FHWA Comments on Discredited EPA
Smart Growth & Transport Report
"Scoop" by Toll Roads News

Re: Characteristics and Performance of Regional Transportation Systems

Also see: EPA Explanation

and EPA Withdraws Inaccurate Traffic/Smart Growth Report Early in 2004, the Environmental Protection Agency issued a report on urban transport and smart growth that was so poorly researched that agency leadership withdrew the report due to criticism from the US Department of Transportation Federal Highway Administration. Problems with the report are outlined in the FHWA comments below ("scooped" by Peter Samuel of Toll Roads News).

Full text of FHWA comments obtained by Toll Roads News

* The report defines desirable transportation performance in narrow, incomplete, and modally biased terms, without regard to the views of US DOT, the Federal agency with purview for national transportation policy.

* EPA's criteria for desirable transportation performance, which are at the core of the analysis, appear to have been selected to serve a limited set of national policy goals to the exclusion of broad, balanced national transportation and environmental policy. EPA focuses on personal travel (to the exclusion of freight), defines slow speed (less than 25mph) as a positive attribute of the transportation system, ignores the performance attributes for a transportation system that serves the national and regional economies, and fails to consider the need to move large numbers of people and goods among multiple origins and destinations 24 hours a day.

Data and Methodology Problems

* The report uses data which are wrong/inappropriately applied or inappropriate statistical techniques. EPA was aware of some of the data problems, and identified them in their July 2003 briefing. Since FHWA has seen the final report, we have identified additional data problems. As one example, EPA does not appear to be aware of the impact of the differences between planning area data and urbanized area data. There is no 'fix' to the data defects, other than to redefine the data inputs, rerun the analysis, and reexamine the conclusions.

* The methodology defines improved system performance as a decrease in vehicle movement and ignores how well the system meets passenger and freight demand. Essential variables are not considered - such as the differing rates of population growth of the 13 cities examined.

* There is a striking difference in the growth rates and economic vitality of the cities that EPA characterizes as high performing (Erie, Pittsburgh, New Orleans, and Philadelphia) vs those described as low performing (Charlotte, Nashville, Atlanta, and Houston). Yet when reviewers urged EPA to factor growth rates into the analysis as a variable, EPA responded 'We do not believe the rate of growth is a major factor influencing transportation system performance - we do not feel it necessary to control for growth rate.'

* Outside reviewers urged EPA to improve the methodology and expand the scope of analysis, but EPA did not do so, citing cost limitations. Yet 3 years ago, FHWA sought to undertake joint research with EPA about transportation performance; EPA initially committed $300,000 to the effort, but then pulled its funding. FHWA still would like to undertake joint research with EPA on transportation performance, at the level of funding that would be necessary for meaningful analysis.

Presentation of Conclusions

* The body of the report talks about uncertainty and the preliminary nature of the results, that more research is needed, etc. As the report moves to conclusions and the executive summary the research and uncertainty aspects are deemphasized.

* In the EPA briefing to DOT regarding this project in July 2003, the study was discussed in terms of 'exploratory' research, that more research was needed.

* Yet EPA has chosen to make wide distribution of the report, highlighting findings that that have insufficient analytical basis, such as "These results suggest that regions with more characteristics of a smart growth transportation system experience more efficient vehicle travel and modest improvements in traffic congestion."

Review Process

* Given the policy implications of the report, and the wide dissemination of the report by EPA, DOT believes EPA should have coordinated at a higher level with DOT - not first-line, technical staff. FHWA technical staff were also remiss in failing to understand the policy significance of the report and many of the underlying flaws in assumptions about transportation performance.

* EPA lists a Peer Review Panel in the published report, but it does not appear that the review process meets EPA's own published standards for Peer Reviews Reference: EPA Peer Review Handbook, 2nd Edition, December 2000) or peer review standards articulated by OMB and the National Academy of Sciences.

* EPA did not ask permission to use Mike Culp's name in the report, nor permission to cite FHWA." ends FHWA comments on CAPORTS

Neither the report nor the FHWA comments are available publicly at present. We have a scoop! TOLLROADSnews 2004-05-15

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