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Comment on the I-94 East-West Corridor Study, Milwaukee - Milwaukee County

"The purpose of the I-94 East-West Corridor Project is to address the deteriorated condition of I-94, obsolete roadway and bridge design, existing and future traffc demand, and high crash rates on I-94 from 70th Street (western terminus) to 16th Street (eastern terminus). The project would provide a safer and more effcient I-94 while minimizing impacts to the natural, cultural, and built environment to the extent feasible and practicable." -- From the Purpose and Need Summary, I-94 East-West Corridor Study, Milwaukee - Milwaukee County

by John December / Updates/More Info:

This is my comment on this plan that I sent in via their public engagement process.

2021-03-19 3:09 pm

Thank you for your efforts on the I-94 East-West Corridor Study project and for accepting this public comment. I'm a Milwaukee resident and know the importance of our highway system and the significance of our city in Wisconsin's transportation network. I believe that your presentation supports the repair of I-94 at its current six-lane capacity, but your claim on eight lanes is not supported by evidence. Your material lacks attention to modern or multimodal transportation management methods and insufficiently addresses equity, climate, and economic issues. Therefore, I write this letter in support of the proper repair, update, and management of the highway, within a multimodal context, at six lanes, but not at eight lanes.

Building additional lanes would require significant construction and maintenance costs, claim additional land, encourage more automobile-oriented land use, erode equity in communities along the corridor, and generate induced demand. The significance of these burdens requires a clear, cogent, and concise explanation of why the additional lanes are required, why they would produce positive results in the long-term, and how they would be managed properly. Further, this explanation requires a specific account of how the burdens these lanes introduce can be mitigated.

First, your argument for extra lanes depends on identifying why the highway, if it would be properly repaired and managed at six lanes, would not meet requirements. To do this, you would need to identify the fraction of the time it would operate at peak use. However, to answer this, your work requires updated statistics on highway capacity demand. Historical observations show no major increased demand in the past decades. Looking at recent patterns, it might be argued that highway capacity should be reduced. You need to show what proper repair, update, and management of the highway at six lanes could do, and then identify why the fraction of the time the highway might be at peak use must require all the additional burdens for the extra lanes. Most importantly, you would need to explain why you have no other means to manage peak capacity.

Next, your argument for extra lanes next depends on explaining why the capacity expansion for peak use would not be nullified by induced demand. This is of particular concern, as your explanation of induced demand is not supported by research elsewhere (Litman, 2021). By failing to address this, you are suggesting a feedback loop of increased highway capacity creating induced demand which then leads to further peak capacity problems (Transportation for America, 2020). This is an unsustainable cycle because of the costs involved and the damage to the economic, land use, and social needs of the local communities, region, and state.

Your argument for extra lanes depends on explaining why Integrated Corridor Management (ICM) and other modern management methods and technologies can't be developed and implemented to manage highway demand in a sustainable way. This is the key to managing induced demand and peak use. ICM methods involve looking at all available resources in a corridor, including public transportation, across governmental units, and not just the highway system in isolation nor specific elements of ICM such as transit signal priority (U.S. Department of Transportation, 2016). Connected Vehicle (CV) technologies promise better use of existing highway capacity and could provide smoother freight transit of the corridor (Leong, 2018). Your lack of coverage of these issues is troubling because it indicates the present highway, let alone an expansion, isn't being managed properly with modern techniques. Adding lanes will not solve this inadequacy.

Your argument for extra lanes requires identifying the inequities of highway construction and how this harm can be mitigated. Spending large amounts of public money that directly impacts communities requires an explanation of why those communities are treated inequitably with regard to public infrastructure. Structural racism has been identified as an issue in public infrastructure (Short, 2019). The historic construction of highways in the area has disproportionately impacted communities which seek opportunities now to rebuild vitality (Niemuth, 2014). The Governor's Task Force on Climate Change Report (2020) identifies climate, emissions, and equity issues with regards to transportation spending. The significant highway spending has caused land use dislocations, inequities, and environmental harm to our communities. Spending on this highway must include providing funds to identify and mitigate this damage. Milwaukee County Ordinance No. 20-4 requires a commitment to identify racial equity impacts (Milwaukee County, 2020).

Your presentation lacks an explanation of how the highway expansion fits into overall transportation goals for the state. The funds indeed are allocated into separate categories, highways in the case here, but you fail to connect how these separate categories of transportation add up to a cohesive whole. The explanation of how the freight transportation in the corridor affects the whole state is adequate, but this is just one part of the transportation system. The state of Wisconsin needs a total approach that articulates the connected nature of transportation at all levels of scale and mode, for all users, with attention to land use, economic, environmental, and social equity concerns. The lack of such an approach puts Wisconsin at an economic disadvantage. Transportation involves all mobility--from active transportation including walking and biking, to mass transportation and individual mobility--including modes for paths, sidewalks, streets, roads, highways, rail, water, and air. Indeed, the goal of ICM and CV technologies is to manage these resources together. Treating highways in isolation, without this perspective of how transportation and land use is a total system that can be managed together, with interrelated parts, is a mistake because it fails to capture the capacity and spirit of all the people of Wisconsin's diverse communities, goals, needs, and aspirations.

As a resident of Wisconsin, I wish you the best in your work because transportation touches the lives of everyone.


John December


Leong, Jeanne, "Study shows autonomous vehicles can help improve traffic flow," February 20, 2018,, Retrieved March 18, 2021 from

Litman, Todd. (2021, 5 March). Generated Traffic and Induced Travel: Implications for Transport Planning. Victoria Transport Policy Institute. Retrieved March 16, 2021 from

Milwaukee County, April 17, 2020, "Achieving Racial Equity and Health," County Code of General Ordinances, Ordinance No. 20-4, Retrieved March 18, 2021 from

Niemuth, Niles William. (2014). Urban Renewal and the Development of Milwaukee's African American Community: 1960-1980. Theses and Dissertations. University of Wisconsin--Milwaukee. 416. Retrieved March 18, 2021 from

Short, Aaron, "There is Structural Racism in Transport: Report," December 18, 2019, Streetsblog USA, Retrieved March 18, 2021 from

State of Wisconsin. (2020). Governor's Task Force on Climate Change Report. Retrieved March 18, 2021 from

Transportation for America. (2020). The Congestion Con: How more lanes and more money equals more congestion. Retrieved March 16, 2021 from

U.S. Department of Transportation, Federal Highway Administration. (2016). Integrated Corridor Management, Transit, and Mobility on Demand. Retrieved March 16, 2021 from

Social Media Comment on the I-94 East-West Corridor Study, Milwaukee - Milwaukee County

I prepared the following comment in response to a union representative who spoke about the I94 project.

2021-02-22 7:05 am

Supporting union jobs is a laudable goal, but there are better ways to do so while at the same time supporting our communities and jobs for the present and future. The primary mistake in thinking that I94 needs to be expanded is not realizing how modern highway use has changed from the last century. For decades now, peak car usage observations have shown that our highways are in less demand and the pandemic has demonstrated much lower needs for driving at peak times. Modern technology in signaling and intelligent vehicles will be able to better utilize highway space and make even our current highway capacity superfluous. Spending one billion dollars on what will essentially be unnecessary and unused pavement to bypass our communities is not a good use of money for our people and union members.

The legacy structure of I94 may be serviceable for some time to come, and adequate repair and maintenance of it now is reasonable, along with many union jobs involved in that repair and maintenance. A far better and more equitable use of the money would be to build diversity into our transportation options through urban passenger rail systems, the construction and operation of which can involve many union jobs. Diversity in transportation options will make our area more resilient in all kinds of challenges. Rubber-wheel passengers cars on highways, as demonstrated by recent events, is a poor transportation mode for our changing climate. Rail travel for passengers works all over the world for passenger traffic, and it frees up space on highways for essential truck traffic and intelligently-controlled vehicles.

By giving people who don't have, afford, or drive cars, less automobile-orientation in transit alleviates injustices resulting from decades of highway-only policies. Changing demographics and interest in living patterns mean that the peak-use of highways may indeed be a relic of the last century, and it would be unwise to build for it. Building, operating, and maintaining urban rail for transportation can build equity, address climate change, and provide family-supporting union jobs that put food on the table.

One billion dollars for what will ultimately likely be entirely unneeded highway capacity that will actually damage our communities by destroying more of it and drawing our area into further automobile-dependence is not a good use of scarce resources. Unions should be preparing for the future, in emerging technologies for transportation which is more diverse, more data-driven, more network-driven, and utilizes 5G, high-definition video, as well as vehicle-to-vehicle and vehicle-to- infrastructure communications. The future of transportation is more efficient, more community-oriented, and moving away from legacy automobile-dependent highways.

Comment on the I-94 East-West Corridor Study, Milwaukee - Milwaukee County

This is my comment on this plan's revision that I sent in via their public engagement process.

2021-12-30 3:45 pm

Thank you for your work. I am in favor of repairing I-94, but I am not in favor of expanding I-94. Your presentation does not provide convincing evidence that expansion is necessary or will address regional transportation goals, will grow our economy, or will be intelligently managed. Your work fails to draw on or reference worldwide practices and research for addressing regional, multimodal transportation in a modern (21st-century) context but relies mainly on 20th-century concepts about transportation. As such, you are committing an error by working for highway expansion (rather than repair and public transit service), and this error has been proven to be very costly to our economy, society, and environment for the past century.

In light of your work, you should get a different, outside team involved that has familiarity with 21st-century concepts and that can competently develop a less costly, intelligent 6-lane alternative as well as develop a 4-lane alternative with more public transit support and transportation management. With traffic usage patterns not increasing and changing due to different work patterns, the peak patterns your modeling assumes may be false assumptions and no longer be applicable to future highway use.

Your work lacks discussion of induced demand and how it will nullify any highway expansion, the use of Integrated Corridor Management which should be present at whatever size of the highway, public transit use to mitigate highway demand, tolling options to dampen demand, advanced technologies for intelligent vehicle navigation, a listing of the economic costs of the project including debt service, an enumeration of how this will be paid for, the levels of subsidies for automobile travel this provides, how this project impacts environmental goals and climate change, and how you address equity and accountability to the historic dislocations of urban populations by highway construction.

Ignoring these considerations means that this project will likely dampen our economic growth due to the enormous debt required to build and maintain it as well as the ineffectiveness of what is built. Your project, as it stands now, sends the world the impression that Wisconsin is firmly committed to the 20th-century, a signal that will not draw manufacturers or commerce to our region who seek an area with intelligently-designed, stable, sustainable transportation systems.

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2023-12-31 · John December · Terms ©