The Impending Conflict over the Oklahoma City Boulevard Represents a Cultural Paradigm Shift

The impending conflict over the Oklahoma City Boulevard is far-reaching both in terms of cause and consequence.  When Steve Lackmeyer, in his coverage of the Boulevard in the Oklahoman, makes reference to “cars vs. people’, he is referencing the growing realization among Oklahoma City citizenry that we have largely built the infrastructure for the city for the benefit of the automobile and that fostering economic development and community-building requires more complete design based on the scale of the human being. What is likely to be expressed in the near future is that the citizenry of OKC (and their elected officials), like those of many other American cities, will resist being marginalized, or altogether excluded, as government agencies create large-scale urban infrastructure projects which seek at times to focus solely on automobile traffic volumes.

Multiple cities across the country and world have benefitted from the teardown of above-grade urban highways and replacement with at-grade boulevards, which resulted in tremendous economic development in the area as a result. The notion that the Oklahoma Department of Transportation would tear down the elevated I-40, move it slightly to the south, and then place a new elevated expressway through a sizeable portion of the area of the old I-40 (leading some to say we will have obtained two new highways for the price of three) threatens to preclude any such economic and communal benefit. The notion that to save right-of-way costs state engineers are planning a zigzag entrance off the Boulevard into Bricktown is stunning and further elucidates the degree of disconnect between ODOT officials and urban planners.

Roughly 100 years ago an untested yet pervasive experiment began to unfold across the world as urban freeways consisting of limited access points (to minimize disruptions) were utilized to maximize flow in and out of downtown and urban centers. In 1922, Henry Ford stated “we shall solve the problem of the city by leaving the city.” Fifty years ago, Jane Jacobs wrote in her seminal work, The Death and Life of American Cities, “Expressways eviscerate cities.”  Over the ensuing five decades, in city after American city, an increasing awareness has taken place in relation to the unintended consequences of urban highways including land use impacts, the severing of urban centers and communities, the loss of economic development opportunities and the suppression of property values, and the public health consequence of subsidization of the automobile over development of alternate modes of travel such as public transit, bicycling and walking.

Likewise, urban streets, which have more lanes than daily traffic counts would warrant and which make no accommodations for street level development, navigation by bicyclists and pedestrians, or public transit, are destined to work against the development of community. Perhaps no street in Oklahoma City epitomizes the adverse effects of focusing solely on moving maximum amounts of traffic to the exclusion of all else more than E.K. Gaylord. To witness the most tragic aspect of the street’s design I would invite the reader to observe downtown workers who exit through the Sante Fe Parking Garage and then dart across seven lanes of traffic at rush hour to make their way to the Bricktown surface parking lot on Main.

In 2009, Jeff Speck was hired to study downtown streets and walkability and stated:

Observing Oklahoma City’s street network, a planner has to ask how such a (relatively) low density of development has produced such a huge volume of traffic as to require so many lanes.  The answer is that it hasn’t.  There is not too much traffic in Oklahoma City.  Rather, there is too much roadway for the traffic it contains.  It is a general rule of thumb in city planning that a two-lane roadway (without left-hand turn lanes) can comfortably handle 10,000 cars per day. Based on this measure, one would expect Average Daily Traffic volumes (ADTs) along most Oklahoma City streets to be in the 15,000 – 25,000 range, given the four to six lanes that have been provided for its movement.

Taxpayer dollars are a finite resource and their utilization must be rigorously questioned especially in regards to the development of our roads in which system-wide needs are so great. The obsession with moving maximum traffic volumes and preventing perceived congestion (even with vehicle per day counts in the 2-4 thousand) reached its most perplexing with the decision to allocate roughly $3 million per mile from the 2007 GOLT Bonds to widen essentially all the roads from 164th to the city line and from Portland to Western.

The contrast between a street such as EK Gaylord and “complete streets” or “better blocks” projects could not be more evident. Efforts, which deploy “traffic calming” measures, make the pedestrian feel safe and more likely to walk. Two-way traffic, narrower lane widths and roundabouts are all associated with decreased traffic speeds.  Suburban Nation authors Jeff Speck and Andres Duany define “Complete Streets”, (which should be our goal for the Boulevard) in the following discussion:

For some 60 years now, most American streets have been designed with the sole objective of moving cars. As a result, pedestrian and bicycle use has declined, as has the viability of closely enfronting urban buildings. In addition to being traffic conduits, streets are public spaces and perhaps the primary location of American civic life. Thoroughfares other than highways-especially streets within neighborhoods-should be designed as places of gathering. This requires the interdisciplinary participation of engineers, planners, architects, landscape architects, and utility companies. The resulting thoroughfares will typically provide narrow (slower-speed) travel lanes, bicycle facilities, on-street parking, continuous tree cover, ample sidewalks, appropriate street furniture and lighting, as well as supportive building frontages.

Roughly ten years ago, Oklahoma City was approached by ODOT (Oklahoma Department of Transportation) and informed that the I-40 crosstown would need to be relocated. As a mitigation step, a “Boulevard” would be built in the right of way where the I-40 used to be. Although there was public discussion over the ensuing years, particularly when it became clear that ODOT would not make accommodations for the extensive network of existing rail lines running into Union Station, a central theme of the process was that consensus opinions of the OKC Council and citizenry were rejected by ODOT. Summarizing her frustration, Ann Simank protested to council during a meeting on July 15th, 2008:

I know that this City and many of the downtown leaders and the Chamber and everyone that we worked with tried to work together…we didn’t want the route…and we were very limited in our decisions and in fact this was driven by the State…this was driven by ODOT…where this present location is going, you need to take up those issues with ODOT…that’s how I feel about it and that’s my experience of being on this City Council during the time that we were involved with ODOT working together to hold community and public meetings…the meetings were held at the Civic Center…they were held at the Convention Center…they were held out in the neighborhoods…and the citizens came…but the City had very little control…we were not the decision makers on what route was chosen for us…so what we did…we got together as a City with vision will do and tried to make lemonade out of lemons, in a way, in my opinion…and we decided that we would mitigate our losses here and we would try to go for a boulevard where the existing interstate was because this City wanted to the new interstate to be at the existing location …we didn’t really endorse the route…the present location

It is difficult to underestimate the impact on the nature of future OKC downtown development arising from ODOT’s decision to relocate the I-40 to a location over the objections of the OKC Council (who voted for an alternate route) and a sizeable number of citizens. The construction of the Boulevard, the Core to Shore Plan, and the eventual MAPS 3 projects are a result of what Ms. Simank calls, the City trying “to make lemonades out of lemons.”  As OKC struggles to create a regional transit system, countless citizens, community leaders and politicians are left scratching their head at ODOT’s shortsighted decision to remove so much existing rail line during the I-40 relocation, particularly the direct southwest connection of rail between downtown and the airport region.

Recent revelations regarding the nature of ODOT’s plans for the Boulevard are opening a collective wound regarding the marginalization of taxpayer and urban planning input towards a project with far reaching implications beyond traffic movement. While the I-40 relocation was marketed to the people of OKC and the nation as the replacement of an urban highway with a “old-fashioned boulevard” (http://www.usatoday.com/news/nation/2008-05-14-highways_N.htm?POE=click-refer) , it has very recently become clear that ODOT intends to limit the at-grade portion of the Boulevard (and therefore the only portion which could accommodate and foster retail and economic development, pedestrian activity and “complete growth” to the portion between Lee and roughly Shields. The intersection with Western, Classen and Reno would all be bypassed by a multilane bridge built on a dirt embankment with the goal being to quickly reach 45 mph traffic flow and minimize disruption from any intersections. In other words, development west of Lee has been forsaken for the singular goal of moving as many cars as possible through a limited access point to an entry into I-40.

By force-fitting what is essentially a limited-access freeway into our urban environment, ODOT is creating a permanent barrier to development of the city’s network as many nearby surface streets are cut off from one another and congestion actually intensifies during rush hours as cars wait in queues to enter limited points of access to the freeway.

The experience in many cities across the nation and world would suggest that replacement of an elevated highway with an at-grade street network would lead to a marked increase in the area’s economic development and property values.  Removal of Portland’s Harbor Drive highway and San Francisco’s Embarcadero Freeway and replacement with a waterfront and at-grade boulevard respectively, led to more than 300% rise in property values in adjacent neighborhoods and a dramatic increase in development. New York City, Chattanooga, Milwaukee, Octavia, Seoul are additional examples of cities replacing urban highways with at grade development projects.

One of the central arguments against placing the new MAPS-3 financed convention center on the North side of the Boulevard between the Myriad Gardens and the new Core-to Shore Park is that some of the most developable land bordering the Boulevard in terms of retail and pedestrian activity will be supplanted.  While efforts are underway to perhaps move the Boulevard within the right of way to the south in order to have retail activity on convention center’s southern boundary, the capturing of additional land from Lee to as far west as Douglas would dramatically increase options for development. One might expect resistance to this concept from advocates of focusing development in the area of the Central Park and convention center.

I first became aware that the Boulevard would be an elevated expressway when I listened to the presentation given by ODOT representative Paul Green in late May 2012 to the MAPS-3 convention center and transit subcommittees. Development along the Boulevard and how the Boulevard might interface with the existing downtown and future MAPS projects (especially the streetcar system) was curiously absent from the discussion. Mr. Green was unaccompanied by anyone from the rail division of ODOT when addressing the transit subcommittee and indicated that he was not aware that the new $120 million streetcar would run on rail (which would need to be incorporated into the Boulevard) or run on electricity. Furthermore, indication that ODOT was incorporating the findings of the City’s intermodal transit hub study (as part of MAPS3 the city is trying to build an intermodal hub at the Sante Fe Station on EK Gaylord where different modes of transportation such as the streetcar, buses, cars, trains, bicyclists and pedestrians can all converge) into its Boulevard design was lacking. The study indicates that for future rail expansion additional lines will be needed. Since the Boulevard runs below grade to run underneath the bridge containing the rail lines, future expansion must be planned for now in terms of when the Boulevard begins to go below grade (to allow for widened platforms the Boulevard would need to begin its below grade descent further east and west from the rail lines).

The notion that the Boulevard would enter Bricktown on Compress Ave as opposed to Oklahoma Ave. (which was apparently shown in previous video renderings by ODOT) is unacceptable on any level and raises serious questions about the process. ODOT’s contention that it does not own the right-of-way and therefore cannot be expected to have the Boulevard enter Bricktown on Oklahoma Ave due to cost is difficult to process given that we have never seen an itemized budget of how the $85 million is going to be spent. What priorities would override having to take three turns to get into Bricktown and making it difficult to go below grade fast enough to accommodate future expansion of rail?

Whether or not some reference was made buried in documents of an elevated roadway west of Lee, it is clear that the process has not met what should be minimum standards of transparency and city council/public deliberation.  There have been no public meetings or presentations by ODOT to the Council in a number of years and certainly not since two new members were elected to the Council last year. There have been no private presentations of Boulevard design to Council members of which I am aware. Clearly, almost the entirety of the Council, the public, and the media were surprised by revelations that the Boulevard would enter Bricktown on Compress Ave and would be elevated west of Lee.

An additional consequence of the lack of public vetting of design options on the Boulevard is that the process may run afoul of the NEPA process and incur the intervention of the Federal Highway Administration. I have asked the Municipal Councilor to issue a white paper on the subject and am told the process will take approximately two weeks. As explained recently by Marion Hutchinson on the blog OKC Talk:

     “The problem they face is that while they undertook extensive reviews and strictly adhered to NEPA with respect to the Crosstown relocation portion of the project, they barely mentioned the Boulevard in the EIS, and when they did it was only in very general terms.
     Any major federal action (includes any state action involving federal money) that has the potential to affect the human environment (not just noise, air, water pollution...historical, cultural, social, business and other impacts are also included) must strictly comply with the National Environmental Policy Act (NEPA), which requires certain environmental reviews, documention and public input. Those may be in the form of an Environmental Assessment (more general and less time consuming) or an Environmental Impact Statement (more extensive), depending on the nature of the action. Most large highway and road projects, especially in heavily populated areas, requires an EIS, which is what ODOT conducted for the Crosstown.
     NEPA has several very important fundamental rules and requirements for properly conducting EA's and EIS's.

1) The agency creating the action to be reviewed under NEPA must not pre-judge the outcome and predetermine an alternative.
2) The agency must develop a reasonable range of alternatives to be reviewed and considered.
3) The agency must seek public comment on its review of the alternatives and seriously consider that input as part of its decision-making process.

     The problem for ODOT with regard to the Boulevard is that they tried to slip it under the Crosstown EIS rug and failed to adequately meet NEPA requirements. The $80 million Boulevard project is a major federal action in and to itself. As such, ODOT should have prepared a separate EA or EIS for the Boulevard which reviewed a reasonable range of alternatives and provided for public review and input regarding those alternatives prior to selecting a final preferred alternative. Unfortunately, ODOT did not do that. Instead, they treated the project as a simple mitigation action related to the Crosstown project and failed to develop and review a range of alternatives specific to the Boulevard for public review and comment. To make matters worse, they are now publicly stating that they have not completed a design for the Boulevard and are just now considering various alternatives. If they had properly conformed to NEPA, the various alternatives would have been reviewed already with adequate public scoping and comments and a preferred alternative would have already been selected.”

The recent (July 12th, 2012) formal response to an inquiry from the FHWA raises concerns especially in regards to their asking ODOT to have a public meeting at this stage in the process:

The FHWA has not yet made a determination as to the level of environmental studies and public involvement required for the Boulevard portion of the I-40 Relocation Project.  We have requested that ODOT provide us an assessment of the social and environmental impacts associated with the project.  As part of their assessment, we have asked ODOT to hold a public meeting to present what is currently being proposed and to seek public input.   When this public outreach and analysis is completed, and the information received, FHWA will make its determination as to the level of environmental documentation for the Boulevard based on the specific impacts identified, their context and intensity, public input, and other factors.

We hope that you will take advantage of this public meeting and provide your recommendations for the ultimate design for this important part of Oklahoma City’s transportation network.

Initial public statements from ODOT have been disheartening in that they resemble efforts at attempting to stifle debate and resistance. Consider the statement from ODOT state deputy highway department director Gary Evans

to Assistant City Manager Dennis Clowers, that a roundabout in the area of Western, Classen and Reno, of which no study has taken place, “would add multiple years and tens of millions of dollars of cost to the project and delay the completion of the reconnection of downtown Oklahoma City to the Interstate. The additional cost would not be funded through ODOT.” While ODOT is unwilling to pay for costs associated with the study of alternatives, they are currently paying incentives to contractors for accelerated demolition of the old I-40. Let’s use a rough estimate of $25 million for the embankment, retaining walls, and bridge structure for the proposed Western, Classen and Reno overpass; a roundabout or alternative at-grade solution would costs tens of millions more than $25 million and take multiple years to design and build? ODOT has raised additional concerns in relation to massive vehicle per day counts (up to 94,000 per day by one account) of which would overwhelm a roundabout. Two-lane roundabouts can handle upwards of 45,000 VPD counts and it is unlikely that the Boulevard would see anything of this sort of VPD counts of which would approximate that of the new I-40. The public dispersal of information of which is potentially inaccurate only intensifies the argument that there is a clear and convincing need for maximum transparency, and participation and deliberation by the public and their elected officials.

The implications of the debate regarding the Boulevard reach far beyond the Boulevard itself. The process of informing the public and its elected officials along with the public vetting of the risks/benefits of alternative proposals in relation to massive infrastructure projects is flawed. Some of the decisions being discussed in recent days are clearly policy decisions. Policy decisions are the exclusive domain of the city’s elected officials (the Mayor and City Councilors). Without an objective assessment of the viability and risks/benefits of alternative designs, the Council is unable to make good policy decisions for its citizens.

In terms of urban planning for our city, one principal guides me as much as any other: one gets more of the behavior for which we design. If a city builds more bicycle trails, it will get more bicyclists riding longer distances. If one builds complete streets and sidewalks which facilitate pedestrian activity, the city will see an increase in the number of people walking the estimated 10,000 steps a day which we all need. If the City exhibits tunnel vision and focuses almost exclusively on moving the greatest number of vehicles through limited access points, it will not only get more people driving automobiles through the type of congestion it sets out to solve, but we will limit our economic development potential and the ability to create that which we all so innately crave; the development of community.