An analysis of the Colorado state government’s flawed plan for I-25

Issue Paper

By Stephen R. Mueller, P. E. and Dennis Polhill, P. E.


This report presents a detailed analysis and critique of the Southeast Corridor plan for Interstate 25 through Denver. The authors spent nearly six months gathering the baseline data and developing the methodology and new analysis tools contained in the report.

It is a timely report for two reasons:

1) The public comment period for the Draft Environmental Impact Statement was still open at the time the full report was published. The report was submitted into the official record to show that there is a better way to analyze a project’s impacts on the public than was presented in the DEIS.

2) The November 1999 ballot contains two measures directly relating to the information contained in this report. Referendum “A”; a statewide ballot issue, is seeking voter approval to bond future federal highway revenues. In the Denver metropolitan area, voters are being asked to allow the Regional Transportation District (RTD) to bond their tax revenues.

Findings of Importance Contained in the Report:
“The goal must be to create a transportation system that offers congestion free driving, better environmental outcomes, and lower taxpayer costs.”


The “official” documents relating to the proposed “improvements” on Interstate 25 show light rail will have no impact on traffic congestion. The conclusion isn’t clearly stated, but is hidden in the numbers and tables contained in the documents.

Proponents of 4A, the more light rail boondoggle proposal, shout that the plan will “take 17,000 cars off the road.” Not only is the statement preposterous, it is NOT a measurement of the traffic congestion that will exist on the freeway. All of the official documents show numerous areas throughout the project and on surrounding facilities where the projected level of service will be rated “F” -which means a completely congested, gridlock condition. Forget the rest of the rhetoric, light rail will NOT solve the problem. It is in the official documents, and finding is further supported in the analysis provided in this report.

Special Interests, particularly in the Southeast Corridor and downtown Denver, have made large contributions to the campaign to build light rail to the Denver Technological Center (DTC) under the mistaken impression that traffic will flow more smoothly if enough people ride the new trolley. There will only be a maximum of eight trolleys per hour running to the DTC, and the 1997 Major Investment Study (MIS) supporting a “light rail only” solution projected that ridership would increase from 1.8% of DTC employees to 3.2%. Even if RTD was able to increase their market share by this amount, it is simply not enough people to have any impact on the highway. Normal traffic growth and latent demand will prevail, and the highway will gridlock.


This report shows that the DEIS recommended “preferred alternative,” which does not involve user pricing, would result in zero improvement in traffic congestion over the 1996 condition the on the very day it opens. Again, there are lots of “Level of Service F” ratings contained in the DEIS. The ever-increasing traffic growth, combined with latent demand (as explained in the complete report), indicate that the CDOT’s new road will be gridlocked on the day it opens.

Under the plan presented by CDOT and RTD, motorists are stuck in gridlocked traffic today, they will be stuck in gridlocked traffic during construction, but what is worse is that they will be doomed to gridlocked traffic on the day this new project opens and forever into the future. Motorists who have survived the construction process will not be pleased.


This report clearly shows that in order to achieve congestion free driving on I-25, a pricing mechanism must be implemented. This report recommends that the existing three free lanes on I-25 be supplemented with new High Occupancy Toll (HOT) Lanes. High occupancy vehicles, such as buses, vanpools, company carpools, and taxicabs would be guaranteed access into the new lanes. The remaining capacity is then sold to people in single occupant automobiles who are willing to pay a toll to use the facility. The price of the toll is variable, depending on the amount of traffic in the HOT lanes. HOT lanes are currently being successfully used in California and Texas, so the technology and benefits of this system has already been proven. People would still be able to choose the free lanes – and the traffic flow in the free lanes will be improved as a result of people who are willing to pay a toll to drive even faster.

HOT lanes offer a future of congestion free driving, and those who receive this benefit will be the ones who pay the costs of the highway improvements. HOT lanes offer far more choices to people than fixed-guideway mass transit systems, and they are environmentally superior and more tax-payer friendly than either light rail or new free lanes.


Many people are being misled about the Environmental Impact Statement process: Public policy is being driven awry by the threat of lawsuit. The United States Environmental Protection Agency has NO AUTHORITY to dictate a specific transportation technology. It is simply not true that if the voters turn down light rail, as it has been in the past, that the highway can’t be widened.

What is true, however, is that any new plan will have to demonstrate “conformity” with the EPA approved air quality plans. The HOT lane proposal contained in this document should easily meet the EPA criteria. This report indicates that HOT lanes offer the ability to achieve a 29% larger reduction in mobile emissions than the plan presented in the DEIS. This plan, therefore, is more environmentally friendly than the DEIS. The official models, however, would still have to be run, which could delay construction for another year. The question voters should ask themselves is “Am I willing to wait a year for a new plan to be developed if I can save myself THREE BILLION DOLLARS?” – Any new plan will include additional highway lanes on I-25. We the People demand it!


Light Rail is hardly rapid transit. The current LRT system speed in Denver is between 15′ and 20 miles per hour. Because the proposed SE corridor light rail would have to merge into this system, it can’t operate at an average speed that is much faster. The travel time from Park Meadows to Downtown Denver will approach a full hour on the new trolley. HOT lanes, offering congestion free driving for most of the distance at 55 miles per hour, will get people downtown in a fraction of the time.


The planning process has been manipulated by special interests, even to the point that blatant mistruths were included in early versions of “official” documents. The MIS and DEIS are hardly more than propaganda pieces intended to rationalize the view favoring light rail transit (LRT). A number of flaws in the DEIS for the I-25 southeast corridor are presented in the report:

A) Failure to adequately scope and analyze the available alternatives.
B) Predetermined LRT placement precludes adequate analysis in the DEIS.
C} Predetermined LRT placement will result in tremendous unaccounted-for future costs to upgrade I-25 in order to resolve future traffic congestion problems.
D) Failure of the DEIS to adequately address the costs and benefits of the various configurations for potential use of the ROW.
E) Traffic growth projections in the DEIS are limited and weakly analyzed.
F} Latent Demand has not been adequately addressed in the document.
G) Impulse driving impacts on congestion were not considered due to limitations in the scoping process.
H) The counting methodology for automobiles versus LRT boardings is inherently flawed.
I) There was inadequate discussion of the potential costs of obtaining additional ROW or providing an alternative engineering solution in several bottleneck areas north of I-225.
J) HOT lanes, given no mention in the DEIS, have been shown to be a substantially superior solution in this report.


Governor Owens and the Colorado Transportation Commission have declared that the majority of the bonds would be used to finance the project analyzed in this report. The measure itself, however, does not specify the actual projects that would be advanced or added if the referendum passes.

In order to construct the HOT lanes, however, it will be necessary to issue bonds. The toll revenues, rather than general tax dollars, will be used to pay off the bonds. This would allow the bond money authorized by Referendum A to be used on other projects throughout Colorado, as designated by the Transportation Commission.


It is clear from this report that the plans to place LRT in the SE Corridor must be stopped. The ROW is needed in order to achieve the socially optimal usage for this transportation facility. RTD should instead plan to invest in additional buses that can use the congestion free HOT lanes, and operate at higher speeds than can be achieved by- LRT. LRT will doom the Denver metro area to subsidies and future tax increases, and a decreasing proportion of people riding mass transit. The increases in the local costs already presented the LRT’s ever changing cost estimates should outrage voters. The greatest cost, however, will be the future need to double-deck I-25 — wasting literally billions of tax dollars that can be saved by using the ROW now. LRT is not financially, environmentally, or functionally justifiable for the I-25 Southeast Corridor. HOT lanes fulfill all the criteria, and those who receive the benefits will pay the costs.

Entire Paper: Let Those Who Receive The Benefits Pay the Costs (PDF)

Copyright (C) 1999 – Independence Institute