies may collect the wrong sort of data. For example, they should, "what are the effects of various strategies on congestion and air pollution?" Instead, they may ask, "what are the effects of various strategies on vehicle-miles traveled?" Since many other factors influence congestion and air pollution, a focus on vehicle-miles traveled will produce misleading results.

A related danger is that planning agencies might emphasize travel-reduction strategies to the exclusion of congestion-reduction strategies such as improved traffic signals or capacity expansions. Mobility advocates should work to insure that a full range of data and strategies are considered.

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