Shoulder access to South Mountain Freeway

R5-10a

ADOT recently completed and opened the South Mountain Freeway in late 2019; which was heralded — rightly so — as a great accomplishment that will provide a much needed connection between the communities of Ahwatukee and Laveen, or more broadly a direct connection between South East and West Valley, bringing for example enhanced employment opportunities. This publicly funded project (funded mostly from sales taxes [4] ), at present, and by default prohibits non-motorized users; this leaves members of the public who choose to or must travel by bicycle excluded.

The Coalition of Arizona Bicyclists (CAZBike) in September 2016 requested that ADOT evaluate access to a very small portion, between two adjacent traffic interchanges, pointing out lack of frontage roads or other suitable routes:

9/29/2016 “(CAZBike) formally request(s) a response from ADOT on allowing bicyclists to use paved shoulders to connect between the western end of the Ahwatukee Foothills and 51st Avenue [since that was written, the since-added Vee Quiva Way would now be the most appropriate western terminus, and 17th Avenue would be the logical eastern terminus because that would coincide with the western end of shared-use path ADOT has since constructed]

And partially reiterates 11/18/2016 “What is the status of my request … and my request that this be done formally with documented response? I want this to all be public record so I want to do it the right way”

We received the following response 4/20/2020 [1], this would be over three years after the request was made. Unfortunately, the response fails to take into account the policy referenced [2], no traffic study of alternate routes was mentioned, and the decision appears arbitrary. The referenced policy makes no mention of ‘metro’ (or ‘urban’,  or ‘rural)’. The reference to Table 1030-A as constituting documentation is specious — the route of the South Mountain Freeway portion of SR202 was not even sited for many years, possibly decades, after SR202 was added to that table. The policy demands a study, and that “Each case shall be judged on its own” yet it wasn’t.

We continue to request that ADOT prepare a traffic study of the area in question, and only then make a decision informed by those particular facts. Prohibiting bicyclists from using the shoulder may in fact be more dangerous; without an objective traffic study we cannot know. ADOT will need to assign the task to an engineer who is skilled in bicycle traffic; and should be familiar with the ADOT reference documentation[6], below.



In addition, it should be investigated how such matters get handled, as the process was frustrating, needlessly protracted, and at times even dishonest and non-professional. The personnel we were instructed to deal with which included at different times Mike Sanders (the bike/ped coordinator at the time the request was made), then on 6/8/2017 (per our meeting with Director Halikowski) Eric Gudino, and as of 12/6/2019 Mr. Gudino informed us our contact would be Donna Lewandowski (the current bike/ped coordinator). The few answers we received over the years were a mixture of: incomplete, lacking documentation, diversionary, falsehoods. See timeline[3]. It is quite clear after viewing some ADOT-internal emails dated 11/22 and 11/23/2020 at that time ADOT engineers were planning a traffic study, consistent with policy. Just after, all activity suddenly and secretly ceased; and we were never informed. We met in-person with numerous ADOT managers 6/8/2017, including Dallas Hammit, when the issue was raised by CAZBike, no one present had anything to say.

ADOT is a public agency and as such has a duty to operate openly and transparently.

 

[1] Formal Response

(full image here, below is text content); Note that it arrived over 3 years after the request was made.

ADOT State Engineer’s Office

April 20, 2020

Ed Beighe President
Coalition of Arizona Bicyclists
cazbike@cazbike.org

Dear Mr. Beighe:

At ADOT, our True North is “Safely Home.” Our goal, working with our transportation partners (metro planning agencies, cities and counties), is to provide an efficient highway system that safely meets the needs of all users. This requires ADOT to make difficult decisions to limit access on some portions of state highways.

I have reviewed the email correspondence requesting ADOT to approve bicycle access on Controlled Access Highways, specifically on the newly-opened Loop 202. Attempting to balance access with safety for all roadway users is difficult, and to that end, ADOT adopted traffic engineering guidance to determine when bicycle access will and will not be allowed on Controlled Access Highways. In some cases bicycles are allowed on controlled access roadways; such as in rural areas where there are no local roadway networks, such as sections of Interstates 8, 10, 17, 19 and 40. As Controlled Access Highways enter metropolitan areas where there is a local network of roads, bike lanes and bike paths, bicyclists are prohibited from using the Controlled Access Highways. Using this adopted traffic engineering guidance (attached), ADOT developed Table 1030-A. Table 1030-A documents ADOT’s decision to prohibit bicyclists on the entire length of SR 202.

Sincerely,
Dallas Hammit
Deputy Director for Transportation / State Engineer

To repeat from above: Unfortunately, the response fails to take into account the policy referenced [2], no traffic study of alternate routes was mentioned, and the decision appears arbitrary. The referenced policy makes no mention of ‘metro’ (or ‘urban’) or ‘rural’. The reference to Table 1030-A as constituting documentation is specious — the route of the South Mountain Freeway was not even sited for many years, possibly decades, after SR202 was added to that table. The policy demands a study, and that “Each case shall be judged on its own” yet it wasn’t.

Prohibiting bicyclists from using the shoulder may in fact be more dangerous; without an objective traffic study we cannot know.

.

[2] Policy: “Bicycles shall not be prohibited…”

ADOT’s written policy, which is referred to in the 4/20/2020 response letter, is 1030 Controlled-Access Highways as Bikeways, reads in relevant part (emphasis in original):

Bicycles as defined in Arizona Revised Statutes §28-101 are permitted by law to operate on all State highways, including controlled-access highways, except where excluded by administrative regulation and the posting of signs to give notice of a prohibition. Bicycles shall not be prohibited from controlled-access highways except under those conditions where alternate routes are available and where such alternate routes are considered comparable or better in terms of convenience and safety

and that “Each case shall be judged on its own”.

ADOT’s policy is very inclusive and reasonable; and should be commended for it. No one wants to or needs to bicycle on a shoulder when a preferable route is available.

 

[3] Timeline

Email chain indicates a flurry of activity soon after inital request made September 2016,  that all suddenly (and secretly) ceased in late November 2016.
It documents that numerous actors within ADOT were well aware, and obviously grasped the situation with regard to the need to formally study the issue.
We were never advised of any outcome, until an email on 1/22/2020 that claimed to describe an outcome (without any documentation).

  1. Bob Beane 9/29/2016 (in attached email) Initial request;
    Michael Sanders replied same day copying Maysa Hanna, Madhu Reddy, Raul Amavisca, and Richard Moeur with policy statements “…bicycles shall not be prohibited from controlled-access highways except…”
  2. Bob Beane 11/18/2016 (attached email): “What is the status of my request … and my request that this be done formally with documented response? I want this to all be public record so I want to do it the right way. I plan to go back to the bicycling community with the details of who considered the request and what the basis is for their decision, pro or con”
  3. Scott Beck said on 11/22/2016 “We have a request from the Coalition of Arizona Bicyclists… Basically, our guidelines indicate that bikes are allowed if there aren’t parallel routes available… There will need to be a formal study/recommendation on the usage”
  4. Richard Moeur 11/23/2016 “If bicyclists are permitted to use the shoulders of 202 between 17th Avenue and Estrella Drive (no intermediate TIs), there shouldn’t be extraordinary exposure to high-risk conflicts, especially given the lack of ramp weaving and self-selecting nature of freeway shoulder users observed elsewhere in the state. However, per the TGP, the route would still need to be justified for access in terms of convenience and safety.”
  5. 11/23/2016: Meeting called by Maysa Hanna was scheduled to occur 12/2/2016 (but then cancelled and never rescheduled) involving Richard Moeur; Scott Orrahood; Robert Samour; Steve Mishler; Scott Beck; Kerry Wilcoxon; Michael Sanders; Raul Amavisca; Tony Abbo;
  6. Michael Sanders 12/1/2016 (in attached email) to Eunice Lee “Will meeting be rescheduled in the next week?”; 12 minutes later Eunice: “Hi Maysa, Please respond to Michael”; which Michael reports was never answered. (We learned this as of May 25, 2017; see email chain, below)
  7. 4/27/2017 Met in person with ADOT director and upper-management; the agenda was set by us, and included overall general bicyclist topics. The shoulder-use request was not discussed; at this time we were under the reasonable assumption that it was still being evaluated.
  8. 6/8/2017 Met in person at ADOT; most time was spent discussing other, unrelated matters.
    I briefly brought up that we had a pending shoulder-use request, hoping to get something, at least status. No one present said anything; when I asked how we move forward was told Eric G would be our “primary contact and ombudsman”. This meeting was attend by in addition to Director Halikowskii: Eric Gudino,  Todd Emery and Dallas Hammit were also in attendance
  9. 1/2/2018 from Mike Sanders personal email (found/unearthed this email much later; this is in a whole different email thread entitled “Notes from 6/8/2017 ADOT / Bicycling Meeting”):
    “talked with Eric Gudino today. He said shoulder use of SMF – 17th Ave to Estrella Dr – is a “no” per State Engineer’s Office (and that the decision was made last year?). He understood cities and MAG (?) were working with GRIC on (shared use) path extension around mountain. I told Eric I had heard nothing on that since one year ago to the day when it had been stated, “The City of Chandler was going to take the lead on this” (apparently because they had an established relationship with GRIC?)”
  10. 2/4/2018 Ed Beighe to Eric Gudino: “Eric: please address the status of shoulder request.”
    2/5/2018 Eric replies: “Please call me at your earliest convenience to discuss.”
    2/5/2018 phone call between Ed and Eric: Eric does not provide any status on the request, deflecting any questions; referring only to a road or path that GRIC may someday build, and adot would have nothing to do with.
  11. 12/5/2019 Ed Beighe to Eric Guidino requesting status of request.
    12/5/2019 Eric Gudino replies with deflections about GRIC, and no mention of the status of our request.
    12/6/2019 Ed Beighe to Eric Guidino: “Let me make clear — we are renewing and once again requesting ADOT to evaluate bicyclist access… ”
    12/6/2019 Eric Gudino to Ed Beighe: “I’ve sent your request to our Bicycle and Pedestrian Program Coordinator, Ms. Donna Lewandowski so that she may begin the process”
  12. 12/6 through later part of December, 2020 Donna suggested to set up time to talk on phone. Several exchanges were made regarding setting a time but Donna’s schedule didn’t allow that to happen, and then the holidays delayed everything.
  13. 1/22/2020 Ed Beighe to Donna Lewandowski “I continue to request an answer per the Adot policy noted earlier… Why won’t you, or anyone at adot answer? If there is an answer — what is it based on?”
  14. 1/22/2020 Donna Lewandowski replies, and I note this the only explanation, after over three years, we’ve ever received, it’s also devoid of evidence:
    “I believe ADOT’s decision has been made, that it wouldn’t be safe to allow bicycling on the shoulders due to the speed differential (particularly on the uphill sections), amount of traffic, and likelihood of large groups of cyclists due to the urban context. Incidentally, while this all happened before I was employed with ADOT, I have been told that the decision was made by Richard Moeur, who authored the documents below and at the time was the ADOT Traffic Standards Engineer…”
  15. 1/22/2020 “great so i am looking forward to reading this analysis that states those conclusions”
  16. 1/24/2020 sidebar between Ed Beighe and Richard Moeur (private correspondence, not included here; it does not comport with what Donna Lewandowski wrote on 1/22 email), in fact here is what RM said 11/23/2016 (see above) indicating he believed, at least on its face, access would not result in “high risk exposure”.
  17. 1/24/2020 Ed Beighe to Donna Lewandowski “I am still waiting (for over three years and counting) for some form of documentation “ADOT’s decision” you alluded to in your email”
  18. 1/31/2020 Ed Beighe to Donna Lewandowski “Regarding my last email of Jan 24, I have not heard back from you: Are you unable to locate any documentation?…”
    (also left voicemail summarizing email)
  19. 4/10/2020 Ed Beighe to Donna Lewandowski “Regarding my un-answered emails (1/24, and 1/31) and voicemails (also 1/31) to you; I am still waiting for you to provide me with documentation on this request”
  20. 4/20/2020 (1PM) Ed Beighe to Donna Lewandowski; sent a copy of Interstate 15 Bicyclist Access Analysis conducted in 2005 produced by ADOT to Donna: “This is what an analysis looks like”.
  21. 4/20/2020 (4:30PM) Dallas Hammit to Ed Beighe “formal” answer; see above for full letter.

 

 

[4] Funding

Arizona’s most expensive highway project in history was recently opened  in very late 2019. In addition to providing a route which avoids downtown Phoenix, it provided much more convenient access between the SE and West Valley, in particular provides a vital link between the communities of Ahwatukee (a part of Phoenix) and Laveen; Gov Ducey declaring it “connects the East Valley and West Valley in ways that will impact the region’s economy for decades” and “enable our state’s growth for generations to come”. It’s open to the public, or more specifically the motoring public who have access to a private automobile, since bicycles are forbidden, and there’s virtually no public transportation.

It should interest everyone to know how the project is funded, because everyone knows that gas taxes pay for roads, right? Wrong, it’s mostly funded from sales taxes.

According to info posted on the FHWA website the Loop 202 / South Mountain Freeway cost nearly $2Billion (excluding financing costs), and has the following funding sources. Note that the largest funding source is a SALES TAX. ($702M, RARF) and and the 2nd largest source are bonds which will be paid off with SALES TAXES ($435M, RARF bond).

Cost $1.837 billion (YOE, not including financing costs)
Funding Sources Federal funds – $493.8 million
State Highway User Revenue Fund Bonds – $205.9 million
Regional Area Road Fund (1/2-cent sales tax) – $702.4 million
Regional Area Road Fund Bonds – $435.3 million

             retrieved from https://www.fhwa.dot.gov/ipd/project_profiles/az_loop_202.aspx

most expensive: “Ducey and others hailed the achievement, which at $1.7 billion is the most expensive single highway project in state history, saying it ‘connects the East Valley and West Valley in ways that will impact the region’s economy for decades’ and ‘enable our state’s growth for generations to come.’ ”

[5] Route Comparison

ADOT refuses, without any explanation, to conduct a traffic study. For reference, then, here are the routes that would need to be compared.

A traffic study is required to comply with ADOT policy[2]. Any such study would need to compare the route along the shoulder as to convenience and safety to whatever available alternative routes exist. Despite the claim in ADOT’s refusal letter[1] that “there is a local network of roads, bike lanes and bike paths” available, the shortest alternative route is OVER SIX TIMES LONGER.

Red Route (freeway shoulder)

Length: 4.6 miles

Elevation change: +323/-389 (start at green pin, end at red); some of it brief and steep.

Number of conflict points: Nearly zero (there are no intervening interchanges, no driveways, one intersection with one turn when westbound)

Conditions: Consistent, very wide shoulders along entire length. Posted speed limit very high (65mph), one-way traffic only (separated).

 

Blue Route (local roads)

Length: 28.7

Elevation change: +276/-336

Number of conflict points: numerous intersections and driveways.

Conditions: Highly variable. Posted speed limits mostly high to very high (55 – 65mph), some 35mph. Shoulders variable; some with rumble strips. Two-way traffic throughout (risk of cross-over). Much of the route is isolated, miles away from nearest services.

 

 

 

 

 

Phoenix City Council Districts: 6 DiCiccio (Ahwatukee), 7 Nowakowski & 8 Garcia (Laveen area)

 

 

 

Below are a couple of potential trails which might provide viable alternative routes:

— the light blue would connect between existing road networks, utilizing the overpass at approximately 35th Ave (I believe this is referred to as a “wildlife underpass”?) and would connect between City of Phoenix’s Shaunessy / 35th Ave and GRIC’s(?) Pecos Road. Pecos there appears to be graded gravel, transitioning to paved as it continues west to 51th Ave. This option would be less convenient for bicyclists using the new SUP

— the fusia colored path would be essentially be a westward continuation of the new SUP. It should be able to continue for some distance on City of Phoenix(?), and at some point becomes GRIC(?) and would connect same as above at Pecos Road.

 

 

[6] Other References

Anyone studying the issue should become familiar with the excellent reference material produced by ADOT:

Bicycle – Motor Vehicle Collisions  on Controlled Access Highways  in Arizona (copy)  Richard C. Moeur, PE Traffic Design Manager, Northern Region; Michelle N. Bina, Traffic Design Section. Arizona Department of Transportation, Intermodal Transportation Division, Traffic Engineering Group.
As expected, bike-MV crashes along controlled access highways are rare, less than one per year on average.

Interstate 15 Bicyclist Access Analysis Richard C. Moeur, PE Traffic Design Manager, Northern Region; Arizona Department of Transportation, Intermodal Transportation Division, Traffic Engineering Group. February 2005.

 

 

See also

cazbike.org/adot-to-build-high-speed-path-along-202-freeway/ — The path is between 40th St and 17th Ave; just east of the segment discussed here.
cazbike.org/south-mountain-freeway-shared-use-path/ — path set to open Oct 19, 2020.
cazbike.org/beane-adot-needs-to-broaden-its-concept-of-transportation/
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