[Public Comment Guide] Active Transportation & Interstate Bridge

Comment Guide: NEPA Public Comment Period

Active Transportation & Interstate Bridge Replacement Project

Rev. November 2024

This document is designed to help you submit your personal or organizational comments on the proposed Interstate Replacement Bridge Project during the NEPA Public Comment Period, which ends Monday, Nov 18th at 11:59 PM PST.

There are a variety of planned improvements for people who walk, bike, and roll throughout the study area, including a system of shared-use paths, bicycle lanes, sidewalks, enhanced wayfinding, and facility improvements to comply with the Americans with Disabilities Act. These are referred to in the draft SEIS as active

transportation improvements.

Who should comment on the active transportation improvements in the DSEIS?

Local Residents: Individuals living in the Portland-Vancouver area who use the I-5 bridge regularly.
Commuters and Travelers: Those who rely on the bridge for daily commutes or travel.
Business Owners and Employees: Businesses that depend on the bridge for transportation of goods and services.
Environmental, Transportation, Land Use, and Social Justice Advocates: Groups and individuals concerned about the project's impact on the environment and transportation system.
Community Organizations: Local groups representing diverse community interests.

How to comment:

Online: We recommend that the public submit comments through the Just Crossing Alliance online comment form available here. Why? The IBR project has been asked by advisory committee members to make public comments available in real-time, but has declined to do so. Just Crossing Alliance is providing a comment form that will both immediately submit comments to IBR and make them available in a viewable archive here. Also, unlike the IBR comment form, the JCA form allows attachments. If you don’t want your comment to be publicly viewable immediately (it will eventually be published in the Final EIS) we suggest you use the IBR comment page instead.
Email: Send comments to draftseis@interstatebridge.org with "Draft SEIS public comment" in the subject line.
Interstate Bridge
Phone: Call 866-IBR-SEIS (427-7347) and include "Draft SEIS" in your message.
Interstate Bridge
Mail: Address written comments to:
Interstate Bridge Replacement Program
Attention: Draft SEIS public comment
500 Broadway, Suite 200, Vancouver, WA 98660

Commenting Tips:

Visit the Draft Supplemental Environmental Impact Statement (SEIS) page and review the Active Transportation Section.
If you have multiple subjects to comment on, submit them in separate comments, one topic per comment.
Maximum one attachment per submission. If you want to submit multiple attachments, submit one comment for each.
Put your comments in your own words, we know that ‘form comments’ will be discounted. Give personal accounts of the impact of this project on your life.
We created this guide below to help you comment on the proposals for people walking, biking, rolling and accessing public transit. If you want to comment on other aspects/chapters of the DSEIS, please visit the Just Crossing Alliance’s IBR Insights webpage.

Why Public Comments Matter:

Influence Decision-Making: Public feedback helps shape the final design and implementation of the bridge replacement, ensuring it meets community needs.
Address Concerns: Comments can highlight potential issues related to traffic, environmental impact, and community disruption, prompting necessary adjustments.
Promote Transparency and Fiscal Responsibility : Engaging in the process fosters transparency and accountability in how public funds are utilized.
Ensure Inclusivity: Diverse input ensures that the project considers the needs of all community members, including marginalized groups.

Why should you trust our feedback on this project?

We are a group of public and active transportation experts, advocates, and users dedicated to seeing an Interstate Bridge replacement that includes world class facilities so public and active transportation users have absolute safety and prioritization. To encourage and support walking, biking, rolling and transit, routes and connectivity must be direct, complete, and complement both existing and planned networks.

We are committed to sustainable, multimodal, and equitable transportation solutions. We adopted a fiscal stewardship approach in our analysis which aims to maximize economic efficiencies and steward public resources, aka your tax dollars.

To identify the concerns listed, we want to acknowledge the contributions of The Street Trust, Oregon Walks, 40-Mile Loop, Bridgeton Neighborhood, local small businesses in Vancouver, Cycle Vancouver, Bikeloud PDX, Families for Safe Streets, and more. These groups have been regularly meeting and have hosted in person events to gather the experiences of people using these facilities.

Comment Guide

For the IBR project to meet its goals of accessibility, safety, and inclusivity, a complete and integrated approach to active transportation and transit is essential. By addressing these design priorities now, we can prevent significant accessibility, safety, and environmental issues down the line. The proposed recommendations will ensure that the bridge serves as a resilient, inclusive, and sustainable investment in public infrastructure which serves generations to come.

We have organized our concerns in four priority areas, which we hope reflect your experiences as a user and will help you organize your comments for submission by the November 18th deadline. We suggest you identify those topics that are most important to you, use some/all of the language provided, and add your personal story to highlight the impact of your comment on your life.

Priority Concern #1: User Access and Experience for People Walking, Biking, Rolling

Why it matters: It is critical that the new bridge meets or exceeds active transportation usership goals. For that to happen, the system must be designed to meet the needs of everyone, from eight to eighty years old, and regardless of their ability level. The current design does not meet this threshold, specifically: connectivity, level of stress/comfort, safety, and operations and maintenance.

Here are some aspects you should consider highlighting in your comments if they affect you and your community:

The elevation of the multi-use path crossing the Columbia River is of high concern. If the multi-use path cannot be lowered, then robust, well-maintained elevators need to be made available as a primary, reliable option for active transportation users. This challenge is especially made clear on the Vancouver access point. Under current design, active transportation users must descend (lose elevation) as they approach the waterfront, then use a ½ mile long, 4.5% grade circular facility to climb up to the bridge before crossing the Columbia River. We are calling this the “Vancouver Dip.” This is a significant barrier and is ableist in design. The program needs to include a multi-use path at the bridge’s grade from Evergreen (the Vancouver library) to the riverfront so that walkers/rollers/riders have direct access to the bridge. This is an extreme example of out of direction travel that is exacerbated by out of elevation travel.
There is additional out of direction travel for people making trips that combine transit and walking/rolling/biking. Current design places active transportation and transit facilities on opposite sides of the bridge, meaning users using more than one mode have additional out of direction travel getting from one side to the other. These additional distances are especially challenging for people with mobility challenges. If you are a multimodal commuter (walks, bikes, rolls AND uses transit in the same trip or commute) then the IBR project team really needs to hear how this would affect you. Share your stories of multimodal trips and how locating the multi-use trail and transit on the same side of the bridge is critical. By ensuring accessibility features, we protect the rights and needs of a broad user base, including non-drivers, low-income residents, and individuals with disabilities. Additional benefits of placing active transportation and transit on the same side of the bridge include:

Seamless Transition: Users should easily switch between transit and active transportation at any station, with no grade changes or distance barriers.
Shared Elevator Access: Allowing active transportation users to share transit station elevators eliminates the need for additional infrastructure, making the design more efficient and accessible.
Eyes on the Path: Transit operators and passengers provide a continuous presence, reducing the isolation felt on a multi-use path and enhancing safety and comfort.
Emergency Egress: The multi-use path should double as an emergency exit route for the transit way, supporting user safety during unexpected events.
Inclusive Design Principles: These principles ensure the accessibility and usability of both transit and active transportation facilities for individuals of all abilities.

Walking/Biking/Rolling Connectivity to the Main Bridge Multi-use Path from Oregon Mainland The Interstate Bridge Replacement project must ensure complete and safe connections to the existing walking, biking, and rolling corridors in Oregon. These pathways need to be as physically separated from freight traffic as possible, especially in areas where new ramps and interchanges will be constructed. Maximizing this separation is key to creating safer, more attractive, and therefore more heavily used walking, rolling, and biking routes.
Separating Vulnerable Road Users from Freight is Critical - A distinct separation of walk/bike/roll corridors from freight routes reduces conflicts between these two user groups. For example, the current design for the ramp from Vancouver Way to MLK North poses significant conflict with freight, as the proposed route travels down, across, and back up a freight-heavy on-ramp. Given the Marine Drive interchange is usually described as the most heavily used freight corridor in Oregon, we believe additional alternatives need to be studied that entirely separate walk/bike/roll travel around rather than through this important freight interchange.
Connection to the Interstate Avenue/Expo Way Walk/Bike/Roll Corridor The Supplemental Environmental Impact Statement (SEIS) presents a well-designed, safe separation for walk/bike/roll users along the Interstate Avenue/Expo Way corridor. This corridor provides an excellent example of the type of separation that should be extended to all Oregon walk/bike/roll corridors to ensure safety and connectivity.
The Marine Drive Single Point Interchange The proposed design for the Marine Drive Single Point Interchange presents a potential conflict between bike lanes and freight traffic. We request that additional alternatives be studied, including options that completely remove bike lanes from this interchange and investment of saved funds into further enhancing other connections. These studies should also explore how the project can meet the requirements of the Oregon Bike Bill without relying on the shoulders of MLK and Marine Drive for bike travel. Our research suggests that the Oregon Bike Bill allows for more flexibility in design than the IBR project has acknowledged. We want to make sure that all allowable uses of the required 1% for bike/ped are studied with a focus on promoting vulnerable road user safety.
The Vancouver/Williams Walk/Bike/Roll Corridor is a major north-south bike route in Portland, but its connection to the new main bridge multi-use path (MUP) is indirect and complicated. Northbound users must navigate bike lanes along the shoulders of northbound MLK, while southbound users must travel along a separated bike lane next to Union Court before joining southbound MLK on a shoulder bike lane. Additional alternatives should be explored in the SEIS to improve this connection. One potential solution is to extend the proposed Union Court separated bike lane further, creating a parallel cycle track or entirely separate path alongside MLK. This path could be located at the toe of the MLK embankment, providing a safe, barrier-separated corridor for both northbound and southbound travel. This would eliminate the need for bike lanes on the shoulders of MLK, significantly separating pedestrian, bike, and roller traffic from freight movements.

These alternatives were previously proposed to the IBR project and have been studied by the City of Portland. We urge the SEIS to consider them further and to adopt separated facilities, especially in these most dangerous areas of heavy freight movement.

The 40-Mile Loop East/West Corridor is the main trail hub for Portland and when fully completed will connect most of the other trails in the region together. Having excellent connections with the 40-Mile Loop is important for ease of use and wayfinding. The IBR is improving an important segment of the 40 Mile Loop and we like that! IBR’s addition to the 40 Mile Loop Trail connects to the west to the already built separated trail along west bound Marine Drive. This connection is well-designed, offering a safe and direct route for cyclists and pedestrians separated from other traffic. We fully support this.

However, the proposed eastbound connection to the Bridgeton Trail portion of the 40-Mile Loop is not ideal. The current design requires out-of-direction travel, routing users around a traffic circle to access the multi-use path on the west side of the Harbor Bridge. This is not a convenient or efficient connection. We request that alternative designs be considered to provide a direct connection from the Bridgeton Trail to the east-side sidewalk of the Harbor Bridge. This would encourage more users to cross the bridge as the east sidewalk offers a scenic view of North Portland Harbor and Mt. Hood. Additionally, we request that the sidewalk on the east side of the Harbor Bridge be as wide as possible and built with wide viewing areas to rest and enjoy the view.

Priority Concern #2: Safety, Comfort and Equitable Multimodal Access

Why it matters: The Interstate Bridge Replacement project must prioritize safety, accessibility, and comfort for all users, particularly those using active transportation modes. Our comments must emphasize the need to integrate active transportation and transit facilities closely, ensuring they serve as a cohesive and accessible network. Missteps in this design could lead to significant safety and accessibility issues, which NEPA requires us to address to protect the interests of all impacted populations. If a single-level bridge is chosen, the multi-use path should be positioned on the outer side, adjacent to the transit lanes. This placement would act as a buffer against noise, vibration, and vehicle debris from motor traffic, enhancing user comfort and safety.

Here are some aspects you should consider highlighting in your comments if they affect you and your community:

Noise and Debris: With tens of thousands of high speed car and truck vehicles passing over the bridge daily, active transportation users need protection from road noise and vehicle debris. To meet active transportation user goals, we need a design that protects users from these roadway hazards. Without adequate noise and debris shielding, the bridge environment will be too uncomfortable and even hazardous. Such conditions could discourage walking, biking, and other modes, pushing people towards single-occupancy vehicle use, thereby increasing environmental impacts and reducing the project's alignment with climate resilience goals.
Temperature and Shading: We know that ambient temperatures on/around the bridge will exceed 100°F in summer months. It is critical that active transportation users have natural and/or human-made shading to mitigate heat and weather impacts on users. Failure to do so could leave the bridge infrastructure unable to serve users effectively and, therefore, miss our active transportation user goals.
Unsheltered homelessness, which is pervasive across Oregon, can be concentrated in the vicinity of covered projects. A safety and maintenance plan is essential to consider a compassionate, long-term approach that integrates both personal safety measures and supportive services for people experiencing homelessness. This way, the IBR can serve not just as an infrastructure project but also as a supportive space that balances public safety and social responsibility, while keeping our shared multi-use paths clear for use as transportation corridors.
Lighting and Isolation: People will only use active transportation and transit if they feel safe. As such, lighting throughout the multi-use path project area is critical. Furthermore, placing active transportation and transit facilities together increases the number of people sharing the space and reduces the feelings of vulnerability and isolation, especially at night or during low-traffic periods.
Emergency Access: We have concerns that medical and police vehicles cannot directly access the multi-use path. Additionally, lack of embedded rail ties prevents ambulances and emergency responders from directly getting to those using the transit system. Furthermore, if emergency responders are expected to access multi-use path and transit users by parking on highway shoulder and scaling a divider, we are concerned that this indicates there is not sufficient separation between automobiles traveling at highway speeds and active transportation modes (see “noise and debris” above).
Grade and Distance: As mentioned previously, current designs require significant out of direction travel both in terms of distance and grade. It is worth noting that single occupancy vehicle travel experiences little to no out of direction travel while active transportation users in and out of Vancouver experience an additional one mile of out of direction travel each time they navigate the Vancouver Dip. This is an inequitable design.

Priority Concern #3: Environmental and Climate Impacts

Why it matters: Did you know that transportation is Oregon’s largest source of climate pollution and that how often and far we drive (especially by ourselves, aka by “single occupancy vehicle”) is a contributor? By building excellent active transportation and transit facilities–and tolling appropriately–this infrastructure project must give world-class options to travelers so they choose non-driving modes of transportation.

Global impacts: Unfortunately, the proposed design does little to reduce auto travel, estimating a 62% increase in study-area miles we drive (aka vehicle miles traveled or VMT) over current amounts (Executive Summary, S-21). Shifting modeshare to active transportation and transit is the most effective method of reducing VMT and meeting specific state/regional carbon reduction goals
Local impacts: If this project fails to reduce VMT, local impacts include:

Additional air pollution (greenhouse gas and particulate matter) from internal combustion emissions generated by vehicles
Negative impacts to water quality from chemical, oil, tire particulate, and brake particulate runoff
Additional noise pollution to surrounding communities

Priority Concern #4: Fiscal Responsibility and Economic Benefits - Let’s get the most bang for our buck!

Why it matters: Active and Public Transportation infrastructure can provide a very high return on investment if well designed.

Economies of Combined Systems: By separating active transportation from light rail, the current project design expends dollars on separate access facilities to both systems. The most significant expenditure is on the spiral ramp connecting active transportation to the Vancouver waterfront and current design does not offer an elevator option to users of the multi-use path.
Demand Management: Managing demand first, will help us shape a more efficient, right-sized, and thus cost-effective project for the future generations. Variable tolling is a powerful tool when equitably deployed.
Mode Equity: Avoid subsidizing private auto travel at expense of walkers/rollers/cyclists
Long term funding plan for operations and maintenance (O&M) of active transportation facilities: Variable Pricing (aka tolling) generates a revenue stream which can be used to fund operations and maintenance for the active transportation facilities, including but not limited to clearing the right of way of debris, glass, trash, snow and ice, and generally keeping the routes/pathways on the bridge and approaches free of barriers.
Equity and tolling in the I-5 Corridor is not a matter of if, but when. For this reason, we insist that regardless which state manages the IBR toll program that implementation is in accordance with ODOT Equity and Mobility Advisory Committee’s Low Income Toll Program, and so that the project enhances rather harms access and mobility for low-income and BIPOC communities.

Conclusion: These comments are constrained to Active Transportation aspects of IBR’s Draft SEIS. For more comprehensive full-project analysis, please visit the Just Crossing Alliance Public Comment Resources.