The answers you get depend on the questions you ask, and on who you ask. Oklahoma state and Oklahoma City (OKC) regional transportation planners and public officials are now asking an important question of the public: "Where should we build an Outer Loop Road?" But this question skips the more important and fundamental question that they should have asked first: "Will we need an Outer Loop Road?" The planners' answer, "YES," is widely accepted but was reached with virtually no public discussion. We should evaluate the method the planners and politicians used to get their answer, and decide whether we agree before allowing them to proceed.

I. Background

1. define the criteria with which to judge solutions,
2. perform a preliminary analysis to screen an initial list of over 50 possible solutions down to 5 or 6 "good" solutions, and
3. perform a detailed analysis on the "good" solutions to screen them down to one "best" solution.

Federal laws and regulations require the MIS team¹ to consider a broad array of potential solutions to transportation problems, and to solicit the opinions of the general public. Furthermore, the main goal of the OKC region's 2020 OCARTS² Plan is the improvement of both non-road and road-based transportation modes, using citizen input as a partial guide. Thus, the MIS team set up a citizens' Advisory Committee, and the Sierra Club has participated since June, 1998. The MIS team also presented results to and received input from the general public at several public meetings.

II. Problems with the Current Loop Study

The Sierra Club objects to the MIS team's apparent decision, based on only their preliminary analysis, that a Loop Road will definitely be needed. This conclusion is not supported by their analysis, which produced a scoring system used to rank the over 50 initial solutions, both road and non-road. Non-road options considered by the MIS team include:

• improving mass transit (bus, rail)
• converting lanes on the existing road network to high-occupancy vehicle (HOV) lanes
• reducing traffic volume during peak periods (incentives for telecommuting, shifting work schedules, & ride-sharing, congestion pricing), known as Transportation Demand Management, or TDM
• enhancing the existing road network (better intersections, better signs, dedicated, reversible commuter lanes), known as Transportation Systems Management (TSM) and Intelligent Transportation Systems (ITS)

Within the ranked list, 4 of the top 5 options, and 7 of the top 11, were non-road solutions. Since non-road solutions appear very attractive, the MIS team should carry them forward and study them in detail, separately from the road-based options, and compare them to the road-based options in the final screening. Indeed, at the November, 1998 meetings of the Advisory Committee, the MIS team stated that this was their plan. Between November and December, however, they decided to "demote" the non-road options from stand-alone alternatives to Loop Road "add-ons." This decision was preliminary and unwarranted, and shows that the MIS team is biased in favor of road-based solutions.

The December presentations to the public unjustly focused both media and public attention on road-based solutions. This narrowing of the discussion is a disservice to OKC area residents. Notably, despite the MIS team's marginalization of non-road options, at the meetings several citizens questioned the need for an Outer Loop Road, and some flatly opposed it.

Building more roads in response to traffic congestion is the "typical" solution. But experience in other U.S. cities shows it is neither the only solution nor the best solution. The MIS provides clear evidence that the same may be true for OKC. The Sierra Club believes that avoiding building an Outer Loop Road is attractive for many reasons, which we summarize below.

III: Why non-Road Options Make Sense for the OKC Area

Big highways, cheap gas, car-oriented community planning, and available land are key ingredients of urban sprawl: low-density, car-dependent economic development beyond the edges of existing service and employment areas. Urban sprawl has been the status-quo form of development in American cities for decades. But runaway sprawl, largely unregulated, resulted in landscapes of endless strip malls and residential subdivisions. Sprawl causes a host of subtle yet serious problems that degrade our quality of life, our society and economy, and the natural environment.

Most of the Sierra Club's reasons to avoid building an Outer Loop Road tie in with urban sprawl. Collectively, our reasons can be grouped into five broad categories:

Transportation: The Loop will relieve little rush-hour congestion, because it won't serve the OKC central business district, the Oklahoma state government complex, or the health center complex. It therefore will divert little rush hour traffic from our highways. The Loop seems to have two main purposes: providing a bypass for through traffic on I-35 and I-40, and providing developmental profit for business interests and property owners along its proposed path.
In contrast, improving our area's mass transit system would offer several benefits to residents, including:
1. better service to the non-driving public (the elderly, the disabled, the poor, and students);
2. more consumer transportation choices, as we shouldn't be limited to driving &/or taking taxis;
3. better access to the new MAPS facilities in downtown OKC.

Loss of Life & Property: The Loop will cause more vehicle travel, leading to more accidents, injuries, and fatalities. Each year in the U.S., almost 15 million motor vehicle accidents kill about 40,000 persons, and injure almost 5 million others, at least 300,000 of them severely. More Americans have been killed by cars than were killed in all the country's wars. These accidents cost the U.S. over $350 billion annually. How much is each lost human life worth? Lost quality of life for the injured? Moreover, highway construction, and the development that often follows it, typically destroys wetlands, which act as huge natural sponges. Reducing the land's ability to absorb and retain rain makes flooding both more likely and more severe, risking even more damage to lives and property.

Land Use: Transportation facilities drive land use patterns. Half the land in an average U.S. city is devoted to car-related uses (roads, parking lots, gas stations, etc.). Nationwide, more land is devoted to cars than to housing. A Loop Road would pave over thousands of acres of our farmlands, forests, prairies, and wetlands, reducing agricultural production capacity, increasing soil erosion, destroying habitat for native wildlife, and possibly threatening endangered species. Building a Loop may also cause the destruction &/or relocation of homes lying within its corridor; at the very least, rural residents will get an unwelcome and unsightly new neighbor. How much of our land should we pave over?

Pollution: Vehicles produce at least 50% of all U.S. air pollution, even though our emissions standards are as strict as any in the world. In 1997, Oklahoma County nearly exceeded federally allowed levels of ozone and carbon monoxide—two air pollutants, associated mostly with vehicle use, that the EPA regulates⁵. Thus, as OKC-area vehicle use increases over time, we risk violating the standards, especially if currently proposed stricter standards become law. We should address this risk before planning more roads, otherwise we may suffer federal fines and poorer health (especially among children, the elderly, and persons already having respiratory problems). Motor vehicles also discharge oil and other toxic materials into rivers and streams because of stormwater runoff; in the late 1990s this is the leading form of water pollution. A Loop Road would threaten our future drinking water supplies. Wetlands destruction multiplies this risk, as they act as natural filtering systems for our pollution.

Economic: The Loop will contribute to the enormous unfair economic distortions caused by car subsidies. Federal, state, and local governments subsidize cars with $300-600 billion a year (depending on the costs included), an average subsidy of $1600-3200 per vehicle⁶. Taxpayers, including nondrivers, foot this bill mostly unknowingly. The fair financing method—making drivers pay the full costs of roads, in proportion to the amount driven—is rarely used. If drivers paid all hidden costs directly in the form of a gasoline tax, the tax on each gallon would be a whopping $5-6! Further, making heavy trucks pay for the road damage they cause would reduce the unfair advantage trucks have over more efficient and less damaging rail freight. An Outer Loop would also promote the "flight to the suburbs" phenomenon that other U.S. cities have experienced, causing the decay of central OKC. A Loop would promote sprawl, meaning we may weaken the local tax base because in the 1990s increases in tax revenues are typically consumed by the costs of delivering new services—water & sewer lines, schools, police and fire protection, and roads. Finally, more vehicle travel means more gasoline use, continuing our country's over-dependence on foreign sources of petroleum (the U.S. imports about half the oil it uses each year).

IV. Sierra Club Recommendations & Plans

Instead, the planners propose building an Outer Loop Road, mainly to serve bypass traffic and certain local business interests. Are these reasons important enough to most OKC area residents to justify tolerating all of a Loop's negative effects?

The Sierra Club believes that before we consider where to build an Outer Loop, we must decide whether to build it. During the MIS to date, the public and the media have virtually ignored the latter question, and the non-road solutions that can illuminate the best answers. Why? Largely because the MIS team has marginalized views that question the need for more roads. Questioning roads doesn't mean questioning progress; it means insisting on smart progress. Questioning the growth of urban sprawl isn't being anti-growth; it's being pro-smart growth.

For the sake of achieving both a better OKC regional transportation system and a more sensible urban setting, the Sierra Club urges the MIS team to accept the following recommendation:

Keep the viable non-road options in the study, separately from Loop Road options. If necessary, combine some or all non-road options in a package. Then compare non-road options to road-based options in the final screening.

The Sierra Club is trying to get its transportation message out. We are cooperating closely with the Control the Loop Action Coalition as they organize the OKC-area's movement of citizens questioning the Outer Loop. We encourage any persons or parties interested in participating to contact either the coalition directly, or us at:
Email: opitz@qns.com

1. the MIS team includes the 3 state agencies funding the study-Oklahoma Department of Transportation, Oklahoma Turnpike Authority, and Association of Central Oklahoma Governments-plus the contractors hired to do the work-Cobb Engineering Co.
   
2. Oklahoma City Area Regional Transportation Study
   
3. G. Tyler Miller, Jr., Living in the Environment, 9th ed., p. 261
   
4. attributed to Robert Samuelson
   
5. Oklahoma Department of Environmental Quality, Air Quality Division
   
6. Miller 261

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