Clackamas County’s official response to the Oregon Department of Transportation (ODOT) I-205 Tolling Project Environmental Assessment (EA) describes a wide variety of concerns with both the methodology and conclusions drawn in the EA. The county submitted its 36 pages of comments to ODOT on April 20.
The county’s primary concern is that the project does not plan for how to alleviate (or mitigate) the impact of all the traffic that will shift from I-205 onto county and city roads to avoid the tolls. That jump in local traffic, which the EA acknowledges could be from 30% to 100%, will dramatically decrease safety and increase congestion on many already crowded local roads.
The EA refers to mitigation measures, but they are minimal and inadequate. For example:
- The only mitigation proposed for the Stafford Road/Rosemont Road intersection is to install a rectangular rapid flashing beacon to improve pedestrian crossing, but the entire intersection is projected to be failing by 2027. No measures at all are proposed to mitigate the increased traffic volume.
- Tripling the average daily traffic volume on rural roads such as Borland Road will create conditions that reduce safety and double the likelihood of crashes. Even so, there are no mitigation measures proposed to address this impact.
- Tolling I-205 is expected to add more than 3,000 vehicles a day to the rural Arndt Road –the equivalent of 10 years’ worth of traffic growth without tolling. Again, there are no mitigation measures proposed to address this dramatic increase.
And even the inadequate mitigation measures that are proposed are unlikely to be in place when tolling is scheduled to begin in late 2024 because there is not enough time to put them in place.
Other county concerns include:
- Higher levels of stress for people walking and rolling along local roadways due to increased traffic;
- Decreased access to local businesses in congested, unsafe conditions;
- No decrease in greenhouse gas emissions, contrary to what is stated in the project, because there are no area alternatives to driving (like transit) and people will be driving longer routes on local roads to avoid paying the toll;
- Severe impacts especially to low-income residents and other communities of concern who will either have to somehow pay the toll or travel on more congested, less safe local routes;
- Significant aspects of the environmental review only covered areas within 100 feet of I-205, which means there was no analysis of impacts to important nearby places such as the historic Arch Bridge in Oregon City;
- There has been no analysis of the cumulative impact of I-205 tolling along with the Regional Mobility Pricing Project (RMPP), ODOT’s next tolling project to toll all lanes on I-5 and I-205 in the Portland metropolitan area.
The EA is the federal environmental review process that ODOT is required to complete before the agency can implement its plans to toll the I-205 Abernethy and Tualatin River bridges in Clackamas County beginning in late 2024. A successful EA results in a Finding of No Significant Impact (FONSI) from the Federal Highway Administration (FHWA).
In consideration of the many deficiencies and negative impacts of the project reflected or omitted from the EA, Clackamas County is requesting that:
- FHWA not issue a Finding of No Significant Impact (FONSI) for this project; and
- FHWA direct ODOT to develop an Environmental Impact Statement (EIS) for this project, combined with the RMPP, to analyze the impacts of both tolling projects and provide meaningful opportunities for public engagement.
Along with the 36 pages of comments the county submitted to the state, more information on Clackamas County efforts to respond to the proposed tolling plan is available on the county web page on ODOT's proposed tolling.