July 22, 2024
To: Secretary Pete Buttigieg, Department of Transportation
CC: Shailen Bhatt, Federal Highway Administration
Christopher Coes, Department of Transportation
Subject: Reconnecting Communities as a principle for ALL USDOT discretionary grant programs
Dear Secretary Buttigieg,
We often hear that Reconnecting Communities is a principle at the US Department of Transportation, not just a grant program. Yet many state departments of transportation continue to seek federal discretionary grant funding for projects that run counter purpose to this principle. Some of them are successful. Some of them promote damaging highway expansions under the guise of Reconnecting Communities, subverting the principle.
A case in point is an application like the Oregon Department of Transportation’s (ODOT’s) FY 25-26 I-5 Rose Quarter Improvement Project to USDOT’s INFRA program.(1) The I-5 Rose Quarter Improvement Project began in 2017 as a highway widening project and remains a highway widening project – with plans to increase I-5’s existing width by two to three times!(2) Community advocates in Portland have pushed instead for a highway cap, to partially mitigate harm done to the Black community in North Portland’s Albina neighborhood from the original construction of I-5. ODOT has adopted the cap into its plans, because it anticipates being able to leverage programs like USDOT’s Reconnecting Communities and Neighborhoods to unlock money for the project’s expansion component.(3) As expected, ODOT’s INFRA application bundles together highway expansion and highway cap, despite the RCN program’s insistence that its programming cannot be used for building new freeway capacity.(4)
Adding lanes to a highway and expanding its footprint disconnects communities and repeats the harms of 20th century highway building that the RCN program seeks to repair. Any project that pursues this goal cannot simultaneously claim that it reconnects communities.
We ask that USDOT fund only the portions of an application that align with the principle of Reconnecting Communities, in cases where applicants apply to USDOT discretionary grant programs seeking to leverage the Reconnecting Communities elements to unlock funding for associated highway widening.
Furthermore, we applaud that this year’s Notice of Funding Opportunity for the Reconnecting Communities and Neighborhoods asks applicants if a highway expansion is associated with the project and reduces the application’s score if the answer is yes. This criteria should be applied to all USDOT discretionary grant programs, to reinforce Reconnecting Communities as a USDOT principle.
The harms of additional lanes of freeway in vulnerable communities are myriad and significant – increased air pollution, greater noise pollution, contributions to the urban heat island effect, loss of affordable housing, more impermeable surfaces increasing flood risk, and of course greater carbon emissions from induced driving – at a time in which communities across America are struggling to find answers to these overlapping challenges while adapting to a quickly changing climate. Reconnecting Communities as a principle and a guiding light for all USDOT discretionary programs has the power to tackle these challenges head on.
1 ODOT’s scope for the project can be found here.
https://www.i5rosequarter.org/media/m04lalit/rq-infra-report-budget_20240506.pdf
2 Through a public records request, advocates from No More Freeways have found that ODOT intends to expand the footprint of I-5 through the Rose Quarter from 82 feet wide to 160 feet wide (and as much as 250 feet wide in some sections). This is wide enough to be striped as a 10-lane highway. ODOT has not made this information publicly available. No More Freeway’s letter can be read here: https://nomorefreewayspdx.com/wp-content/uploads/2024/07/070224-NMF-Comments-opposing-Oregon DOT-INFRA-grant-application-as-submitted.pdf
3 An August 2022 letter from ODOT to the Oregon legislature requesting funding the project’s new lanes makes this clear: “Any award of RCP funding would represent an initial investment in the highway cover and would unlock the potential for additional Federal funding.”
https://www.oregon.gov/odot/IF/EboardRequests/ODOT_IIJA%20Reconnecting%20Communities%20Ros e%20Quarter%20Request%20to%20Apply%20Grant_Letter.pdf
4 USDOT wrote in a letter announcing ODOT’s receipt of the RCN grant: “Projects receiving RCN grant funding cannot be used for additional through travel lanes for single-occupant passenger vehicles or highway expansion.” That letter can be read here:
https://www.i5rosequarter.org/media/p3jd3zls/rcn-2023-capital-award-letter-rose-quarter.pdf