I-205 Tolling: Concerns

The City's Concerns:

The West Linn City Council and elected officials from other nearby cities are very concerned about the impact of the proposed tolling projects on our local streets, community, and businesses and have consistently argued against ODOT's I-205 tolling proposal. Through individual and group letters, public comment participation, emails, and lobbying state legislators, they have made clear their shared belief that the proposed tolling is not in the best interest of West Linn or area communities. The City is particularly concerned about: 

• Safety and congestion on local West Linn roads used by those routing around the proposed two (2) toll gantries planned in West Linn. Creating negative impacts to local business districts and community members.
• Inadequate mitigation plans to reduce negative impacts of tolling I-205 in West Linn (currently ODOT has only identified two (2) small pedestrian projects, no actual traffic or transit solutions are planned for expected diversion traffic volumes on local streets).
• Plans to begin tolling before limited mitigation measures are in place.
• Inequitable burden for community members that don’t have the option to shift work hours or travel times to avoid peak tolls. Added layers of bureaucracy for low income or marginalized persons to be aware of and apply for low-income toll programs.
• Unfairly placing a disproportionate burden for funding these needed upgrades on the local residents who, because of otherwise insufficient transportation and transit infrastructure, must utilize the facilities on a daily basis.
• Upending decades of precedent which has allocated the cost of major transportation projects to all interstate users.

Further concerns are detailed in a September 15, 2020 letter to ODOT's Toll Program Director:

The ODOT tolling plan is deficient in at least four major ways:

1. It unfairly places a disproportionate burden for funding these needed upgrades on the local residents who, because of otherwise insufficient transportation and transit infrastructure, must utilize the facilities on a daily basis; and
2. It upends decades of precedent which has allocated the cost of major transportation projects to all interstate users; and
3. It has failed to consider the input of West Linn and other local city and county residents, who have made it clear that they do not want to be unfairly targeted for 100% of the burden of paying for this project; and
4. It has ignored the opportunity to ask that the state legislature and the federal government allocate funding for these two projects as they have done for highway projects along the I-5 corridor in Eugene/Springfield, Highway 97 in Central Oregon, Interstate 84, or along coastal Highway 101. This point was also made by other cities in the region, as well as the C4 Regional Transportation Coordinating Committee, made up of dozens of regional transportation leaders.

The C4 letter sent in August 2020 also made a number of key points which we support and wish to re-emphasize two key aspects at this time. These include:

A Regionwide Approach to Tolling (as suggested in the legislative intent in HB 2017): “We request ODOT use this NEPA process to additionally assess the original intent of HB 2017 to toll the entirety of I-5 and I-205, between the Columbia River and their intersection north of Wilsonville. Value pricing as a means of congestion relief cannot be achieved as a pilot program where select communities bear the burden of discovery. If value pricing is to have a true impact in our region, ODOT and the region at large will benefit by studying those impacts now, and potentially pursuing those methods of value pricing if they truly model congestion relief. This approach not only favors a system-wide approach to congestion relief, but also removes the already observable and unfair model of penalizing several small communities to fund a project of statewide significance.”

Diversion: “Diversion already exists on local roads due to bottleneck congestion on I-205. Increased diversion to roads already accommodating diversion is likely to eliminate community support. Hence why Comment 3-A is so important. The I-205 Widening and Seismic Improvements Project must be considered completed for any of this to resonate with our local communities. We also expect the NEPA analysis to inform how ODOT plans to remedy the impacts of tolling diversion where transportation gaps exist in this area, including a need for improved transit alternatives such as bus on shoulder access and connection routes around the project, improved pedestrian accommodation on projects where diversion will increase, and additional river crossings to accommodate diversion.“

We urge the Department and the Oregon Transportation Commission to consider a plan which:

1. Prioritizes securing immediate funding from the state legislature and any potential federal infrastructure package (the tried and proven approach that has worked for every single state highway project in the state since the 1970s);
2. Suggests tolling only once a comprehensive, regionwide dialogue - - complete with public buy-in - - has been secured, and any tolling is not focused squarely and solely on the residents of West Linn, Oregon City, Milwaukie, Wilsonville, Gladstone, Tualatin, etc. At the very least, the plan needs to recommend a simultaneous and regionwide tolling approach on all major transportation highways (e.g., I-5, I-205, I-84, 217, 26), or at minimum the entirety of I-205 and I-5 through the Metro region. Further, if ODOT is unwilling to consider this alternative, and is to move forward with tolling on a limited confined reach (i.e., Stafford Rd to Abernethy Bridge or Hwy 213), then all funds generated by that tolling must be spent within this area and ODOT should extend/expand the length of any tolling for a proposed limited segment (such as the proposed Stafford Rd to Abernethy Bridge) to different endpoints to minimize problems with diversion etc. locally - for example extend the tolling reach on I-205 to between I-5 on the south and Hwy 224 on the north;
3. Prioritizes getting construction underway as soon as possible in order to avoid severe inflationary cost drivers.
    

What you can do:

Share your comments directly with ODOT so they are included in the record. I-205 tolling will have a direct impact on YOU as a West Linn community member, whether or not you drive.

• Email:  Oregontolling@odot.oregon.gov
• Comment online
• Phone:  503-837-3536

Here are some questions Council has asked ODOT about this project. Anyone who shares these questions may ask ODOT or their State Representatives for answers:

• Who will define who is low-income, and what relief will these households receive? Does creating a credit program that has to be opted into just create another access issue (more bureaucracy to navigate)? This should be sorted out prior to the program being approved.
• Will West Linn get any transit to offset impacts? As with the above, why hasn’t this been determined in advance of the tolling program?
• What about the impact on local organizations like the West Linn Food Pantry? Delivery drivers are volunteers, often themselves seniors on fixed incomes.
• How can it possibly be that the only mitigation measure needed in West Linn is a small section of pedestrian improvements on one street? If traffic is increasing 100%, how can there be no impacts?
• How does ODOT plan to conduct further outreach in West Linn? In-person events are being held in Tualatin, Gladstone, and Oregon City but not West Linn.
• Will the impacts on the business community be clearly studied and defined?
• Does tolling makes sense on I-205 when there are so many diversion opportunities? ODOT already created part of the problem back in the original design of I-205 and its intersection with Highway 43 and Willamette Falls Drive.

Learn More:

Below are some formal examples of formal correspondence exchanged over this issue through the years. You can also read up on the background of ODOT's I-205 project here, or check its latest status at our I-205 Hub Page.