A breakdown of the evaluation criteria and murky metrics used to justify the removal of boulevard options for Rethinking I-94
The Minnesota Department of Transportation (MnDOT) recently confirmed they plan to remove at-grade boulevard options from their Rethinking I-94 process. The Department intends to proceed exclusively with options that rebuild the freeway.
MnDOT commented on this decision in the Star Tribune, saying the two boulevard options “do not meet the goals for enhancing mobility, safety and connectivity.”
We obtained MnDOT’s initial scoring for the ten Rethinking I-94 project alternatives. We also obtained MnDOT’s internal talking points regarding this decision.
To those familiar with the Twin Cities Boulevard movement, this might come as a surprise. After all, these same issues form many of the core arguments for converting I-94 into a community boulevard. A boulevard conversion would enhance mobility (less traffic and improved transit, walking and biking access), safety (safer traffic speeds, safer sidewalks, protected bike paths, less pollution) and connectivity (neighborhoods would literally be reconnected).
How is it possible for MnDOT to use these same metrics to justify removing the boulevard options from further consideration in the Rethinking I-94 process? The truth is that MnDOT is using the same playbook used by departments of transportation across the country to justify the building and expansion of highways. Evidence from similar boulevard conversion projects has demonstrated reduced pollution, increased economic development, and minimal traffic impacts. Given these successful precedents, a boulevard solution for I-94 would likely yield similar positive outcomes for our community.
Highway planners often use opaque processes with little accountability to justify projects that never achieve their promised benefits and severely harm surrounding communities. Here are the fallacies of the metrics, assumptions and talking points used by MnDOT and discuss the reasons why the Twin Cities Boulevard is the best path to achieving those goals.
The EIS Process can be easily manipulated by MnDOT
There are a lot of acronyms, so buckle in. MnDOT is required by the National Environmental Policy Act (NEPA) to go through an environmental impact statement (EIS) process when planning a major highway project like Rethinking I-94. This requires MnDOT to:
- Create goals for the project (called the project’s “Purpose & Need”)
- Create a wide variety of design options (called alternatives) that meet those goals
- Create metrics to score each of the options
- Select the project option that performs best in that process.
MnDOT staff often talk about their process as an objective and fair process. However, this process is murky, and MnDOT staff and project consultants have extensive leeway over the process. Staff can hand-pick goals and metrics that best align with their intended project outcome, which is almost always expanded freeways. The evaluation criteria are often vague qualitative measures that have a wide range of interpretations. The Federal Highways Administration requires MnDOT to use measures directly related to transportation, but MnDOT has the flexibility to use alternate measures that holistically evaluate project options.
Traffic models are used to project how regional traffic congestion will be impacted decades from project completion. The results are stated as fact despite the fact that these models are nearly always wrong.
NEPA is also deeply flawed. The law was intended to mitigate additional impacts, not repair historic and ongoing harms. This means that the pollution and health impacts, the demolished homes and businesses, the stolen generational wealth, the traffic noise and divided communities are all viewed as an acceptable status quo. This is why Our Streets and community partners are leading the charge for a new highway justice bill to address these gaps in future major highway projects.
Residents, community groups and elected officials have raised concerns about MnDOT’s evaluation process for Rethinking I-94 for years. This includes a letter from 28 community organizations in 2021, multiple City resolutions, and a May 7, 2024 letter from elected officials. The Reimagining I-94 report, created by nationally respected traffic engineers, highlighted fundamental issues with MnDOT’s evaluation criteria that were sure to doom any projects that didn’t rebuild the highway.
The letters and report were acknowledged by project staff but never acted upon. Now MnDOT is using the same flawed metrics to justify the decision to remove the at-grade options from consideration.
MnDOT Mobility Metrics are Outdated & Inaccurate
MnDOT staff are citing outdated traffic models and disproven assumptions to predict traffic chaos if I-94 is removed, but studies and dynamic traffic models don’t reflect that as reality.
MnDOT gave the boulevard options a failing grade for “mobility”. Measures of mobility, which are determined by the capacity for a roadway to move car traffic, are commonly used to justify rebuilding or expanding highways. MnDOT’s core argument for keeping the freeway is:
I-94 is needed because it carries tens of thousands of trips per day. If we replaced I-94 with a boulevard, our models predict that the corridor and surrounding streets will be clogged with traffic.
The traffic model and measures used by MnDOT to evaluate mobility exclusively measure “corridor throughput”, “mainline speed”, and “travel time reliability”, which is inherently biased. These metrics favor alternatives that maintain high speeds and maximize traffic capacity, inefficient for short urban trips and harmful to adjacent communities. Page 85 of the Reimagining I-94 report discusses this in detail.
MnDOT’s decision to score the at-grade options as failing for mobility while scoring the expanded freeway option favorably does not reflect reality. We know that planning for more and more car traffic does not work, due to induced traffic. Conversely, when highways have been removed or even suddenly closed for construction, people have shifted their habits, driven less, used transit more, and overall congestion was reduced.
Furthermore, the static traffic model that MnDOT staff used to predict traffic impacts is antiquated and inaccurate. Dynamic traffic assignment (DTA) is needed to more accurately model traffic impacts. MnDOT staff recently admitted that they would utilize a dynamic traffic model during the next phase of the project, conveniently after the elimination of the at-grade alternatives.
Boulevard options would improve mobility for all users. I-94 is incredibly inefficient at moving people. Cars are least efficient at moving people in urban settings. By converting a space that is almost exclusively dedicated to cars into a community boulevard with a dedicated transitway, new sidewalks, reconnected neighborhoods, protected bike lanes, and lanes for car traffic, the at-grade boulevard options would efficiently move more people while reducing overall traffic and congestion. While some trips may take minutes longer, overall access, resiliency and multimodal options will be significantly improved.
The at-grade boulevard options would also create opportunities to repurpose asphalt into new affordable homes, businesses and parks, which would make it easier for Minneapolis and Saint Paul residents to access more daily needs within their community. The land use changes enabled by highway removal will bring people and jobs to highly accessible, location-efficient places, which will increase mobility and access while minimizing VMT. Land use changes are not currently reflected in MnDOT’s traffic modeling.
MnDOT Staff are Downplaying Severe Pollution Impacts
MnDOT staff are parroting myths about congestion pollution to downplay the severe pollution impacts of the highway and spread misinformation about the boulevard options.
MnDOT’s analysis somehow docked the boulevard options for their impact on air and noise pollution, claiming that converting I-94 into a boulevard would increase pollution in environmental justice communities. MnDOT justified its analysis by claiming that the boulevard would clog adjacent streets with idling traffic, worsening pollution deeper into neighborhoods. MnDOT also claimed that because the boulevard option would fill in the trench and reconnect the corridor with a surface-level roadway, noise and pollution would travel further into neighborhoods.
Similar rhetoric has been commonly used by highway engineers, however, this is not true for the following reasons:
- The highway already has a major impact on surrounding neighborhoods. Air pollution levels closest to I-94 are significantly higher than elsewhere, contributing to steep disparities in health issues like asthma, cancer, dementia, and life expectancy. A national report highlighted how highways have severe health impacts, which disproportionately impact communities of color. MnDOT’s scoring ignores existing pollution and gave positive pollution scores to project options that would rebuild the highway as is.
- The assumption that congestion worsens pollution has been debunked as a myth. While slower-moving traffic does pollute more, the boulevard would carry significantly less traffic overall, reducing pollution. Furthermore, as vehicles become more fuel-efficient and electrification accelerates, the impact of idling cars will be eliminated. Most new cars already have a feature that automatically shuts off the engine when stopped.
- The argument that a boulevard would increase traffic noise does not add up. Noise pollution is determined by the speed and volume of traffic. Anyone who walks along or across I-94 today knows that it is significantly louder than any urban street in the Twin Cities.
The at-grade options would significantly reduce pollution by reducing overall traffic and increasing greenspace and access to clean alternatives. Significant reductions in pollution have been observed after previously completed highway removal projects, including the Cheonggyecheon highway removal project in South Korea.
MnDOT is Not Accounting for Economic Potential, Reparations
MnDOT staff are citing impacts to economic vitality to remove the boulevard options from further consideration. The at-grade options were scored lower in this metric than highway options that cement I-94’s footprint and suppress nearby property values. Economic vitality can mean many things, however, MnDOT staff narrowly interpreted it to mean the ability for people to drive through the corridor, which they argue increases access to businesses, jobs and employment opportunities.
It is concerning that MnDOT’s analysis makes no mention of the economic vitality that was destroyed when the state highway department first routed I-94 through communities like Rondo, Merriam Park, Cedar-Riverside and North Minneapolis. Over 400 businesses were demolished in Rondo alone, equating to millions in stolen generational wealth. Given that so many homes, businesses and other community institutions were destroyed by I-94, one would think that MnDOT’s analysis of economic vitality would consider which project options create opportunities to return land to residents and build new homes and businesses along the corridor. However, this was completely absent in MnDOT’s process.
The boulevard would improve economic vitality for all neighborhoods in the project area. Economic vitality is a core benefit of the at-grade boulevard options. By repurposing land currently occupied by the freeway trench for new businesses, homes, parks and other community uses, the at-grade options create the potential to equitably reinvest in historically marginalized communities. One report estimated that a boulevard conversion could create up to 2450 permanent jobs, 2230 new homes, and add millions to the local tax base.
MnDOT Says Interstate is Safer, More Walkable and Bikeable (Yes, Really)
The at-grade boulevard options scored poorly in MnDOT’s evaluation process for safety and walkability and bikeability. The justification for this scoring is that a boulevard conversion would increase potential conflict points and overall crashes by turning freeway bridges into at-grade intersections.
This analysis is misleading for a few reasons. First, while crashes may be less frequent on a freeway, they tend to be more severe, on average, because of the higher speeds at impact. Furthermore, many crashes involving pedestrians and bicyclists along the corridor occur on streets near the freeway’s on/off ramps, where drivers race to and from the freeway. Because I-94 severed much of the historic street grid, there are limited places for people walking, biking, driving or taking transit to cross the trench, and this can create safety issues.
The boulevard options would improve safety. The at-grade options would reconnect all neighborhoods in the project corridor while adding new sidewalks and a protected bikeway from downtown Minneapolis and Saint Paul. However MnDOT staff scored these options worse than highway options that would rebuild the highway trench and divide neighborhoods for another half century.
MnDOT Ignores Community Input, Climate Goals
The at-grade alternatives have experienced strong community support from residents along the corridor. The at-grade A & B options ranked most favorably in MnDOT’s 2023 Rethinking I-94 public survey. MnDOT’s dismissal of these highly-favored options contradicts their own community engagement process and undermines the value of public input.
Both the City of Minneapolis and Saint Paul have passed unanimous resolutions outlining the City’s priorities for Rethinking I-94. Both resolutions “opposed the reconstruction of I-94 in its current form.” The City Council of Minneapolis 2024 resolution explicitly called on MnDOT to continue to study “a wide variety of highway removal options in the upcoming Rethinking I-94 scoping decision document.” Saint Paul’s 2021 resolution stated “that the future I-94 corridor (should) have reduced traffic volume and reduced vehicle miles traveled consistent with state and local goals and plans, leading to improved air quality, better health outcomes, and reduced noise for people living, working, playing, and traveling in the corridor”. It is unacceptable that MnDOT staff are choosing to dismiss the clear priorities of elected officials who represent the communities most impacted by the project.
Take Action
Register and sign up to speak at the PAC meeting on January 17. Public comment is held at the end at approximately noon.
Volunteer with us. We’ll be doorknocking the project corridor in January to educate and garner support.
Email elected officials and the MnDOT project team.