I-205 Toll Project Environmental Assessment - 508

I-205 Toll Project
Environmental Assessment
February 2023
I-205 Toll Project
This page intentionally left blank.
www.OregonTolling.org
I-205 Toll Project
February 2023
I-205 Toll Project
I-205 Toll Project
I-205 Toll Project

ODOT Key Number: 21371
Submitted Pursuant to 42 U.S.C. 4332 (2)(c) and where applicable, 49 U.S.C. 303
by U.S. Department of Transportation, Federal Highway Administration and
Oregon Department of Transportation
DOUGLAS Digitally signed by DOUGLAS
RICHARD HECOX
RICHARD HECOX Date: 2023.02.14 13:00:21 -08'00'
Keith Lynch, Division Administrator, Federal Date of Approval
Highway Administration, Oregon Division
February 14, 2023

Mandy
ndy Putney, Strategic Initiatives
Initiatives Director, Date of Approval
Oregon Department of Transportation, Urban
Mobility Office
The following persons may be contacted for additional information concerning this document:
Mandy Putney Thomas Parker

ODOT Urban Mobility Office FHWA Oregon Division
SW Boones Ferry Road 530 Center Street NE, Suite 420
Tualatin, OR 97224 Salem, OR 97301
(503) 837-3536 (503) 316-2549
Abstract:
The Oregon Department of Transportation (ODOT) is proposing to implement tolls on the Interstate 205
(I-205) Abernethy Bridge and Tualatin River Bridges to raise revenue for construction of planned
improvements to I-205, including seismic upgrades and widening, and to manage congestion. This
Environmental Assessment, developed by ODOT in partnership with the Federal Highway Administration,
presents an evaluation of the effects of tolls and the toll-funded I-205 improvements on the human and
natural environment in accordance with the National Environmental Policy Act.
I-205 Toll Project
I-205 Toll Project
Notice of Document Availability

This Environmental Assessment is available for review at the following locations:
Oregon City Public Library Tualatin Public Library

606 John Adams Street 18878 SW Martinazzi Avenue
Oregon City, OR 97045 Tualatin, OR 97062
(503) 657-8269 (503) 691-3074
West Linn Public Library Canby Public Library

1595 Burns Street 220 NE 2nd Avenue
West Linn, OR 97068 Canby, OR 97013
(503) 656-7853 (503) 266-3394
These documents are also available on the I-205 Toll Project website:
https://www.oregon.gov/ODOT/tolling/Pages/I-205-Tolling.aspx.
How to Submit Comments

Written comments on the Environmental Assessment can be submitted during the public comment period
(February 21, 2023, to April 7, 2023) by email to I205TollEA@odot.oregon.gov or by regular mail to:
Mandy Putney
ODOT Urban Mobility Office
18277 SW Boones Ferry Road
Tualatin, OR 97224
Comments also can be submitted in writing through a form accessible via the project website
(https://www.oregon.gov/ODOT/tolling/Pages/I-205-Tolling.aspx) and orally at a public hearing for the
Environmental Assessment. Details on the public hearing date, time, and location can be accessed online
at: https://www.oregon.gov/ODOT/tolling/Pages/I-205-Tolling.aspx.
Comments may also be submitted by leaving a voice message on the I-205 Toll Project’s comment line at
503-837-3536 during the comment period. Except for voice messages and oral testimony at the virtual
public hearing, which will be transcribed, comments must be submitted in writing.
I-205 Toll Project
Si desea obtener información sobre este proyecto traducida al español, sírvase llamar al 503-731-4128.
Nếu quý vị muốn thông tin về dự án này được dịch sang tiếng Việt, xin gọi 503-731-4128.
Если вы хотите чтобы информация об этом проекте была переведена на русский язык,
пожалуйста, звоните по телефону 503-731-4128.
如果您想瞭解這個項目，我們有提供繁體中文翻譯，請致電：503-731-4128
如果您想了解这个项目，我们有提供简体中文翻译，请致电：503-731-4128
For Americans with Disabilities Act or Civil Rights Title VI accommodations, translation/ interpretation
services, or more information call 503-731-4128, TTY (800) 735-2900 or Oregon Relay Service 7-1-1.
I-205 Toll Project
Table of Contents
1 Introduction ............................................................................................................... 1-1
1.1 Location ............................................................................................................................. 1-1
1.2 Background and Context.................................................................................................... 1-2
1.3 Purpose ............................................................................................................................. 1-4
1.4 Need ................................................................................................................................. 1-4
1.4.1 Critical Projects Need Construction Funding .............................................................................. 1-4
1.4.2 Traffic Congestion Results in Unreliable Travel.......................................................................... 1-4
1.4.3 Traffic Congestion Affects Freight Movement............................................................................. 1-5
1.4.4 Traffic Congestion Affects Safety .............................................................................................. 1-5
1.4.5 Traffic Congestion Contributes to Climate Change ..................................................................... 1-5
1.4.6 Oregon’s Highway System is Not Seismically Resilient .............................................................. 1-6
1.5 Goals and Objectives ......................................................................................................... 1-6
1.6 Next Steps ......................................................................................................................... 1-7
2 Project Alternatives ................................................................................................... 2-1
2.1 Alternatives Assessed in this Environmental Assessment................................................... 2-1
2.1.1 No Build Alternative .................................................................................................................. 2-1
2.1.2 Build Alternative ....................................................................................................................... 2-1
2.2 Alternatives Considered but Not Advanced ........................................................................ 2-8
2.2.1 Alternative 1: Abernethy Bridge Toll .......................................................................................... 2-9
2.2.2 Alternative 2: Abernethy Bridge Toll with Off-Bridge Gantries ................................................... 2-10
2.2.3 Alternative 4: Segment-Based Tolls – Between Stafford Road and OR 213 .............................. 2-11
2.2.4 Alternative 5: Single-Zone Toll – Between Stafford Road and OR 213 ...................................... 2-12
3 Affected Environment, Environmental Consequences, and Mitigation ................. 3-1
3.1 Transportation ................................................................................................................... 3-1
3.1.1 Affected Environment ............................................................................................................... 3-1
3.1.2 Environmental Consequences................................................................................................... 3-9
3.1.3 Summary of Effects ................................................................................................................ 3-30
3.1.4 Avoidance, Minimization, and/or Mitigation Measures .............................................................. 3-31
3.2 Air Quality ........................................................................................................................ 3-45
3.2.1 Affected Environment ............................................................................................................. 3-45
3.2.2 Environmental Consequences................................................................................................. 3-47
3.3 Climate Change ............................................................................................................... 3-51
3.4 Economics ....................................................................................................................... 3-55
3.5 Noise ............................................................................................................................... 3-64
3.6 Visual Quality................................................................................................................... 3-68
3.7 Social Resources and Communities ................................................................................. 3-70
www.OregonTolling.org Page i
I-205 Toll Project
3.8 Environmental Justice ...................................................................................................... 3-86

3.8.5 Preliminary Environmental Justice Determination .................................................................... 3-99
3.9 Land Use ....................................................................................................................... 3-100
3.9.1 Affected Environment ........................................................................................................... 3-100
3.9.2 Environmental Consequences............................................................................................... 3-103
3.9.3 Summary of Effects .............................................................................................................. 3-106
3.9.4 Avoidance, Minimization, and/or Mitigation Measures ............................................................ 3-106
3.10 Geology and Soils.......................................................................................................... 3-106
3.11 Hazardous Materials ...................................................................................................... 3-109
3.12 Historic and Archeological Resources ............................................................................ 3-111
3.13 Vegetation and Wildlife .................................................................................................. 3-113
3.14 Wetlands and Water Resources ..................................................................................... 3-116
3.14.4 Avoidance, Minimization, and or Mitigation Measures ............................................................ 3-119
3.15 Cumulative Impacts ....................................................................................................... 3-119
3.15.2 Potential Cumulative Impacts by Resource ............................................................................ 3-123
4 Public Involvement, Agency Coordination, and Tribal Consultation ..................... 4-1
4.1 Equity-Focused Engagement ............................................................................................. 4-1
4.1.1 Equity and Mobility Advisory Committee .................................................................................... 4-1
4.1.2 Historically and Currently Excluded and Underserved Communities ........................................... 4-1
4.2 Public Outreach ................................................................................................................. 4-2
4.3 Agency Coordination.......................................................................................................... 4-4
4.3.1 Lead Agencies ......................................................................................................................... 4-4
4.3.2 Cooperating Agencies .............................................................................................................. 4-4
4.3.3 Participating Agencies .............................................................................................................. 4-4
4.3.4 Project Working Groups and Agency Briefings........................................................................... 4-5
4.3.5 Mitigation Workshops with Local Jurisdictions............................................................................ 4-5
4.4 Tribal Consultation ............................................................................................................. 4-6
4.5 Summary of Input Considered in this Environmental Assessment....................................... 4-7
5 Preparers ................................................................................................................... 5-1
6 References ................................................................................................................. 6-1
7 Glossary ..................................................................................................................... 7-1
www.OregonTolling.org Page ii
I-205 Toll Project
Figures
Figure 1-1. I-205 Toll Project Area .................................................................................................... 1-1
Figure 2-1. Schematic Diagrams of No Build and Build Alternatives .................................................. 2-2
Figure 2-2. Build Alternative: Bridge Tolls – Abernethy Bridge and Tualatin River Bridges ................. 2-3
Figure 2-3. Electronic Toll System .................................................................................................... 2-4
Figure 2-4. Alternative 1: Abernethy Bridge Toll ................................................................................ 2-9
Figure 2-5. Alternative 2: Abernethy Bridge Toll with Off-Bridge Gantries ........................................ 2-10
Figure 2-6. Alternative 4: Segment-Based Tolls – Between Stafford Road and OR 213 ................... 2-11
Figure 2-7. Alternative 5: Single-Zone Toll – Between Stafford Road and OR 213........................... 2-12
Figure 3-1. Transportation Area of Potential Impact .......................................................................... 3-2
Figure 3-2. Pre-pandemic Year (2019) Average Weekday Daily Traffic Volumes in Area of
Potential Impact and Surrounding Roadways .................................................................. 3-4
Figure 3-3. Existing Year (2021) High Crash Locations and Safety Priority Index System
Locations (2015 through 2019) ....................................................................................... 3-8
Figure 3-4. Projected 2045 No Build and Build Alternative Daily Traffic Volumes in Area of
Potential Impact and along Key Study Corridors ........................................................... 3-13
Figure 3-5. Projected Build and No Build Peak-Hour Volumes Percent Change on Key
Roadways in 2045 ........................................................................................................ 3-16
Figure 3-6. 2045 No Build vs. Build (Build minus No Build) Peak-Hour Travel Times for Key
Roadways .................................................................................................................... 3-20
Figure 3-7. Summary of Intersection Effects in 2027 and 2045 in the Area of Potential Impact ........ 3-23
Figure 3-8. Summary of Intersection Effects in 2027 and 2045 the Area of Potential Impact
within Oregon City, West Linn, Gladstone ..................................................................... 3-24
Figure 3-9. Air Quality Area of Potential Impact............................................................................... 3-46
Figure 3-10. Economics Area of Potential Impact.............................................................................. 3-56
Figure 3-11. Monetized Value of the Effects of Increasing Traffic Volumes over Time,
Comparing the No Build Alternative to Current Conditions (in discounted millions
2021$) .......................................................................................................................... 3-58
Figure 3-12. Monetized Value of the Effects of Increasing Traffic Volumes over Time,
Comparing the Build Alternative to the No Build Alternative and Current Conditions
(in discounted millions 2021$) ....................................................................................... 3-60
Figure 3-13. Noise Area of Potential Impact...................................................................................... 3-64
Figure 3-14. Estimated Change in Future Non-Highway Traffic Noise Levels – Existing
Conditions to 2045 Build Alternative.............................................................................. 3-67
Figure 3-15. Social Resources and Communities Area of Potential Impact........................................ 3-72
Figure 3-16. Environmental Justice Concentrations within the Area of Potential Impact..................... 3-87
Figure 3-17. Section 4(f) and Section 6(f) Resources and Properties in the Area of Potential
Impact ........................................................................................................................ 3-102
Figure 3-18. Land Use Impacts....................................................................................................... 3-105
Figure 3-19. Rock Cut Limits .......................................................................................................... 3-108
Figure 3-20. Present Actions and Reasonably Foreseeable Future Actions..................................... 3-121
www.OregonTolling.org Page iii

I-205 Toll Project
Tables
Table 2-1. List of Anticipated Environmental Permits and Approvals ................................................ 2-8
Table 3-1. Difference in Daily Regional Vehicle Miles Traveled and Vehicle Hours Traveled in
2045: Build Alternative Minus No Build Alternative ........................................................ 3-10
Table 3-2. Comparison of Trips by Travel Mode in 2045: Build Alternative to No Build
Alternative .................................................................................................................... 3-11
Table 3-3. Projected Peak-Hour Volumes on I-205 Segments in 2045: No Build and Build
Alternatives .................................................................................................................. 3-14
Table 3-4. Peak-Hour Volumes on Key Roadways – No Build and Build Alternatives ..................... 3-15
Table 3-5. Build versus No Build Daily Hours of Congestion on I-205 in 2045 ................................ 3-17
Table 3-6. No Build and Build Alternative Average Peak-Hour Travel Times on I-205 between
I-5 and SE 82nd Drive (minutes) in 2045....................................................................... 3-18
Table 3-7. Summary of Intersection Impacts .................................................................................. 3-25
Table 3-8. Truck Freight Corridor Travel Times for 2045 Build and No Build Alternatives
(minutes) ...................................................................................................................... 3-27
Table 3-9. Intersections with Safety Impacts under Build Alternative Based on Criteria
Evaluation .................................................................................................................... 3-29
Table 3-10. Key Roadway Segments with Safety Impacts under Build Alternative Based on
Criteria Evaluation ........................................................................................................ 3-29
Table 3-11. Summary of Transportation Effects by Alternative ......................................................... 3-30
Table 3-12. Proposed Mitigation for OR 99E/Gladstone/Oregon City Area ....................................... 3-33
Table 3-13. Proposed Mitigation for OR 99E/Canby Area ................................................................ 3-37
Table 3-14. Proposed Mitigation for Willamette Falls Drive/West Linn Area ...................................... 3-39
Table 3-15. Proposed Mitigation for SW Stafford Road and SW Borland Road Area ........................ 3-40
Table 3-16. Proposed Mitigation for OR 43/Lake Oswego Area ....................................................... 3-41
Table 3-17. Proposed Mitigation for the Tualatin Area...................................................................... 3-42
Table 3-18. MSAT Emissions (tons per year)................................................................................... 3-48
Table 3-19. 2027 Daily Vehicle Miles Traveled Changes within Area of Potential Impact.................. 3-48
Table 3-20. 2027 Benzene Emission Details (tons) .......................................................................... 3-49
Table 3-21. 2027 Diesel Particulate Matter Emission Details (tons).................................................. 3-49
Table 3-22. Annual Modeled Criteria Pollutant Emissions ................................................................ 3-50
Table 3-23. Summary of Air Quality Effects by Alternative ............................................................... 3-50
Table 3-24. No Build Alternative Annualized Maintenance Energy Use and GHG Emissions............ 3-52
Table 3-25. No Build Alternative CO2e Emissions ............................................................................ 3-52
Table 3-26. Build Alternative Annualized Construction Energy Use and GHG Emissions ................. 3-53
Table 3-27. Build Alternative Annualized Maintenance Energy Use and GHG Emissions ................. 3-53
Table 3-28. Build Alternative CO2e Emissions ................................................................................. 3-54
Table 3-29. Total Economic Effects Related to Toll System Construction (2024-2027) ..................... 3-59
Table 3-30. Annualized Economic Benefits Related to Consumer Spending under the Build
Alternative Relative to No Build Alternative (2027 to 2045) ............................................ 3-60
Table 3-31. Household Effects Related to Toll Revenue Operations ................................................ 3-61
Table 3-32. Comparison of Median Household Budget and Transportation Costs in the Area of
Potential Impact under the No Build Alternative and Build Alternative (in 2021$,
rounded) ....................................................................................................................... 3-61
Table 3-33. Change in Estimated Annualized Spending by Industry (2027 to 2045) ......................... 3-62
Table 3-34. Summary of Annualized Economic Effects related to Toll Revenue Operations
(2027 to 2045) .............................................................................................................. 3-62
Table 3-35. Summary of Economics Effects by Alternative .............................................................. 3-63
Table 3-36. Demographic Groups in the Area of Potential Impact .................................................... 3-73
Table 3-37. Social Resources and Communities Effects by Alternative ............................................ 3-84
Table 3-38. Environmental Justice Demographic Groups in the Area of Potential Impact ................. 3-88
Table 3-39. Percentage of Income Spent on Transportation ............................................................ 3-92
Table 3-40. Environmental Justice Effects ....................................................................................... 3-95
Table 3-41. Summary of Mitigation Measures to Address Adverse Effects on Environmental
Justice Populations....................................................................................................... 3-98
www.OregonTolling.org Page iv
I-205 Toll Project
Table 3-42. Summary of Land Use Effects by Alternative............................................................... 3-106

Table 3-43. Summary of Geology and Soils Effects by Alternative ................................................. 3-109
Table 3-44. Summary of Hazardous Materials Effects by Alternative.............................................. 3-111
Table 3-45. Summary of Historic and Archaeological Resources Effects by Alternative .................. 3-112
Table 3-46. Anadromous Fish Species and Habitats of Concern in the Area of Potential Impact .... 3-114
Table 3-47. Summary of Vegetation and Wildlife Effects by Alternative .......................................... 3-116
Table 3-48. Summary of Wetlands and Water Resources Effects by Alternative ............................ 3-118
Table 3-49. Present Actions and Reasonably Foreseeable Future Actions..................................... 3-122
Table 5-1. List of Preparers ............................................................................................................. 5-1
www.OregonTolling.org Page v
I-205 Toll Project
Appendices
Appendix A Comparison of I-205 Screening Alternatives Technical Report
Appendix B I-205 Toll Project Performance Measures
Appendix C I-205 Toll Project Transportation Technical Report
Appendix C1 I-205 Toll Project Mitigation Workshop Summaries
Appendix C2 I-205 Toll Project Truck Toll Multiplier Sensitivity Analysis – Transportation Effects
Appendix D I-205 Toll Project Air Quality Technical Report
Appendix D1 I-205 Toll Project Criteria Pollutant Emissions Memorandum
Appendix D2 I-205 Toll Project Truck Toll Multiplier Sensitivity Analysis – Air Quality Effects
Appendix E I-205 Toll Project Energy and Greenhouse Gas Technical Report
Appendix E1 I-205 Toll Project Truck Toll Multiplier Sensitivity Analysis – Energy and
Greenhouse Gas Effects
Appendix F I-205 Toll Project Economics Technical Report
Appendix F1 I-205 Toll Project Truck Toll Multiplier Sensitivity Analysis – Economic Effects
Appendix G I-205 Toll Project Noise Technical Report
Appendix H I-205 Toll Project Abbreviated Visual Impact Assessment
Appendix I I-205 Toll Project Social Resources and Communities Technical Report
Appendix J I-205 Toll Project Environmental Justice Technical Report
Appendix K I-205 Toll Project Land Use Technical Memorandum
Appendix L I-205 Toll Project Geology and Soils Technical Memorandum
Appendix M I-205 Toll Project Hazardous Materials Technical Memorandum
Appendix N I-205 Toll Project Historic and Archaeological Resources Technical
Memorandum
Appendix O I-205 Toll Project Vegetation and Wildlife Technical Memorandum
Appendix P I-205 Toll Project Wetlands and Water Resources Technical Memorandum
Appendix Q I-205 Toll Project Cumulative Impacts Technical Report
Appendix R I-205 Toll Project Engagement Summary
www.OregonTolling.org Page vi
I-205 Toll Project
Acronyms and Abbreviations

Acronym/Abbreviation Definition
2018 CE 2018 Categorical Exclusion Closeout Document
ACM asbestos-containing material
API area of potential impact
BLTS bicycle level of traffic stress
BMPs best management practices
CE categorical exclusion
CFR Code of Federal Regulations
CRBG Columbia River Basalt Group
dBA A-weighted decibels
DEQ Oregon Department of Environmental Quality
DSL Oregon Department of State Lands
EA Environmental Assessment
EFC Equity Framework Communities
EO Executive Order
ESH Essential Salmonid Habitat
FHWA Federal Highway Administration
FONSI Finding of No Significant Impact
FY Fiscal Year
GHG greenhouse gases
HCA Habitat Conservation Area
HMCS Hazardous Materials Corridor Study
I- Interstate
I-205 Improvements Project I-205 Improvements: Stafford Road to OR 213 Project
IPaC Information for Planning and Consultation
Leq equivalent sound level
LOS level of service
LTS level of traffic stress
mmBtu million British thermal units
MMLOS multimodal level of service
MP mile post
MSA Metropolitan Statistical Area
MSAT mobile source air toxics
MT metric tons
NAAC Noise Abatement Approach Criteria
NAAQS National Ambient Air Quality Standards
n.d. no date
NEPA National Environmental Policy Act
NMFS National Oceanic and Atmospheric Administration National Marine Fisheries
Service
OAR Oregon Administrative Rules
ODFW Oregon Department of Fish and Wildlife
ODOT Oregon Department of Transportation
OHWM Ordinary high water mark
OR Oregon Route
PM Particulate Matter
PM10 particulate matter 10 microns or less in size
PM2.5 particulate matter 2.5 microns or less in size
Phase 1A I-205: Phase 1A Project
Portland MSA Portland-Vancouver-Hillsboro metropolitan statistical area
www.OregonTolling.org Page vii

I-205 Toll Project
Acronym/Abbreviation Definition
FAHP Programmatic Endangered Species Act Programmatic Biological Opinion and Magnuson-
Stevens Act Essential Fish Habitat Response for the Federal-Aid Highway
Program in the State of Oregon
Project Variable rate tolls on the Abernethy and Tualatin River Bridges and the toll-
funded I-205 improvements between Stafford Road and OR 213
R1ACT Region 1 Area Commission on Transportation
RBC Risk Based Concentration
RFFA reasonably foreseeable future action;
RTP Regional Transportation Plan
SHPO State Historic Preservation Office
TriMet Tri-County Metropolitan Transportation District of Oregon
USACE U.S. Army Corps of Engineers
USFWS U.S. Fish and Wildlife Service
Value Pricing Feasibility Analysis Portland Metro Area Value Pricing Feasibility Analysis
v/c volume-to-capacity
VHT vehicle hours traveled
VMT vehicle miles traveled
www.OregonTolling.org Page viii

I-205 Toll Project
1 Introduction
The Oregon Department of Transportation (ODOT) proposes to use variable-rate tolls1 on the
Interstate 205 (I-205) Abernethy Bridge and Tualatin River Bridges to raise revenue for construction of
planned improvements to I-205, including seismic upgrades and widening, and to manage congestion.
This Environmental Assessment, developed by ODOT in partnership with the Federal Highway
Administration (FHWA), presents an evaluation of the effects of variable rate tolls and the toll-funded
I-205 improvements (together, the “Project”) on the human and natural environment in accordance with
the National Environmental Policy Act (NEPA).
1.1 Location
The Project is located approximately 5 miles south of Portland, Oregon, and crosses through the
jurisdictions of Oregon City, West Linn, and Clackamas County. The Project area is the segment of I-205
between Stafford Road and Oregon Route (OR) 213, as shown in Figure 1-1.
Figure 1-1. I-205 Toll Project Area
1
Variable-rate tolls are fees charged to use a road or bridge that vary based on time of day and can be used as a
strategy to shift demand to less congested times of day.
www.OregonTolling.org Page 1-1

I-205 Toll Project
1.2 Background and Context

In 2016, the Oregon Governor’s Transportation Vision Panel held regional forums across the state to
better understand how the transportation system affects local economies. Participants consistently
identified the negative effects of traffic congestion and the need for seismic preparedness as key issues
in the Portland metropolitan area. Traffic congestion in the Portland metropolitan area creates challenges
for commuters and businesses, and makes it difficult for producers across the state to move their goods
into and through Portland in a predictable, reliable, and timely fashion (Transportation Vision Panel 2016).
In addition, the region’s aging roadway and bridge system makes it particularly vulnerable to the impacts
of a major seismic event (Transportation Vision Panel 2016).
In 2017, the Oregon Legislature passed Oregon House Bill 2017, known as “Keep Oregon Moving.”
Oregon House Bill 2017 committed hundreds of millions of dollars to fund bottleneck relief highway
projects, seismic improvements, freight rail enhancements, transit improvements, and upgrades to biking
and walking facilities. The legislation also directed the Oregon Transportation Commission to pursue and
implement value pricing 2 on I-5 and I-205 in the Portland metropolitan area to help manage traffic
congestion. Oregon House Bill 3055, which the Oregon Legislature passed in 2021, further supported
implementation of the Oregon Toll Program and related toll projects to manage congestion and raise
revenue.
As directed by Oregon House Bill 2017 and the Oregon Transportation Commission, ODOT prepared the
Portland Metro Area Value Pricing Feasibility Analysis (Value Pricing Feasibility Analysis) (ODOT 2018a),
which determined that tolls could be used to help improve travel on I-5 and I-205 during peak times and
raise revenue for congestion-relief projects. In December 2018, the Oregon Transportation Commission
submitted a proposal to FHWA seeking approval to continue the process of implementing tolls on I-5 and
I-205 (ODOT 2018a). The Oregon Transportation Commission then directed ODOT to meet the Oregon
Legislature’s directive and proceed with the NEPA process for tolling on I-5 and I-205 while addressing
three priority issues identified during the public involvement process for the Value Pricing Feasibility
Analysis:
• Impacts of tolling on communities experiencing low income
• The need for improved transit and other transportation choices
• The potential for highway pricing to cause traffic to divert to local streets
Consistent with this direction, ODOT is developing a statewide tolling program, the Oregon Toll Program,
to manage congestion and raise revenue, starting with two toll projects: the I-205 Toll Project and the
Regional Mobility Pricing Project. The I-205 Toll Project is the first of ODOT’s toll projects to advance into
the NEPA process and is seeking funding approval under the federal tolling authorization program
codified in 23 U.S. Code Section 129 (Section 129). 3 The Regional Mobility Pricing Project is a separate
2
Value pricing, sometimes known as congestion pricing or variable rate tolling, is a strategy that charges higher
fees to use roads or bridges during “rush hour” in an effort to shift trips to less congested times of day.
3
The Section 129 General Tolling Program allows public agencies to impose new tolls on federal-aid highways for
initial construction of a new highway, bridge or tunnel; initial construction of new lanes added to existing highways
as long as the number of toll-free lanes is not reduced; and on the reconstruction or replacement of bridges,
tunnels, and highways (FHWA n.d.-a).

I-205 Toll Project
toll project that would require authorization under the federal Value Pricing Pilot Program.4 As part of the
Oregon Toll Program, ODOT will deliver a recommendation to the Oregon Transportation Commission
that addresses program-level strategies to promote equity and mobility. The Oregon Toll Program will
also establish a toll collection system in accordance with nationally adopted interoperable protocols and
procedures to process transactions, manage accounts, and provide services for customer relationship
management and toll enforcement, as well as to support financial management, accounting, reporting,
and auditing.
In addition to tolling, Oregon House Bill 2017 identified improvements on I-205 as a priority project, known
as the I-205: Stafford Road to OR 213 Improvements Project (I-205 Improvements Project). The purpose
of the improvements was reducing congestion; improving mobility, travel time reliability, and safety; and
providing seismic resiliency for I-205 to function effectively as a statewide north-south lifeline route after a
major earthquake by widening I-205 and seismically upgrading or replacing 13 bridges. 5
In 2018, ODOT and FHWA determined that, with respect to FHWA regulations implementing NEPA, the
I-205 Improvements Project qualified as a categorical exclusion (CE) (23 CFR 771.117[d][13]). In
December 2018, FHWA signed a CE Closeout Document (2018 CE) for the I-205 Improvements Project,
which demonstrated that it would not involve significant environmental impacts. At that time, the potential
locations for tolling on I-205 had not been determined, and tolling of I-205 was not included in any
adopted long-term transportation plan.6 Therefore, tolling was not considered part of the I-205
Improvements Project nor analyzed in the 2018 CE.
After FHWA approved the 2018 CE, ODOT advanced elements of the I-205 Improvements Project as
multiple phased construction packages; however, efforts to secure construction funding for the entirety of
the project were unsuccessful. In 2021, Oregon House Bill 3055 provided financing options that allowed
the first phase of the I-205 Improvements Project to be constructed without toll revenue. 7 This first phase,
referred to as the I-205: Phase 1A Project (Phase 1A), includes reconstruction of the Abernethy Bridge
with added auxiliary lanes and improvements to the adjacent interchanges at OR 43 and OR 99E. ODOT
determined that toll revenue would be needed to complete the remaining construction phases of the I-205
Improvements Project as described in the 2018 CE (i.e., those not included in Phase 1A). In May 2022,
FHWA and ODOT reduced the scope of the project to include only Phase 1A and completed a NEPA re-
evaluation that reduced the scope of the 2018 CE decision for the scaled back project. (ODOT 2022a).
Construction of Phase 1A began in summer 2022 and is estimated to be complete in 2025. The toll-
funded improvements were removed from the I-205 Improvements Project and accompanying 2018 CE
decision and are now included in the I-205 Toll Project. The environmental effects of the toll-funded
4
Established in 1991, the Value Pricing Pilot Program is a federal program designed to demonstrate whether and
to what extent roadway congestion may be reduced through congestion pricing strategies, and how these
strategies may affect driver behavior, traffic volumes, transit ridership, air quality, and availability of funds for
transportation programs. More information is available at
https://ops.fhwa.dot.gov/congestionpricing/value_pricing/.
5
More details about design alternatives considered for each component of the improvements can be found in the
Proof of Concept Report (HDR 2017) and the Cost-to-Complete Report for the Combined Interstate 205
Abernethy Bridge and Widening Projects (HDR 2018a).
6
Federal regulations require that transportation projects be formally included in state and/or regional long-term
transportation plans prior to receiving NEPA approvals.
7
If tolling is approved upon completion of environmental review of the I-205 Toll Project, toll revenues could be
used to pay back loans for Phase 1A.

I-205 Toll Project
improvements are analyzed in this EA. Section 2.1.2, Build Alternative, provides a more detailed
description of these toll-funded improvements to I-205.
1.3 Purpose
The purpose of the Project is to use variable-rate tolls on the I-205 Abernethy Bridge and Tualatin River
Bridges to raise revenue for construction of planned improvements on I-205 from Stafford Road to OR
213 and to manage congestion.
1.4 Need
1.4.1 Critical Projects Need Construction Funding
Toll revenue is needed to fund construction of critical projects. 8 Available funding for transportation has
not kept pace with the cost of maintaining the transportation system or the cost of construction of new
transportation and congestion-relief projects. ODOT’s transportation funding originates from a mix of state
(approximately 77%) and federal (approximately 23%) sources (ODOT 2022a). The State Highway Fund
relies on a three-pronged approach: the gas tax, weight-mile tax, and driver and motor vehicle fees. The
Federal Highway Trust Fund is funded primarily by federal fuel taxes. These state and federal funding
sources have not been adjusted to reflect increasing construction costs, rising inflation, a more fuel-
efficient vehicle fleet, and growing transportation infrastructure demand. Despite recent federal
investments in transportation infrastructure, including the Infrastructure Investment and Jobs Act of 2021,
federal funding has not kept pace with rising transportation costs over the last several decades
(Congressional Budget Office 2020). The federal gas tax has not been adjusted since October 1993, and
federal funds have been supplemented by increasing state-based contributions including from sources
outside of state fuel taxes (Oregon Legislative Revenue Office 2022). At the state level, escalating
expenditures to maintain aging infrastructure, the need to perform seismic upgrades for Oregon’s bridges,
and rising construction costs have increased financial needs. ODOT must explore every possible method
for getting the most out of its existing infrastructure, funding projects to ease congestion, and planning for
increased earthquake resiliency.
1.4.2 Traffic Congestion Results in Unreliable Travel

On I-205, daily vehicle hours of delay increased by 25% in each direction from 2015 to 2017, indicating
that the extent and duration of congestion on I-205 continues to increase and that travel continues to
become less and less reliable (ODOT 2018b). Congestion conditions contribute to travel-time
predictability issues, which result in significant delays to passenger and freight traffic. I-205 northbound
has one of the lowest operating speeds in the region, one of the largest deteriorations of speed during
peak hours, and the most congested conditions during the PM peak period. This additional traffic and
congestion make it more challenging for travelers to get to work and other appointments on time (HDR
2018b).
In 2018, on average, more than 100,000 vehicles used the section of I-205 between Stafford Road and
OR 213 each day (ODOT 2019). For most of its 26.5-mile length, I-205 is six lanes (three through lanes in
each direction). The only remaining four-lane section is from Stafford Road to OR 99E. The transition
from a six-lane to a four-lane section creates a bottleneck, which results in congestion and causes
crashes (ODOT 2013a; HDR 2018a). Northbound I-205 from I-5 to the Abernethy Bridge has been
8
The Oregon Constitution (Article IX, Section 3a) specifies that revenues collected from the use or operation of
motor vehicles is to be spent on roadway projects, which could include construction or reconstruction of travel
lanes, as well as bicycle and pedestrian facilities or transit improvements in or along the roadway.

I-205 Toll Project
identified as one of the region’s top recurring bottlenecks during the evening commute. In 2017, this
section of I-205 experienced 3.5 hours of congestion in the evening, from 2:45 p.m. to 6:15 p.m.
Southbound I-205 from OR 213 to the Abernethy Bridge experienced over 3 hours of congestion in the
morning, from 6 a.m. to 9:15 a.m. (ODOT 2018b). In total, the section of I-205 between Stafford Road and
OR 213 experienced approximately 6.75 hours of congestion daily.
The coronavirus pandemic (COVID-19) dramatically altered traffic levels in 2020 as this Environmental
Assessment analysis was starting, but pre-COVID-19 pandemic traffic congestion has largely returned
(ODOT 2021a). The existing and future traffic conditions analyzed in this Environmental Assessment
reflect adjustments for pre-COVID-19 pandemic conditions, as described in Appendix C, I-205 Toll Project
Transportation Technical Report.
The population of the Portland metropolitan area is expected to grow from 2.5 million residents in 2018 to
over 3 million in 2040 (23%) and over 3.5 million in 2060 (43%), further exacerbating existing congestion
problems (Census Reporter 2018; Metro 2016).
1.4.3 Traffic Congestion Affects Freight Movement

Movement of people and goods is critical to support a growing economy. Freight tonnage in the Portland
metropolitan area is expected to double by 2040, with 75% of total freight tonnage moved by truck (Metro
2018a). I-205 is a designated north–south interstate freight route in a roadway network that links Canada,
Mexico, and major ports along the Pacific coast. Trucks represent 6% to 9% of total traffic on I-205
(ODOT 2018b).
Congestion on I-205 affects the ability to deliver goods on time, which results in increased costs and
uncertainty for businesses. The cost of congestion on I-205 increased by 24% between 2015 and 2017,
increasing to nearly half a million dollars each day in 2017 (ODOT 2018b). Increasing congestion and
demand for goods will result in more delay, costs, and uncertainty for all businesses that rely on I-205 for
freight movement.
1.4.4 Traffic Congestion Affects Safety

The majority of crashes on I-205 result from congestion (70 percent related to rear-end crashes and
another 18 percent related to sideswipe and/or overtaking). Most of these crashes occurred during peak
commute periods (HDR 2018b). I-205 in the Project area has numerous sites that rank in the top 5 or 10
percent of sites according to 2019 data from the Safety Priority Index System (SPIS), ODOT’s systematic
scoring method for identifying potential safety problems on state highways based on the frequency, rate,
and severity of crashes (ODOT n.d.-a). This ranking means that those sites have higher than typical crash
histories and are considered priorities for potential safety improvement projects.
1.4.5 Traffic Congestion Contributes to Climate Change

Greenhouse gas emissions from cars and trucks represented 39% of total statewide emissions in 2016
(Oregon Global Warming Commission 2018). Idling vehicles in congested conditions contribute to these
emissions (U.S. Department of Energy 2015). Combined idling from heavy-duty and light-duty vehicles
consumes about 6 billion gallons of fuel annually in the United States, generating about 30 million tons of
carbon dioxide emissions each year from personal vehicles (U.S. Department of Energy 2015). In March
2020, the Governor of Oregon signed an executive order to reduce greenhouse gas emissions 45%
below 1990 levels by 2035 and 80% below 1990 levels by 2050 (State of Oregon 2020a).

I-205 Toll Project
1.4.6 Oregon’s Highway System is Not Seismically Resilient

There is a 30% chance that a Magnitude 8.0+ earthquake will occur in Oregon within the next 50 years.
Most bridges in western Oregon will suffer serious damage or destruction in such a major seismic event
because they were built before the existence of modern seismic codes (ODOT 2014). Transportation
infrastructure resilience is one of the primary components required for an effective recovery following a
major natural disaster. ODOT has designated I-205 as a statewide north-south lifeline route, which means
it must be operational quickly after a disaster renders other roadways unusable or impassable. As a
lifeline route, I-205 could be the only connection between Oregon and Washington in the event of an
earthquake and would serve as a critical route to provide supplies and services to the region. The I-205:
Phase 1A Project, currently under construction, includes reconstruction of the Abernethy Bridge to
achieve seismic design requirements to withstand the Cascadia Seismic Event. However, eight additional
bridges on I-205 in the Project area do not meet current seismic design criteria and could collapse in a
significant seismic event.
1.5 Goals and Objectives

The Project’s goals and objectives are desirable outcomes beyond its purpose and need. The following
goals and objectives reflect input collected during summer-fall 2020 engagement for the tolling aspects of
the Project and from the Value Pricing Feasibility Analysis Policy Advisory Committee, partner agencies,
the Equity and Mobility Advisory Committee, and other Project stakeholders (see Chapter 4 for more
information on engagement with these groups).
Past land use and transportation investments have resulted in negative cultural, health, and economic
effects on local communities and populations, and have disproportionately affected historically and
currently excluded and underserved communities.9 Additionally, these communities are often left out of
transportation planning and decision-making processes. These practices, along with more recent
gentrification in Portland and surrounding cities, have resulted in a mismatch between job locations and
housing in areas with few transportation options. ODOT will continue to engage communities who use or
live near the segment of I-205 between Stafford Road and OR 213, especially those that have been
historically and are currently excluded and underserved, in participation throughout the Project design,
development, implementation, monitoring, and evaluation processes.
With input from the Equity and Mobility Advisory Committee, ODOT is prioritizing equity throughout the
Project development process. The goals and objectives listed below reflect this priority:
• Goal: Provide benefits for historically and currently excluded and underserved communities.
- Maximize benefits and minimize burdens associated with implementation of the Project.
- Support equitable and reliable access to job centers and other important community places, such
as grocery stores, schools, and gathering places.
- Support equitable and reliable access to health-promoting activities (e.g., parks, trails, recreation
areas) and health care clinics and facilities.
- Design the toll system to support travel options for people experiencing low incomes.
9
As defined in the Oregon Toll Program’s Equity Framework (ODOT 2020c), these communities include people
experiencing low-income or economic disadvantage; Black, Indigenous and people of color; older adults and
children; persons who speak non-English languages, especially those with limited English proficiency; persons
experiencing a disability; and other populations and communities historically excluded from and underserved by
transportation projects.

I-205 Toll Project
• Goal: Limit additional traffic diversion from tolls on I-205 to adjacent roads and
neighborhoods.
- Design the toll system to limit rerouting from tolling.
- Design the toll system to minimize impacts on quality of life factors, such as health, noise, safety,
job access, travel costs, and environmental quality for local communities from traffic rerouting.
• Goal: Support safe travel regardless of mode of transportation.
- Enhance vehicle safety on I-205 by reducing congested conditions.
- Support safe multimodal travel options (e.g., pedestrians, bicycles, transit, automobiles) on
roadways affected by tolling.
• Goal: Contribute to regional improvements in air quality and support the State’s climate
change efforts.
- Support reduced vehicle air pollutants and greenhouse gas emissions in the Portland
metropolitan area through reducing congestion, resulting in more consistent vehicle speeds, less
vehicle idling, and fewer overall motor vehicle emission hours on I-205 and on local roadways
affected by tolling.
- Reduce localized air pollutants through reduced congestion and improved travel efficiency,
particularly in community areas where pollutants may be concentrated due to traffic congestion.
• Goal: Support multimodal transportation choices.
- Support shifts to higher occupancy vehicles (including carpooling) and other modes of
transportation (e.g., transit, walk, bike, telework).
- Collaborate with transit providers to support availability and enhancements of transit and other
transportation services along I-205, especially for historically and currently excluded and
underserved communities.
• Goal: Support regional economic growth.
- Provide for reliable and efficient regional movement of goods and people along I-205.
- Provide for reliable and efficient movement of goods and people on local roadways affected by
tolling.
- Improve regional access to jobs and employment centers, especially for historically and currently
excluded and underserved communities.
• Goal: Support management of congestion and travel demand.
- Design the toll system to improve efficient use of roadway infrastructure and improve travel
reliability.
• Goal: Maximize integration with future toll systems.
- Design a toll system that can be expanded in scale, integrated with tolling on other regional
roadways, or adapted to future toll system applications.
• Goal: Maximize interoperability with other transportation systems.
- Design a toll system that is interoperable with other transportation systems in the region.
1.6 Next Steps

The following are next steps for the Project:
• Public and agency review of this Environmental Assessment during the public comment period from
February 21, 2023 to April 7, 2023 (45 days).
• Preparation of a Revised Environmental Assessment that includes FHWA’s and ODOT’s responses
to public and agency comments on the Environmental Assessment, additional environmental studies
to address comments (if needed), and refinement of environmental commitments to mitigate Project
impacts.

I-205 Toll Project
• FHWA determination of whether the Project would have significant adverse effects on the human and
natural environment and whether additional environmental analysis in an Environmental Impact
Statement is needed; or the Project’s effects (considering mitigation commitments) warrant a Finding
of No Significant Impact (FONSI). If a FONSI is issued, it would include FHWA’s conclusion that the
Project would not create significant adverse effects and would identify ODOT’s mitigation
commitments.
• Rulemaking process to implement Oregon Transportation Commission toll policy decisions. Oregon
Transportation Commission will set toll rates about 6 months prior to toll implementation.
• Final design, construction, and implementation of the Project, following completion of the NEPA
process.

I-205 Toll Project
2 Project Alternatives
2.1 Alternatives Assessed in this Environmental Assessment
ODOT evaluated two alternatives in this Environmental Assessment:
• No Build Alternative
• Build Alternative
Figure 2-1 depicts the proposed lane configuration of I-205 through the Project area, and major elements
to be constructed under the No Build Alternative and Build Alternative.
2.1.1 No Build Alternative

National Environmental Policy Act regulations require an evaluation of a No Build Alternative to provide a
baseline to compare with the potential effects of a Build Alternative. The No Build Alternative consists of
existing transportation infrastructure and any planned improvements that would occur regardless of the
Project. The No Build Alternative includes the I-205: Phase 1A Project (reconstruction of the Abernethy
Bridge with added auxiliary lanes and improvements to the adjacent interchanges at OR 43 and OR 99E)
as a previously approved project that would be constructed by 2025. Under the No Build Alternative,
tolling would not be implemented and the toll-funded widening and seismic improvements on I-205
between Stafford Road and OR 213 would not be constructed.
2.1.2 Build Alternative

Under the Build Alternative, drivers of vehicles on I-205 would be assessed a toll for crossing the
Abernethy Bridge (between OR 43 and OR 99E) and for crossing the Tualatin River Bridges (between
Stafford Road and 10th Street). The Build Alternative includes construction of a third through lane in each
direction of I-205 between the Stafford Road interchange and the OR 43 interchange, a northbound
auxiliary lane between OR 99E and OR 213, toll gantries and supporting infrastructure (shown in Figure
2-2 and Figure 2-3), and replacement of or seismic upgrades to multiple bridges along I-205.
The following sections provide a more detailed description of the Build Alternative.

I-205 Toll Project
Figure 2-1. Schematic Diagrams of No Build and Build Alternatives

I-205 Toll Project
Figure 2-2. Build Alternative: Bridge Tolls – Abernethy Bridge and Tualatin River Bridges

I-205 Toll Project
Bridge Tolls – Abernethy and Tualatin River Bridges

Two areas have been identified for placement of the toll gantries and supporting infrastructure (see Figure
2-2). The gantries and supporting infrastructure would be located entirely within the existing I-205 right-of-
way.
Tolling Technology
Under the Build Alternative, tolling would consist of an Figure 2-3. Electronic Toll System
all-electronic system that would automatically collect
tolls from vehicles traveling on the highway, as shown
in Figure 2-3. There would be no toll booths requiring
drivers to stop. Rather, antennae, cameras, lights, and
other sensors would be mounted on the toll gantries
spanning the roadway and would either (1) read a
driver’s toll account transponder (a small sticker placed
on the windshield), or (2) capture a picture of a
vehicle’s license plate and send an invoice to the
registered owner of the vehicle.
The I-205 toll system would be designed to be

nationally interoperable. Transponders for tolling
systems elsewhere in the country could be used to How electronic tolling works. An all-electronic
collect tolls on I-205, and drivers with an Oregon Toll system would automatically collect tolls from
Program transponder could use their transponder and vehicles traveling on the highway. A transponder
associated account to pay tolls in other states. Owners (a small sticker placed on the windshield) is read
of vehicles with out-of-state license plates and no and connected to a prepaid account. If a vehicle
transponder would receive an invoice for tolls on I-205 doesn’t have a transponder, a camera captures
the car’s license plate, and the registered owner is
in the same way as those with Oregon plates.
billed. This keeps traffic flowing without stopping
to pay tolls.
Tolling Infrastructure
Toll gantries would consist of vertical columns on the
outside of the travel lanes and a horizontal structure that would span the travel lanes to which the
electronic tolling equipment would be attached. Toll gantries would be constructed of a metal framework
with metal or concrete support structures. Gantries and supporting infrastructure would be designed to be
consistent with other improvements to I-205 included in the Project. The final structure type and design
would be determined during preliminary design of the gantries and would be based on cost, aesthetics,
and ease of construction. The toll gantry areas would include paved parking for service vehicles, which
would typically be protected by a safety barrier or guard rail.
In addition to the toll technology mounted overhead on the gantries themselves, the gantries would
require some additional toll system equipment for data processing, storage, and network operations. This
equipment is generally enclosed within a small, access-controlled concrete structure, from which
connections to existing ODOT data fiber and commercial power would be routed. ODOT currently
operates a fiber data network with a 48-strand fiber-optic cable along the north side of I-205, to which the
toll system equipment would be connected. A backup generator (typically fueled by diesel or natural gas)
would be provided so the toll equipment would function during power outages. No relocation of existing
utilities to accommodate construction of the gantries or any supporting infrastructure is expected.
The Abernethy Bridge toll gantry area would include three toll gantries: a mainline gantry structure that
spans all highway lanes, and gantries over the northbound on-ramp and the southbound off-ramp. Each

I-205 Toll Project
toll gantry would include a single gantry structure. The Tualatin River Bridges toll gantry area would
include two toll gantries: one over the mainline northbound travel lanes and one over the mainline
southbound travel lanes. Each toll gantry would include a single gantry structure.
Toll Implementation
As Oregon’s toll authority, the Oregon Transportation Commission will set toll rates, policies (including
discounts and exemptions), and price escalation. If tolling is approved, the Oregon Transportation
Commission would ultimately set toll rates at levels sufficient to meet all financial commitments, fund
Project construction and maintenance, and manage congestion. The Oregon Transportation Commission
is expected to finalize toll rates in 2024. ODOT could begin tolling as early as December 2024, before the
completion of construction of the improvements to I-205 under the Build Alternative.
Toll Rate Assumptions

Toll rates have not been determined and will be set by the Oregon Transportation Commission if tolling is
approved. For environmental analysis and financial planning purposes, a baseline weekday variable-rate
toll schedule was identified that balances the objectives of revenue generation sufficient to meet the
funding target for capital construction of the I-205 improvements, and alleviating congestion on I-205
during peak travel times. The identified toll rates would also provide a sustainable source of revenue for
ongoing corridor operations and maintenance as well as periodic repair and replacement costs. For
environmental analysis and financial planning purposes the identified baseline toll rate schedule for the
year of opening varies as follows:
• During off-peak hours, toll rates are assumed to be lowest, ranging from $0.55 overnight (from 11
p.m. to 5 a.m.) to $0.65 in the midday and evening (from 10 a.m. to 1 p.m. and 8 p.m. to 11 p.m.) to
cross a single bridge.
• During peak hours (6 a.m. to 9 a.m. and 3 p.m. to 7 p.m.), toll rates are assumed to be highest during
peak hours, varying from $1.65 to $2.20 to cross a single bridge depending on which weekday peak
hour.
• During the shoulder period hours just before and after the peak periods (5 a.m. to 6 a.m., 9 a.m. to 10
a.m., 1 p.m. to 3 p.m., 7 p.m. to 8 p.m.), toll rates are assumed to be $1.00 to cross a single bridge.
These assumed rates would apply to each bridge crossing. The rates for a through-trip (i.e., crossing both
the Abernethy and Tualatin River bridges) would be double the assumed toll rate for only crossing one
bridge. The assumed toll rates are provided in State Fiscal Year (FY) 2025 dollars indicative of the year of
opening and are assumed to escalate annually with general price inflation, conservatively assumed to be
2.15% per year.
The effects analysis presented in this Environmental Assessment assumes that all vehicles would be
charged the same toll rate. However, because some effects could be sensitive to the mix of vehicle types
(i.e., volumes of passenger vehicles and trucks), analysts examined the effects of a higher toll rate for
medium and heavy trucks on traffic and how it could affect air quality, energy consumption and
greenhouse gas emissions, and economic effects.10 Appendix C2, I-205 Toll Project Truck Toll Multiplier
Sensitivity Analysis – Transportation Effects; Appendix D2, I-205 Toll Project Truck Toll Multiplier
Sensitivity Analysis – Air Quality Effects; Appendix E1, I-205 Toll Project Truck Toll Multiplier Sensitivity
10
Medium trucks are defined as single-unit trucks (i.e., no trailer) weighing 14,001 to 33,000 pounds. Heavy trucks
are defined as those pulling one or more trailers and weighing more than 33,000 pounds. These definitions come
from the Oregon Metro Regional Transportation Demand Model (Metro 2020) based on FHWA vehicle
classifications.

I-205 Toll Project
Analysis – Energy and Greenhouse Gas Effects; and Appendix F1, I-205 Toll Project Truck Toll Multiplier
Sensitivity Analysis – Economics Effects, provide the results of these analyses.
A recent financial analysis confirmed that, under the assumed baseline toll rates, there would be sufficient
net toll revenues to leverage bonds that would meet the toll funding contribution target for construction of
the planned I-205 improvements (ODOT 2022b).
Improvements to I-205
Under the Build Alternative, a 7-mile portion of I-205 would be widened between Stafford Road and OR
213, with added through lanes between Stafford Road and OR 43 and a northbound auxiliary lane from
OR 99E to OR 213. Eight bridges between Stafford Road and OR 213 would be replaced or
reconstructed to withstand a major seismic event. New drainage facilities would be installed in both
directions of I-205.
Bridge Reconstructions and Replacements

Reconstructed and replaced bridges would be designed to remain operational after the anticipated
Magnitude 8+ Cascadia Subduction Zone Earthquake and to avoid collapse after a 1,000-year return
period earthquake (ODOT 2018b).
The following bridges would be reconstructed with foundation improvements and substructure upgrades
for seismic resiliency but would not be replaced:
• Northbound I-205 bridge over Blankenship Road – Mile Post (MP) 5.84.
• Southbound I-205 bridge over Blankenship Road – MP 5.90
• Northbound I-205 bridge over 10th Street (West Linn) – MP 6.40
• Southbound I-205 bridge over 10th Street (West Linn) – MP 6.42
• I-205 over Main Street (Oregon City) – MP 9.51
The following bridges would be replaced to meet seismic design standards and to facilitate the widening
of I-205.11
• Northbound I-205 bridge over SW Borland Road – MP 3.82
• Southbound I-205 bridge over SW Borland Road – MP 3.81
• Northbound I-205 bridge over the Tualatin River – MP 4.1
• Southbound I-205 bridge over the Tualatin River – MP 4.08
• Northbound I-205 bridge over Woodbine Road – MP 5.14
• Southbound I-205 bridge over Woodbine Road – MP 5.19
• Sunset Avenue (West Linn) bridge over I-205 – MP 8.28
• West A Street (West Linn) bridge over I-205 – MP 8.64
The I-205 bridges over 10th Street and Blankenship Road would be widened and raised to meet the
proposed new highway grade. The I-205 bridges over the Tualatin River and SW Borland Road would be
11
Originally, seismic upgrading (reconstruction) was considered for all 13 of the I-205 bridges; however, during the
preliminary analysis process, it was determined that widening I-205 would require rebuilding replacement of the
West A Street and Sunset Avenue bridges due to column conflicts with the location of the new lanes. In addition,
replacements would be less costly than seismic upgrading retrofitting and widening the Borland Road, Tualatin
River, and Woodbine Road bridges due to the cost of foundation retrofits upgrades and long-term maintenance
(ODOT 2018b).

I-205 Toll Project
replaced on a new alignment between the existing northbound and southbound directions to
accommodate construction. The I-205 bridges over Woodbine Road would be replaced on the existing
alignment and raised to meet the proposed new highway grade. The Broadway Street Bridge over I-
205would be removed to enhance the function of the OR 43 interchange.
Traveler Information Signs (Active Traffic Management Improvements)

Traveler information signs would be constructed as a part of the Project. A variable message sign would
be installed on I-205 northbound at M.P. 4.26, just south of the Johnson Road bridge over I-205 on a new
cantilever sign structure, and three variable advisory speed signs would be mounted on each side of the
realigned Sunset Ave bridge over I-205.
Additional Improvements
The Build Alternative could result in traffic rerouting from I-205 with the implementation of tolling. Chapter
3 describes potential mitigation measures that would reduce the effects of rerouting. These measures
could become part of the Build Alternative. ODOT will continue to coordinate with partner agencies to
determine appropriate mitigation measures in the affected communities. Through this coordination effort
and public comment on this Environmental Assessment, ODOT will finalize and present its mitigation
commitments in the Revised Environmental Assessment.
Construction
Construction of the Build Alternative is expected to last approximately 4 years, beginning in late 2023 with
construction of toll gantries and toll-related infrastructure and continuing from 2024 through 2027 with
construction of I-205 widening and seismic improvements. Most toll-related construction would be
conducted alongside I-205 within the existing right-of-way. For highway widening, it is anticipated that
construction would be sequenced to widen one direction of I-205 at a time, enabling traffic to be moved to
a temporary alignment while the remaining widening work is completed. Construction activities would
include adding temporary crossover lanes to enable access to the temporary traffic configurations during
roadway widening. Staging areas for construction equipment and supplies for the Build Alternative would
be located primarily in the median of I-205 in ODOT right-of-way.
In-water work would be required to replace the bridges over the Tualatin River. Temporary piles in the
Tualatin River would be required to support work bridges and would occupy approximately 3,000 square
feet. The piles would be removed after bridge construction, and the area would be expected to return to
pre-construction conditions. Installation of drilled shafts would be needed for the new bridge piers. Drilled
shafts would be constructed using fully cased excavations. Other areas of excavation performed within
the Tualatin River would likely be contained within a cofferdam during construction.
Widening activities would require removal of additional rock along a portion of the existing rock slope
adjacent to northbound I-205 in West Linn from the Broadway Bridge (MP 8.69) to southwest of the
Sunset Avenue Bridge (MP 8.38). Blasting would be required to move the rock cut face 35 to 40 feet
south of the existing rock face for a total length of approximately 2,565 feet.
Anticipated Permits and Approvals

Table 2-1 lists the anticipated local, state, and federal environmental permits, clearances, and approvals
for Project construction.

I-205 Toll Project
Table 2-1. List of Anticipated Environmental Permits and Approvals

Permit or Approval Required Description
City of West Linn Water Resource Area Yes Required for any development in WRAs. WRAs
(WRA) Permit include wetlands, streams, and Significant Riparian
Corridors.
City of West Linn Habitat Conservation Area Yes Required for any disturbance to HCAs. HCAs are
(HCA) Review associated with wetlands, waters, and upland
habitats.
Clackamas County Noise Variance To be determined Required for nighttime construction per Clackamas
County Code Chapter 6.05 Noise Control (Clackamas
County 2000).
Clackamas County Water Environment Yes Required for any disturbance to wetlands and
Services Wetland and Stream Buffer streams and their associated buffers. Wetland and
Variance streams are mapped along and across I-205. Buffers
are determined during land use permitting.
Clackamas County Water Environment Yes Required for any disturbance to HCAs. HCAs are
Services HCA Development Permit mapped along and across I-205 and are associated
with wetlands, waters, and upland habitats.
Clackamas County Water Environment Yes Required for development within the Tualatin River
Services Floodplain Development Permit floodplain.
National Marine Fisheries Service/U.S. Fish Yes Required for impacts on Endangered Species Act
and Wildlife Service Section 7/Endangered listed salmonid species.
Species Act
Oregon Department of Fish and Wildlife Fish Yes Required to comply with OAR 635-412-005 for the
Passage Plan replacement of the I-205 bridges over the Tualatin
River.
Oregon State Historic Preservation Office Yes Required when a federal action has the potential to
Section 106 Review affect historic resources listed, eligible for listing, or
potentially eligible for listing on the National Register
of Historic Places, in compliance with the National
Historic Preservation Act.
US Army Corps of Engineers Section 404 Yes Required for impacts on jurisdictional wetlands and
Permit; Oregon Department of State Lands waters.
Removal-Fill Permit; Oregon Department of
Environmental Quality 401 Water Quality
Certification
HCA = Habitat Conservation Area; I- = Interstate; OAR = Oregon Administrative Rule; OR = Oregon Route; WRA =
Water Resource Area
2.2 Alternatives Considered but Not Advanced

In 2020, ODOT identified and evaluated five alternatives for tolling I-205 between the Stafford Road and
OR 213 interchanges to manage congestion and raise revenue for congestion-relief projects. These
alternatives—identified as Alternatives 1, 2, 3, 4, and 5—represented location options where tolls would
be charged (toll gantries) and different methods for assessing tolls (e.g., single point, segment-based,
and zonal). ODOT evaluated each tolling alternative based on the alternative’s ability to manage demand
on I-205 and limit rerouting to nearby roadways while generating revenue. Each of the alternatives
assumed completion of the planned I-205 improvements.
Sections 2.2.1 through 2.2.4 summarize the alternatives for tolling that were initially considered but not
advanced for study in this Environmental Assessment (identified as Alternatives 1, 2, 4, and 5 in
Appendix A, Comparison of I-205 Screening Alternatives Technical Report) and the reasons ODOT did
not move forward with these alternatives.
Appendix A provides a more detailed analysis of tolling alternatives.

I-205 Toll Project
2.2.1 Alternative 1: Abernethy Bridge Toll

Under Alternative 1, vehicles would be assessed a toll to cross the Abernethy Bridge in any direction at a
single toll gantry on I-205 (Figure 2-4). Toll-funded improvements to I-205 would be the same under
Alternative 1 as the Build Alternative. Because Alternative 1 would toll trips at one location, it would be
less effective at managing broader traffic congestion on I-205 between Stafford Road and OR 213 and
generating revenue to fund improvements. Having a single toll point on the Abernethy Bridge would also
result in substantially higher traffic volumes throughout the day near Oregon City due to traffic rerouting to
avoid the toll. For these reasons, ODOT did not advance Alternative 1 for further study.
Figure 2-4. Alternative 1: Abernethy Bridge Toll

I-205 Toll Project
2.2.2 Alternative 2: Abernethy Bridge Toll with Off-Bridge Gantries

Representing a refinement of Alternative 1, Alternative 2 would charge drivers a single toll for crossing the
Abernethy Bridge. However, this alternative would include tolling points both on approaches to the
Abernethy Bridge (south of OR 43 and north of OR 99E) and on the bridge itself (Figure 2-5). Vehicles
would not be assessed separate tolls upon passing each gantry; rather, the additional gantries located on
the approaches would determine if a vehicle has traversed the bridge or made a trip that would have
otherwise occurred on the bridge (i.e., the vehicle exited I-205 at OR 43 or OR 99E, crossed the Oregon
City Arch Bridge, and then re-entered I-205 on the other side of the Willamette River). Toll-funded
improvements to I-205 would be the same under Alternative 2 as the Build Alternative.
As with Alternative 1, because Alternative 2 would only toll trips at one general location (on or near the
Abernathy Bridge), it would be less effective at managing broader traffic congestion on I-205 between
Stafford Road and OR 213 and generating revenue to fund improvements compared to alternatives that
would toll trips at more than one general location. Although the multiple toll points could somewhat reduce
rerouting compared to Alternative 1, Alternative 2 would also result in substantially higher traffic volumes
throughout the day near Oregon City due to traffic rerouting to avoid the toll. For these reasons, ODOT
did not advance Alternative 2 for further study.
Figure 2-5. Alternative 2: Abernethy Bridge Toll with Off-Bridge Gantries

I-205 Toll Project
2.2.3 Alternative 4: Segment-Based Tolls – Between Stafford Road and OR 213

Alternative 4 would toll four segments of I-205: between Stafford Road and 10th Street, 10th Street and
OR 43, the Abernethy Bridge (between OR 43 and OR 99E), and OR 99E to OR 213 (Figure 2-6).
Vehicles would be assessed a toll for each segment traveled for a total of up to four segments. This
alternative would rely on mainline toll gantries and distribute the total toll assessed for trips over multiple
tolling points. Toll-funded improvements to I-205 would be the same under Alternative 4 as the Build
Alternative.
After the screening process in March 2021, ODOT recommended moving forward with both Alternatives 3
and 4 for evaluation in this Environmental Assessment. Subsequently, ODOT decided not to advance
Alternative 4 because, unlike Alternative 3, it is not eligible for funding approval under the federal tolling
authorization program codified in 23 U.S. Code Section 129 (Section 129). Section 129 clearly defines
requirements for federal approval that yield a proven, expeditious, and predictable process under which
ODOT may rely upon the outcome – an important factor given that toll revenue is required to fund
construction of the planned improvements to I-205 included in the Build Alternative. Alternative 4 would
not be eligible for funding approval under Section 129 because all of the mainline toll gantries would be
associated with I-205 roadway segments and would not be associated with construction or reconstruction
of bridges along I-205. Therefore, Alternative 4 would not meet the requirements under Section 129.
Figure 2-6. Alternative 4: Segment-Based Tolls – Between Stafford Road and OR 213

I-205 Toll Project
2.2.4 Alternative 5: Single-Zone Toll – Between Stafford Road and OR 213

Alternative 5 would use a single-zone toll structure, where any vehicles entering the tolled zone on I-205
between Stafford Road and OR 213 would be assessed the full amount of the toll regardless of distance
traveled (Figure 2-7). Alternative 5 could include mainline toll gantries as well as ramp-based gantries,
such that the gantries would be at each entry point within the toll zone. This alternative would minimize
undesirable rerouting patterns by removing the financial incentive for some vehicles to exit I-205 earlier
(or enter later) in their trip than they otherwise might with a toll in place. The toll-funded improvements on
I-205 under Alternative 5 would be the same as the Build Alternative.
ODOT did not advance this alternative for further study because the single-zone toll structure would
provide limited flexibility in managing traffic congestion, leading to a greater concentration of rerouted
traffic east of Stafford Road and in Gladstone, and would be more challenging to scale to other segments
of I-205 or other state highways. Net toll revenues for Alternative 5 would be lower than any alternative
except Alternative 1. Furthermore, Alternative 5 would not likely be eligible for funding approval under the
federal tolling authorization program codified in Section 129 because all of the proposed mainline toll
gantries would not be associated with construction or reconstruction of bridges along I-205.
Figure 2-7. Alternative 5: Single-Zone Toll – Between Stafford Road and OR 213

I-205 Toll Project
3 Affected Environment, Environmental

Consequences, and Mitigation
This chapter describes the environmental features and resources that would be affected by the Build
Alternative. Sections 3.1 through 3.14 include descriptions of the area of potential impact (API) for each
resource topic, existing environmental conditions (Affected Environment), the short-term and long-term
impacts and benefits of the Build Alternative compared to the No Build Alternative (Environmental
Consequences), and the actions ODOT would take to avoid, minimize, or mitigate Project impacts
(Avoidance, Minimization and/or Mitigation Measures). Section 3.15 presents the cumulative impacts that
would result from implementation of the Build Alternative when considered with other past, present, and
reasonably foreseeable future actions.
The information in this chapter is derived from the technical reports and memorandums presented in
Appendices C through Q of this Environmental Assessment. For information on the methods of analysis,
relevant regulations and guidance, data sources, model results, and other details of the analyses, please
refer to Appendices C through Q as cited in Sections 3.1 through 3.15.
3.1 Transportation
3.1.1 Affected Environment
The transportation API, shown in Figure 3-1, generally extends along I-205 from the I-5 interchange 12
near Tualatin to the SE 82nd Drive interchange near Gladstone and extends south along OR 99E about
10 miles to Aurora. The analysis focuses on key roadways, referred to in this Environmental Assessment
as study corridors, in the I-205 vicinity and 50 study intersections that would potentially experience
differences in AM or PM peak-hour traffic volumes under the Build Alternative compared to the No Build
Alternative. Chapter 3 of Appendix C, I-205 Toll Project Transportation Technical Report, provides a more
detailed description of the API and methodology used for the analysis.
Existing Travel Patterns

Most I-205 travelers in the API currently originate from the nearby areas of Gladstone (12%), West Linn
(10%), Oregon City (8%), and Clackamas (8%). Fewer travelers come from areas farther away, including
approximately 3% from Clark County, Washington. About 25% of I-205 trips in the API are through trips,
and about 75% are local trips, meaning they enter and/or exit I-205 at one of the five interchanges in
the API.
When there is traffic congestion on I-205, some travelers currently reroute to local roads to avoid traffic.
For example, an estimated 20% to 30% of travelers using northbound I-205 to get to the Oregon City
Arch Bridge take alternative roads during the PM peak period (4 p.m. to 6 p.m.) to reach the bridge. The
proportion of travelers who reroute from I-205 to local routes may be greater than 50% for some travel
patterns. The most frequent rerouting routes include SW Borland Road, Willamette Falls Drive, SW
Stafford Road, and OR 99E.
12
A relatively small portion of I-5 was included within the API because most sections of I-5 would not experience
substantial differences in traffic volumes between the No Build and Build Alternatives, as detailed in the I-205 Toll
Project Transportation Technical Report.

I-205 Toll Project
Figure 3-1. Transportation Area of Potential Impact

I-205 Toll Project
Traffic Volumes
Figure 3-2 presents the 2019 (pre-pandemic year) average weekday (Tuesday, Wednesday, and
Thursday) daily traffic volumes for I-205 and surrounding roadways in the API. I-5, OR 43, OR 213, and
OR 99E carry the highest daily traffic volumes in the API aside from I-205. Both northbound and
southbound I-205 in the API generally experience their highest weekday traffic volumes between
approximately 7 a.m. and 9 a.m. and 4 p.m. and 6 p.m., but the peak volumes vary by direction and
location. For example, at the Abernethy Bridge, the southbound direction (headed toward the I-5
interchange) has higher volumes in the AM peak period, while the northbound direction (headed toward
Oregon City) has higher volumes in the PM peak period. Most of the 50 study intersections have peak
traffic volumes from 7:45 a.m. to 8:45 a.m. and 5 p.m. to 6 p.m.
Traffic Operations
I-205 Operations
Analysts evaluated existing traffic operations using metrics such as volume-to-capacity (v/c) ratios,13 level
of service (LOS), 14 travel times, and reliability. Although all segments 15 on northbound and southbound
I-205 in the API meet the ODOT v/c mobility standard during the AM peak hour and PM peak hour under
existing year (2021) conditions, the following I-205 segments operate at LOS E or F (meaning highest
congestion levels and delays):
• AM peak hour: Northbound I-205 between OR 213 and SE 82nd Drive.
• PM peak hour: Northbound I-205 from the 10th Street off-ramp to the on-ramp from SE 82nd Drive;
southbound I-205 in areas where vehicles frequently change lanes (between OR 213 and OR 99E,
and the merge from the OR 43 on-ramp).
Average weekday travel times for northbound I-205 between I-5 and SE 82nd Drive were approximately
8 minutes during the AM peak period (7 a.m. to 9 a.m.) and 18 minutes during the PM peak period (4 p.m.
to 6 p.m.), based on recorded regional travel time data for June 2019. For southbound I-205 in the same
location, travel times were approximately 18 minutes during the AM peak period and 13 minutes during
the PM peak period. For reference, a trip at the speed limit between I-5 and SE 82nd Drive in either
direction should take about 9 to 11 minutes.
13
Volume-to-capacity (v/c) ratios measure the level of congestion on a roadway or intersection by dividing the
volume of traffic by the capacity of the facility in question. In general, a low v/c ratio indicates smooth operations
and minimal delays. As the ratio approaches 1.0, congestion increases, and operational performance is reduced.
At 1.0, the capacity is fully utilized (ODOT 2020d). ODOT and many local jurisdictions use v/c ratios to measure
operational performance and set a mobility standard within which they want all of their relevant facilities to
operate.
14
Level of service (LOS) is a qualitative measure used to relate the quality of traffic flow on a roadway based on
factors like vehicle speed and congestion. LOS uses letter “grades” of A through F, representing little to no delay
and very high delays, respectively.
15
Segment refers to particular portions of I-205 and other roadways studied in this analysis.

I-205 Toll Project
Figure 3-2. Pre-pandemic Year (2019) Average Weekday Daily Traffic Volumes in Area of
Potential Impact and Surrounding Roadways
Source: Metro Regional Travel Demand Model

I-205 Toll Project
Analysts measured reliability of travel based on a buffer time analysis, which considers the time added to
travel when conditions are uncertain. 16 On northbound I-205, average AM peak-period travel times were
found to be highly reliable, whereas average PM peak-period travel times were found to be moderately
reliable. On southbound I-205, although average AM peak-period travel times were longer than average
PM peak-period travel times, the AM peak-period travel times were more reliable because they had less
variation.
Intersection Operations
Analysts measured intersection performance based on existing mobility standards, which vary by
jurisdiction, with some measured as v/c ratios and others measured as LOS. Of the 50 study
intersections, 45 operate within identified mobility standards under existing year (2021) conditions during
the AM peak hour and 40 operate within identified mobility standards under existing conditions during the
PM peak hour. The following intersections currently fail to meet mobility standards:
• AM Peak Hour
- The stop-controlled intersection at OR 43 and Willamette Falls Drive (No. 14 on Figure 3-1)
- The stop-controlled intersection at OR 213 and I-205 southbound ramps (No. 29 on Figure 3-1)
- The signalized intersection at OR 43 and McVey Avenue (No. 44 on Figure 3-1)
- The stop-controlled intersection at OR 99E and S South End Road (No. 46 on Figure 3-1)
- The stop-controlled intersection at OR 99E and S Lone Elder Road (No. 49 on Figure 3-1)
• PM Peak Hour
- The stop-controlled intersection at OR 43 and Willamette Falls Drive (No. 14 on Figure 3-1)
- The signalized intersection at OR 99E and I-205 southbound ramps (No. 20 on Figure 3-1)
- The stop-controlled intersection at OR 213 and I-205 southbound ramps (No. 29 on Figure 3-1)
- The signalized intersection at SE 82nd Drive and I-205 northbound ramps (No. 32 on Figure 3-1)
- The signalized intersection at SE 82nd Drive and I-205 southbound ramps (No. 33 on Figure 3-1)
- The stop-controlled intersection at 12th Street and Willamette Falls Drive (No. 37 on Figure 3-1)
- The signalized intersection at McLoughlin Boulevard and 14th Street (No. 41 on Figure 3-1)
- The stop-controlled intersection at SW Stafford Road and SW Childs Road (No. 42 on Figure 3-1)
- The stop-controlled intersection at OR 99E and S South End Road (No. 46 on Figure 3-1)
- The stop-controlled intersection at OR 99E and S Lone Elder Road (No. 49 on Figure 3-1)
Transit
Transit providers in the API include the Tri-County Metropolitan Transportation District of Oregon (TriMet),
Canby Area Transit, South Clackamas Transportation District, and South Metro Area Transit. In addition,
Clackamas Community College operates a shuttle service between its Oregon City campus and
Clackamas Town Center. There are three park-and-ride lots in the API.
16
Travel time reliability considers the range of potential travel times roadway users may experience, the consistency
of travel times, and the ability of roadway conditions to provide a desired travel time. Buffer time is the additional
travel time drivers would need to allocate beyond the average travel time to account for unexpected delays and to
be on time 95% of the time. A highly reliable travel time means that travelers would not need to add time beyond
the average travel time. A moderately reliable travel time means that travelers would need to add about 50% more
time beyond the average travel time (e.g., for a 20-minute average travel time, a traveler should budget an
additional 10 minutes). Reliability is particularly important for roadway users who need to ensure that they arrive at
their destinations by a given time (e.g., needing to be at work by a certain time, or for truck freight haulers who
need to deliver their goods by a certain time).

I-205 Toll Project
The eastern portion of the API (Oregon City and Gladstone) contains more transit coverage than the
western portion (West Linn). I-205 has no transit service west of OR 43. Ten transit lines operate in the
API. Three provide 15-minute or better weekday peak service and seven operate every 30 to 60 minutes
during the peak periods. Five TriMet lines operate on Saturday and Sunday, and Canby Area Transit Line
99X runs on Saturday.
There are bus routes on portions of I-205, OR 43, OR 99E, OR 213, and Willamette Falls Drive, although
there are no bus stops on I-205 and OR 213. Based on a multimodal level of service (MMLOS) analysis17
for roadways with bus stops in the API, Willamette Falls Drive has an overall transit LOS of F because it
has one low-frequency bus route. OR 43 has an overall transit LOS of B because it has one bus route
that offers high-frequency service. Transit LOS on OR 99E ranges from A to E but averages LOS C
overall because it is a long roadway that spans multiple cities and has varying transit conditions.
Active Transportation
Pedestrians and bicyclists are prohibited on I-205 north of the OR 43 interchange. Pedestrian facilities,
such as sidewalks and marked or signalized crossings, and bicycle facilities, such as bicycle lanes and
local multiuse pathways, generally exist within the API in downtown Oregon City and Lake Oswego and
the historical areas of West Linn and Gladstone. However, there is limited pedestrian and bicycle
connectivity between cities. There are no protected bicycle lanes within the API, but a few off-street trails
and local shared-use pathways are provided. Other areas of the API generally do not have pedestrian
and bicycle facilities.
Sixteen unsignalized intersections in the API were analyzed for level of traffic stress (LTS)18 to
pedestrians and bicyclists (locations shown in Figure 3-1). Analysts focused on unsignalized intersections
because, in general, pedestrians and bicyclists experience the greatest stress at this type of intersection.
Three of the 16 intersections experience the highest LTS for pedestrians (LTS 4), and 10 intersections
experience LTS 4 for bicycles. To determine the potential effects of changes in traffic volumes, bicycle
LTS and pedestrian LOS were also analyzed on segments of SW Stafford Road, SW Borland Road,
Willamette Falls Drive, OR 43, OR 213, and OR 99E in the API. The highest overall bicycle LTS in the
API occurs on segments of SW Stafford Road, SW Borland Road, OR 213, and OR 99E. Pedestrian LOS
varies by roadway, ranging from OR 43 at level B or C, to OR 213 with results at level E or F.
Truck Freight Mobility

The truck freight network within the API includes two national highway truck freight routes (I-5 and I-205)
and two connector truck freight routes (OR 99E and OR 213). These truck freight routes connect and
serve the industrial areas within the Portland metropolitan area that are vital to the regional economy. I-5
and I-205 are essential truck freight routes that serve a substantial volume of trucks within the API. I-205
carries the second highest truck volume (after I-5) in the Portland region, with a daily volume of up to
14,000 trucks, which accounts for about 8% of total traffic on I-205. Truck volumes peak around 9 a.m. in
the southbound direction and around 11 a.m. in the northbound direction. However, high truck volumes
17
MMLOS can be used to measure the performance of bicycle, pedestrian, and transit facilities. Transit LOS
analysis quantifies user perception of quality of transit service based on various transit and roadway
characteristics, including transit speed, frequency, estimated ridership, and on-time performance. Similar to
vehicle LOS, LOS A is the best or most suitable level and LOS F is the worst or least suitable level.
18
LTS is an analysis method used to rate multimodal conditions by estimating the perceived safety of bicycle and
pedestrian infrastructure. Higher average daily traffic, higher speeds, and higher numbers of vehicle lanes
increase stress levels for both pedestrians and bicyclists. The LTS analysis provides scores of 1 through 4 for
each mode, with level 1 representing little or no traffic stress and level 4 representing high stress.

I-205 Toll Project
occur from approximately 8 a.m. to 3 p.m. in both directions, ranging from 400 to 450 trucks per hour
southbound and from 600 to 700 trucks per hour northbound (ODOT 2021b). There is a major truck
freight hub that attracts a high volume of truck freight traffic south of OR 212 and east of I-205. Many of
the truck trips associated with this facility use I-205 between Stafford Road and OR 213.
On major truck freight routes in the API, buffer times are now consistently higher during midday period
than during the AM peak period, indicating ongoing issues with truck freight delivery reliability to and
through the Portland region throughout the day. Many business owners have reported changing to
staggered shifts, adding evening and overnight operations, and increasing operations during off-peak
hours, with some delivery shifts now starting as early as 2 a.m. (ODOT 2021b).
Transportation Safety
Between 2015 and 2019, 3,540 crashes were recorded along study corridors in the API and, separately,
about 58 crashes were recorded at study intersections outside of those study corridors in the API. In
general, the average number of crashes per year has decreased over time, except for an increase in
2016 (ODOT no date [n.d.]-a). However, there may be an artificial reduction in the number of crashes
recorded by ODOT because of a change in reporting requirements in early 2018.
Most crashes along the study corridors resulted in injury or property damage only. Nine of the total
reported crashes resulted in fatalities. The largest share of crashes was attributed to motorists failing to
avoid the vehicle ahead (36%) (ODOT n.d.-a). A total of 38 crashes involved pedestrians and 27 crashes
involved bicyclists. Most crashes involving pedestrians and bicyclists occurred on OR 99E, followed by
OR 43.
The intersection crash rate and critical crash rate19 were calculated at the 50 study intersections, for
6 study corridor segments, and for I-205. Nine of the 50 study intersections had above-average crash
rates compared to other similar intersections within the API. Study corridor segment crash rates were also
compared to that of similar segments within the region. The segment crash rate calculation involves
volumes, segment length, and total crashes within a 5-year period (2015 to 2019). The segment crash
analysis found that most corridors—including on I-205—currently have segments that exceed the critical
crash rate.
ODOT uses a Safety Priority Index System, which is a method to identify potential safety issues on state
highways by identifying state highway segments with higher than typical crash histories. State highway
segments with Safety Priority Index System values that rank in the top 5% by ODOT are considered
priorities for potential safety improvement projects. Figure 3-3 shows the Safety Priority Index System
locations identified within the API.
19
The intersection crash rate is the total number of crashes occurring at an intersection in proportion to the vehicles
entering the intersection. The critical crash rate compares the intersection crash rates of the 50 study intersections
to other intersections with similar characteristics within the region.

I-205 Toll Project
Figure 3-3. Existing Year (2021) High Crash Locations and Safety Priority Index System
Locations (2015 through 2019)
Source: ODOT Crash Reporting Unit: https://tvc.odot.state.or.us/tvc/ (ODOT n.d.-a)

I-205 Toll Project
3.1.2 Environmental Consequences

This section summarizes the short-term and long-term transportation effects of the No Build and Build
Alternatives. Chapter 5 of Appendix C, I-205 Toll Project Transportation Technical Report, provides more
detailed information about these effects and how they were modeled. Short-term effects are discussed
only for the Build Alternative because they relate to construction and tolling prior to the completion of
roadway improvements. The long-term effects section discusses both the No Build and Build Alternatives
relative to one another. The long-term effects analysis focuses primarily on operations in 2045, except for
the intersection analysis, which also considers operations in 2027 to represent an interim year after the
start of tolling.
Short-Term Effects
The same number of through lanes and speed of traffic would generally be maintained on I-205
throughout construction of the Build Alternative during daytime hours. Night-time lane closures of I-205,
SW Borland Road, and Woodbine Road, in accordance with Oregon Standard Specifications for
Construction (ODOT 2021c), would be necessary during demolition of existing structures and erection of
new bridge beams. A full closure of all I-205 lanes would be required during the demolition of the bridges
at West A Street, Sunset Avenue, and Broadway Street. Detours would be provided during these full
closures and would generally use I-5, I-84, OR 99E, and OR 224. Rolling slowdowns would occur during
rock blasting on northbound I-205 between Sunset Avenue and West A Street, which would be timed to
coincide with the lowest traffic volumes during times of day when blasting can be done safely.
Approximately 15 to 20 days of blasting is anticipated from summer to fall of the first year of construction.
The West A Street and Sunset Avenue underpasses would be replaced throughout a period of 2 years.
On West A Street, traffic would be maintained with one lane in each direction, except for an
approximately 6-month period where only northbound traffic would be allowed. Southbound traffic would
be detoured to Broadway Street. On Sunset Avenue, one lane in each direction would remain open with
periodic single-lane two-way flagging operations. Flagging operations would likely be restricted to certain
hours, including off-peak daytime hours.
Construction of overhead toll gantries would occur during bridge construction periods and require one full
I-205 closure, which would be limited to brief overnight periods (less than 2 hours), for each gantry
location. Short-term detours with temporary signage would be used for the roadway closures. Additional
lane closures would be required to complete toll equipment work over the lanes, but most of these
closures would be limited to short periods of time. Full construction closure details, including durations
and frequency of closures, would be determined once the construction contractor is selected.
Tolling During Construction of Roadway Improvements

ODOT would begin tolling I-205 as early as 2024 prior to completing construction of the I-205 roadway
improvements in the Build Alternative. Traffic volumes were modeled for two pre-completion tolling
scenarios based on projected 2027 traffic volume demand: 20 (1) tolling across the Abernethy Bridge
during its construction and (2) tolling across the Abernethy and Tualatin River Bridges during their
construction. Both scenarios would have two through lanes in each direction of I-205 between Stafford
Road and OR 213, which is the same as existing conditions, because the third through lane would not yet
be complete.
20
2027 volumes were used for the pre-completion tolling scenarios because 2027 volumes represent the highest
volumes that would be anticipated throughout the pre-completion tolling period.

I-205 Toll Project
Compared with the No Build Alternative in 2027, tolling only the Abernethy Bridge prior to its completion
would result in 10% to 15% lower total average daily traffic volumes on I-205 in the API, with the highest
reduction on the Abernethy Bridge. Tolling both the Abernethy Bridge and Tualatin River Bridges prior to
their completion would result in 20% to 30% lower average weekday traffic volumes on I-205 in the API,
with the largest reductions occurring between OR 99E and OR 43, and between 10th Street and SW
Stafford Road). Similarly, compared to the No Build Alternative in 2027, traffic volumes would generally
be higher on segments of SW Borland Road, SW Stafford Road, OR 99E, OR 213, and OR 43 if both
bridges are tolled during the pre-completion period. The largest differences are expected on SW Borland
Road east of SW Stafford Road near Stafford Hamlet in unincorporated Clackamas County and on OR
99E west of Lone Elder Road just south of Canby, where volumes may be 5% to 10% higher. Any effects
resulting from the pre-completion tolling scenarios would last for 2 to 3 years and would be comparable to
effects under the Build Alternative in 2027, which are discussed in the Long-Term Effects subsection of
Section 3.1.2. Chapter 5 of Appendix C, I-205 Toll Project Transportation Technical Report, provides
more detailed analysis of the pre-completion tolling scenarios as compared with the 2027 Build
Alternative.
Long-Term Effects
Transportation System Measures
Analysts examined transportation system performance measures such as VMT, VHT, and changes in
modes of travel to assess the effects of the proposed Build Alternative as compared to the No Build
Alternative from a systemwide perspective covering the entire Portland metropolitan area.
Regional daily VMT and VHT would be slightly lower overall and for highways under the Build Alternative
compared to the No Build Alternative, as shown in Table 3-1. Daily VMT and VHT would be slightly higher
for non-highway routes under the Build Alternative compared to the No Build Alternative. This difference
reflects the number of trips that would reroute from I-205 to arterial roadways or change their mode of
travel to avoid tolls under the Build Alternative.
Table 3-1. Difference in Daily Regional Vehicle Miles Traveled and Vehicle Hours Traveled in
2045: Build Alternative Minus No Build Alternative
Build Minus No Build
Difference in % Difference in Difference in % Difference in
Regional Vehicle Regional Vehicle Regional Vehicle Regional Vehicle
Roadway Type Miles Traveled Miles Traveled Hours Traveled Hours Traveled
Highways -229,231 -1.1% -14,393 -2.9%
Non-Highway 99,836 0.3% 3,710 0.3%
Total -129,395 -0.2% -10,683 -0.7%
Source: Appendix C, I-205 Toll Project Transportation Technical Report (Section 5.3.1)
Section 5.3.1 of Appendix C, I-205 Toll Transportation Technical Report, provides more detailed
information about changes in VMT and VHT by time of day. VMT and VHT would primarily be lower under
the Build Alternative compared to the No Build Alternative during the peak-traffic periods when toll rates
would be highest. The number of highway trips would be lower in almost every hour of the day under the
Build Alternative compared to the No Build Alternative. Total VMT and VHT on both highway and arterial
roadway routes would be higher during the hours immediately before and after peak-traffic periods with
the highest expected tolls, indicating that some travelers would change the time of day that they make
their trips to avoid the highest tolls.

I-205 Toll Project
The Build Alternative is projected to have a relatively small effect on travel mode choice in the region, with
the trend indicating slightly fewer single-occupancy vehicle trips and slightly more high-occupancy
vehicle, transit, and active transportation trips, as shown in Table 3-2. These changes in mode would
likely be due to the lower travel costs compared to one person in a car paying the full toll.
Table 3-2. Comparison of Trips by Travel Mode in 2045: Build Alternative to No Build
Alternative
Difference (Build
Travel Mode No Build Trips Build Trips minus No Build)
Single-Occupancy Vehicle 5,248,000 5,245,000 -3,000
High-Occupancy Vehicle 4,307,000 4,309,000 +2,000
Transit 696,500 697,300 +800
Active 1,276,600 1,276,800 +200
Total 11,528,100 11,528,100 0
Analysts also assessed the potential for induced and latent demand under the Build Alternative. Induced
demand occurs when a road project results in increased use of the transportation network due to
unplanned changes to land use. Latent demand occurs when a lower perceived “cost” of driving (in
time/convenience or money) results in people choosing to drive more often, drive farther, or choose
driving over another mode such as walking or rolling, biking, carpooling, or using public transit. Induced
demand and latent demand can lead to an increase of VMT and potential increase in vehicle emissions.
The travel demand modeling for the Build Alternative included rerunning trip distribution, mode choice,
and traffic assignment (vehicle trip routing) to capture any changes in future travel patterns that may
occur based on the addition of the Build Alternative to the transportation network. Therefore, the modeling
accounts for potential effects related to the improved I-205 facility attracting more trips and the potential
for induced or latent demand.
Analysts compared travel demand patterns throughout the API under the No Build Alternative and Build
Alternative. As shown in Table 3-1, modeled regional VMT showed minimal differences between the No
Build Alternative and Build Alternative, indicating that the Build Alternative would not result in substantial
induced or latent demand. The following factors contribute to this conclusion:
• Adding a third lane to I-205 between Stafford Road and OR 213 would be a “lane continuity” project.
The Build Alternative would widen the 7-mile section of I-205 from two through lanes to three through
lanes to match the number of through lanes on the adjacent portions of I-205. Although induced or
latent demand could occur, it would likely be limited to localized trips in the widened area—i.e., those
who are currently diverting away from I-205 due to congestion but would return to I-205 because
conditions under the Build Alternative would be less congested.
• Congestion pricing has been shown to counteract demand on roadways (Garcia-López et al 2020).
The cost of the tolls and the application of a variable toll rate schedule under the Build Alternative
would help to manage demand and discourage higher peak-hour vehicle demand. Thus, to some
degree, the toll costs would balance or offset the potential for induced or latent demand due to
increased capacity.
• Induced demand is less likely to occur from road projects in Oregon because of the state’s strong
land use laws which restrict unplanned changes to land use. Section 3.9 and the I-205 Toll Project
Land Use Technical Memorandum provide more information about applicable state and local land use
policies.

I-205 Toll Project
Traffic Volumes and Potential Rerouting

Daily Traffic Volumes
Figure 3-4 shows projected differences in average daily traffic within the API between the No Build
Alternative and Build Alternative in 2045. Most of these locations would experience relatively small
changes in traffic volumes at a daily level under the Build Alternative compared to the No Build
Alternative.
Section 5.3.2 of Appendix C, I-205 Toll Project Transportation Technical Report, provides more detailed
information and maps showing changes in daily volumes by location. For the most part, differences in
daily traffic volumes on local roadways would be largest closest to the tolled bridges. Parallel routes to
I-205, including SW Borland Road and Willamette Falls Drive, could experience 30% to 100% higher daily
volumes under the Build Alternative compared to the No Build Alternative because some drivers would
choose to reroute to these roadways to avoid tolls. By contrast, some of the surrounding roads between
10th Street and OR 43 would experience lower volumes (by up to 30% under the Build Alternative
compared to the No Build Alternative). Because the I-205 segment between 10th Street and OR 43 would
not include a toll gantry and would have an additional lane of capacity in both directions with the Build
Alternative, traffic performance on I-205 is expected to improve, which could attract more traffic back to
I-205 and away from local streets.
Near the Abernethy Bridge, traffic volumes would range from 5% to 50% higher in downtown Oregon City
and across the Arch Bridge under the Build Alternative because some travelers would reroute their trips
to avoid the toll on the Abernethy Bridge. Much of this difference would occur during off-peak travel times
when alternative routes are less congested and provide a trip that is not much slower than taking I-205.
There would be generally higher daily traffic volumes in and around Canby, with about 20% higher traffic
volumes on OR 99E in Canby, under the Build Alternative compared to the No Build Alternative.

I-205 Toll Project
Figure 3-4. Projected 2045 No Build and Build Alternative Daily Traffic Volumes in Area of
Potential Impact and along Key Study Corridors

I-205 Toll Project
Peak-Hour Volumes
During the AM peak hour in 2045,21 Build Alternative volumes would be lower than No Build Alternative
volumes on both northbound and southbound I-205 in the API. The largest difference in northbound
volumes would be on I-205 at the Abernethy Bridge, which would be about 11% lower under the Build
Alternative. The largest difference in southbound volumes would be the segment between SW Stafford
Road and I-5, where volumes would be almost 24% lower under the Build Alternative compared to the No
Build Alternative. While some of this difference can be attributed to travelers shifting their trips out of the
peak periods due to the higher tolls during this time, more of the difference likely would result from
rerouting related to avoiding the toll point located on the Tualatin River Bridges, as well as the existence
of reasonably close and less congested southbound alternate roadways.
During the PM peak hour, northbound I-205 in the API would experience 8% to 35% higher traffic
volumes under the Build Alternative compared to the No Build Alternative. These differences would occur
primarily because of the improvement in northbound travel times due to added capacity and the projected
congestion on alternative routes to I-205 in the PM peak hour. These factors would result in travel
benefits for I-205 users that would likely offset the cost of the toll and attract users away from alternate
northbound routes and to I-205 during the PM peak hour. However, southbound I-205 would experience
lower traffic volumes under the Build Alternative compared to the No Build Alternative because of
rerouting related to avoiding the toll and the availability of reasonably close and less congested
southbound alternative roadways. These differences would be comparable to the AM peak-hour
projections, with the largest difference between SW Stafford Road and I-5. Table 3-3 compares peak-
hour volumes on I-205 segments in the API for the No Build and Build Alternatives.
Table 3-3. Projected Peak-Hour Volumes on I-205 Segments in 2045: No Build and Build
Alternatives
% Difference
No Build Build (Build minus No Build)
AM Peak PM Peak AM Peak PM Peak AM Peak PM Peak
I-205 Segment Hour Hour Hour Hour Hour Hour
Northbound
Between I-5 and SW Stafford Rd 3,470 3,835 3,475 5,185 0.1% 35.2%
Between SW Stafford Rd and 3,820 3,360 3,575 4,335 -6.4% 29.0%
10th St (Tualatin River Bridges)
Between 10th St and OR 43 4,000 3,925 3,825 4,840 -4.4% 23.3%
Between OR 43 and OR 99E 4,470 4,975 3,985 5,435 -10.9% 9.2%
(Abernethy Bridge)
Between OR 99E and OR 213 5,080 5,885 4,820 6,375 -5.1% 8.3%
Southbound
Between OR 213 and OR 99E 3,730 6,100 3,970 6,055 6.4% -0.7%
Between OR 99E and OR 43 3,405 5,480 3,500 5,515 2.8% 0.6%
(Abernethy Bridge)
Between OR 43 and 10th St 4,000 4,725 4,055 4,295 1.4% -9.1%
Between 10th St and SW Stafford 3,400 4,270 3,435 3,765 1.0% -11.8%
Rd (Tualatin River Bridges)
Between SW Stafford Rd and I-5 3,495 4,045 2,660 3,010 -23.9% -25.6%
21
For future conditions, the peak hour is assumed to be sometime within the 2-hour peak periods of 7 a.m. to 9 a.m.
(AM peak) and 4 p.m. to 6 p.m. (PM peak).

I-205 Toll Project
Figure 3-5 identifies the key roadways in the API that are summarized in Table 3-4. Table 3-4 compares
average peak-hour volumes at these selected key roadway locations under the No Build and Build
Alternatives for each direction of travel. A positive number in Table 3-4 indicates higher volumes under
the Build Alternative compared to the No Build Alternative, while a negative number in Table 3-4 indicates
lower volumes. The largest differences in local roadway volumes would occur closer to the tolled bridges
and along OR 99E. SW Borland Road and Willamette Falls Drive are parallel routes that would
experience greater PM peak-hour volumes, especially in the westbound direction under the Build
Alternative compared to the No Build Alternative. This difference in volumes would occur because of
changes in how local drivers access I-205 under the Build Alternative. Peak-hour traffic volumes would
also be higher on OR 99E, particularly in Oregon City, as some travelers would reroute their trips to avoid
the toll on the Abernethy Bridge.
Table 3-4. Peak-Hour Volumes on Key Roadways – No Build and Build Alternatives
AM Peak Hour PM Peak Hour
2045 2045
No 2045 Percent No 2045 Percent
Arterial Location Direction Build Build Change Build Build Change
1. SW Borland Rd west of SW Stafford Rd NB/EB 380 330 -13% 635 460 -28%
SB/WB 720 730 1% 610 530 -13%
2. SW Stafford Rd north of SW Borland Rd NB/EB 860 665 -23% 870 950 9%
SB/WB 845 985 17% 955 1,380 45%
3. SW Stafford Rd south of SW Borland Rd NB/EB 1,140 805 -29% 550 740 35%
SB/WB 475 340 -28% 1,055 1,380 31%
4. SW Borland Rd east of SW Stafford Rd NB/EB 415 420 1% 850 925 9%
SB/WB 340 670 97% 440 635 44%
5. OR 99E west of Lone Elder Rd NB/EB 505 520 3% 765 750 -2%
SB/WB 755 920 22% 1,000 1,090 9%
6. OR 99E east of Redwood S NB/EB 665 690 4% 890 915 3%
SB/WB 575 530 -8% 1,255 1,380 10%
7. OR 99E north of S South End Rd NB/EB 865 1,145 32% 950 910 -4%
SB/WB 580 560 -3% 1,640 1,845 13%
8. OR 99E west of 10th St NB/EB 930 1,025 10% 1,180 1,095 -7%
SB/WB 755 690 -9% 1,955 2,415 24%
9. OR 213 south of Washington St NB/EB 2,405 2,340 -3% 2,695 2,520 -6%
SB/WB 2,190 2,115 -3% 2,450 2,670 9%
10. OR 99E north of Gloucester St NB/EB 1,200 1,180 -2% 1,325 1,280 -3%
SB/WB 1,340 1,360 1% 2,015 1,990 -1%
11. OR 43 north of Hidden Springs Rd NB/EB 1,170 1,235 6% 1,110 1,185 7%
SB/WB 745 730 -2% 1,155 955 -17%
12. OR 43 south of A Ave NB/EB 1,470 1,570 7% 1,225 1,350 10%
SB/WB 1,410 1,385 -2% 1,950 1,700 -13%
Note: Arterial location numbers in the first column correspond to the numbered locations in Figure 3-5.
EB = eastbound; NB = northbound; SB = southbound; WB = westbound

I-205 Toll Project
Figure 3-5. Projected Build and No Build Peak-Hour Volumes Percent Change on Key
Roadways in 2045

I-205 Toll Project
Traffic Operations
I-205 Operations
Under the No Build Alternative, all segments of northbound I-205 and southbound I-205 in the API would
meet ODOT’s v/c mobility standard during the AM peak hour and PM peak hour, except for the I-205 on-
ramp from OR 213 during the PM peak hour. Despite meeting the mobility standard, during the AM peak
hour, the segments of northbound I-205 between SW Stafford Road and OR 43 and between OR 213 and
SE 82nd Drive, and the segment of southbound I-205 between OR 99E and SW Stafford Road, are
projected to operate at LOS F. In addition, during the PM peak hour, all segments of northbound and
southbound I-205 between SW Stafford Road and SE 82nd Drive are projected to operate at LOS F.
Under the Build Alternative, the segments of northbound I-205 between OR 213 and SE 82nd Drive
would exceed ODOT’s v/c mobility standard during the AM and PM peak hours. One southbound
segment in the AM peak hour (between OR 99E and OR 43) and five southbound segments in the PM
peak hour (between north of SE 82nd Drive and the off-ramp to OR 99E) would not meet ODOT’s v/c
mobility standard. However, these northbound and southbound I-205 segments would operate with higher
speeds and improved travel times (generally at LOS D, with one segment between SE 82nd Drive and
OR 213 operating at LOS E) under the Build Alternative than the No Build Alternative.
Under the Build Alternative, there would be less congestion on northbound I-205 during the AM peak
period and substantially less congestion during the PM peak period than there would be under the No
Build Alternative. There would be less congestion on southbound I-205 from OR 212 to OR 213 during
the AM peak and PM peak periods, and traffic is expected to travel at much faster speeds south of OR
213, than with the No Build Alternative.
Overall, the additional highway capacity and the value pricing strategy under the Build Alternative would
result in substantially fewer daily hours of congestion at most locations on both northbound and
southbound I-205 compared to the No Build Alternative in 2045, as shown in Table 3-5.
Table 3-5. Build versus No Build Daily Hours of Congestion on I-205 in 2045
Hours of Congestion by I-205 Segment
SW Stafford Rd – 10th Abernethy
Level of St 10th St – OR 43 Bridge OR 99E – OR 213
Alternative Congestion NB SB NB SB NB SB NB SB
Heavy 5 8 8 8 0 0 2 2
No Build Moderate 13 14 13 13 1 2 9 4
Heavy 0 0 0 0 0 0 0 0
Build Moderate 0 0 0 0 0 0 0 2
NB = northbound; SB = southbound
With the added capacity in both directions and congestion pricing on I-205, the Build Alternative would
improve I-205 travel times in the API by a range of about 4 minutes to more than 14 minutes during the
AM and PM peak periods compared to the No Build Alternative, as shown in Table 3-6. The Build
Alternative would provide the most substantial benefits to northbound I-205 travelers between the I-5
ramps and SE 82nd Drive in the PM peak period.

I-205 Toll Project
Table 3-6. No Build and Build Alternative Average Peak-Hour Travel Times on I-205 between
I-5 and SE 82nd Drive (minutes) in 2045
Direction Build No Build Difference % Difference
of Travel From To 7-9 AM 4-6 PM 7-9 AM 4-6 PM 7-9 AM 4-6 PM 7-9 AM 4-6 PM
I-205 NBI-5 ramps SE 82nd 10.7 12.7 14.9 27.2 -4.2 -14.5 -28% -53%
Drive
I-205 SB SE 82nd I-5 ramps 10.7 10.5 14.5 14.2 -3.8 -3.7 -26% -26%
Drive
Travel times along I-205 in the AM and PM peak periods would experience less variation and be more
reliable under the Build Alternative in both the northbound and southbound directions compared to the No
Build Alternative. The largest difference in reliability would occur on northbound I-205 during the PM peak
period. While the No Build Alternative would experience large variations, with travel times ranging
between 21 and 36 minutes depending on the time of the trip, the Build Alternative would experience
improved travel times ranging between 11 and 19 minutes, which represents up to a 75% improvement in
reliability.
Key Roadway Operations

Analysts modeled travel times under the No Build and Build Alternatives in 2045 along SW Borland Road,
SW Stafford Road, Willamette Falls Drive, OR 43, Main Street in Oregon City, and OR 99E in the API.
Figure 3-6 shows a comparison of travel times for the entire length of the roadways studied. Section 5.3.3
of Appendix C, I-205 Toll Project Transportation Technical Report, provides additional maps showing
more detailed analysis of travel time differences for individual segments of these roadways. In general,
travel times on roadways used to access I-205 that are farther from the tolled bridges (e.g., SW Borland
Road, SW Stafford Road, and Willamette Falls Drive) would be longer under the No Build Alternative than
the Build Alternative because of ongoing I-205 congestion, which would result in a continuation of the
rerouting observed under existing conditions, as described in Section 3.1.1. Travel times would be similar
or slightly longer on roadway segments near downtown Oregon City (e.g., portions of OR 43, Main Street,
and OR 99E) under the Build Alternative, depending on direction of travel and time of day, because of
additional rerouting related to vehicles avoiding the tolled bridges.
Major findings of this analysis include:

• On the segment of SW Borland Road between SW 65th Avenue and SW Stafford Road, there would
be minimal travel time differences (less than 1 minute) between the Build and No Build Alternatives
for each direction in both the AM and PM peak hours.
• On SW Stafford Road, the largest travel time differences would occur in the PM peak hour for traffic
traveling toward the I-205 interchange. The additional capacity and congestion pricing strategy
proposed under the Build Alternative are expected to result in better I-205 northbound operations in
the PM peak hour than the No Build Alternative, which would in turn free up northbound on-ramp
traffic and greatly reduce congestion along SW Stafford Road leading to the interchange. On
southbound SW Stafford Road from SW Borland Road to the I-205 northbound ramps, travel times
would be nearly 8 minutes shorter under the Build Alternative than the No Build Alternative. On
northbound SW Stafford Road between SW Mountain Road and the I-205 northbound ramps, travel
times would be about 19 minutes shorter under the Build Alternative than the No Build Alternative.

I-205 Toll Project
• On SW Borland Road/Willamette Falls Drive, projected travel-time differences between the No Build
and Build Alternatives would be relatively minor, except for during PM peak hour in the eastbound
direction from SW Stafford Road to 10th Street. Travel times in this segment would be nearly 9
minutes shorter under the Build Alternative than the No Build Alternative because the added I-205
capacity under the Build Alternative would result in less rerouting to SW Borland Road and Willamette
Falls Drive.
• On OR 43, projected travel-time differences between the Build and No Build Alternatives across both
segments in the northbound direction would be minimal in both the AM and PM peak periods. In the
southbound direction, however, AM peak-hour travel times would be 2.5 minutes longer under the
Build Alternative than the No Build Alternative between Hidden Springs Road and McKillican Street,
most likely due to an increase in volumes destined for the Arch Bridge. PM peak-hour travel time on
this same segment would be 7 minutes shorter under the Build Alternative than the No Build
Alternative because some southbound OR 43 trips would reroute to southbound I-205 south of the
OR 43 interchange. For the McKillican Street to Main Street segment that crosses the Arch Bridge
into downtown Oregon City, although the projected AM peak-period travel time would be similar under
the No Build and Build Alternatives, the PM peak-hour travel time would be about 3 minutes longer
under the Build Alternative than the No Build Alternative due primarily due to backups from increased
congestion in downtown Oregon City.
• On the Main Street corridor in downtown Oregon City, there would be relatively large travel-time
differences in the southbound direction, with travel times projected to be 12 minutes shorter under the
Build Alternative during the AM peak hour and nearly 8 minutes longer during the PM peak hour
compared to the No Build Alternative. For the southbound direction, most of the difference in the AM
peak hour would occur on the southern half of the corridor between 10th Street and OR 99E, while in
the PM peak hour the differences would be more evenly split between the northern and southern
segments of the corridor. In the northbound direction, travel times under the Build Alternative would
be roughly 2 minutes longer than the No Build Alternative in both the AM and PM peak hours.
• On OR 99E, overall northbound travel times are projected to be 3.5 minutes shorter during the AM
peak hour under the Build Alternative compared to the No Build Alternative, with most of this travel
time difference (2.6 minutes) occurring in the southern segment between Canby and Oregon City.
There would be minimal differences in northbound travel times during the PM peak hour. Overall
southbound travel times would be about 3 minutes longer during the AM peak period and about
1 minute longer during the PM peak hour. The segment through Oregon City is expected to
experience most of this difference (2.8 minutes in the AM peak hour and 1.3 minutes in the PM peak
hour) due to additional traffic rerouting through Oregon City and across the Arch Bridge, causing
congestion that would back up onto OR 99E and cause additional delay.

I-205 Toll Project
Figure 3-6. 2045 No Build vs. Build (Build minus No Build) Peak-Hour Travel Times for Key Roadways

I-205 Toll Project
Intersection Operations
As noted in the introduction to Section 3.1.2, the intersection analysis considers operations in 2027 to represent
an interim year after the start of tolling, in addition to operations in 2045. Intersection mobility standards vary by
jurisdiction, with some measured as v/c ratios and others measured as LOS.22 Most of the 50 study
intersections would meet standards under both the No Build and Build Alternatives in both 2027 and 2045.
information about projected operations at each study intersection in 2027 and 2045 during the AM and PM
peak hours. The greatest impacts would occur at intersections that are projected to meet standards under the
No Build Alternative but would not meet those standards under the Build Alternative. Figure 3-7 and Figure 3-8
show the intersections that would experience differences in intersection operations under the Build Alternative
relative to the No Build Alternative. The symbols presented on the figures are intended to represent the most
negative scenario at each location; for example, if an intersection would meet standards during the AM peak
period but would not meet standards during the PM peak period in a given analysis year, it would be
represented by the symbol indicating that it does not meet standards during that year.
In 2027, one intersection would not meet standards under the No Build Alternative and would meet
standards under the Build Alternative during the AM peak hour (i.e., the Build Alternative would result in
better operations at these locations):
• The signalized intersection at OR 43 and I-205 southbound ramps
In 2045, one intersection would not meet standards under the No Build Alternative and would meet
standards under the Build Alternative during the PM peak hour (i.e., the Build Alternative would have
better operations at this location):
• The stop-controlled intersection at Hidden Springs Road and Santa Anita Drive
In 2027, five intersections would meet standards under the No Build Alternative but would not meet them
under the Build Alternative during the AM and/or PM peak hour (i.e., the Build Alternative would have
worse operations at this location):
• The signalized intersection at 7th Street and Main Street
• The signalized intersection at OR 99E and W Arlington Street
• The signalized intersection at the I-5 northbound ramps and Nyberg Street
• The signalized intersection at the I-5 southbound ramps and Nyberg Street
• The roundabout intersection of SW Stafford Road and SW Rosemont Road
In 2045, three intersections would meet standards under the No Build Alternative but would not meet
them under the Build Alternative in 2045 during the AM and/or PM peak hour (i.e., the Build Alternative
would have worse operations at this location):
• The stop-controlled intersection at OR 99E and 15th Street
22
The v/c ratio standard is different for the Build Alternative than it is for the No Build Alternative. The Build
Alternative is required to comply with the v/c standard as outlined in the ODOT (2012) Highway Design Manual
(generally a v/c ratio of 0.75), whereas the No Build Alternative is required to comply with the v/c standards
defined in the Oregon Highway Plan (ODOT 1999), which is generally a v/c ratio 0.99 for the mainline and 0.85 for
intersections (ODOT 2012). This dual standard applies to the mainline sections of I-205 between Stafford Road
and OR 213, as well as the ramp termini intersections along that segment and at the Nyberg Street/I-5
interchange.

I-205 Toll Project
• The signalized intersection at OR 99E and 10th Street

• The signalized intersection at SW Borland Road and SW 65th Avenue
In 2027, 15 intersections would not meet standards under both the No Build and Build Alternatives during
the AM and/or PM peak hours. Of those intersections, the following 9 would experience comparatively
worse 23 conditions under the Build Alternative during the AM and/or PM peak hour:
• The signalized intersection at OR 99E and the I-205 southbound ramps
• The signalized intersection at OR 99E and I-205 northbound ramps
• The signalized intersection at McLoughlin Boulevard (OR 99E) and 14th Street
• The signalized intersection at OR 43 and McVey Avenue
• The stop-controlled intersection OR 99E and New Era Road
• The stop-controlled intersection at OR 99E and South End Road
• The signalized intersection at OR 99E and Ivy Street
• The stop-controlled intersection of OR 99E and Lone Elder Road
• The stop-controlled intersection of SW Stafford Road and SW Mountain Road
In 2045, 23 intersections would not meet standards under both the No Build and Build Alternatives during
the AM and/or PM peak hours. Of those intersections, the following 13 would experience comparatively
worse conditions under the Build Alternative during the AM and/or PM peak hour:
• The signalized intersection at OR 99E and the I-205 northbound ramps
• The signalized intersection at OR 99E and 14th Street
• The signalized intersection at SE 82nd Drive and the I-205 northbound ramps
• The stop-controlled intersection of SW Stafford Road and SW Mountain Road
• The stop-controlled intersection at 12th Street and Willamette Falls Drive
• The signalized intersection at OR 43 and McVey Avenue
• The signalized intersection at OR 43 and A Avenue
• The roundabout intersection of SW Stafford Road and SW Childs Road
• The roundabout intersection of SW Stafford Road and Rosemont Road
• The stop-controlled intersection at OR 99E and South End Road
• The stop-controlled intersection OR 99E and New Era Road
• The signalized intersection of OR 99E and Ivy Street
• The stop-controlled intersection at OR 99E and Lone Elder Road
Under the Build Alternative, one off-ramp termini intersection, 10th Street and the I-205 southbound off-
ramps, would experience off-ramp queues that would spill back onto the I-205 mainline, causing negative
effects on mainline operations during the AM peak hour only. Table 3-7 lists the intersections where there
would be impacts. It includes whether the impact was identified as part of the 2027 or 2045 analysis, or
both, and whether the intersection would meet standards under the No Build Alternative but not the Build
Alternative, or if it would fail under both alternatives but be comparatively worse under the Build Alternative.
23
An intersection is considered comparatively worse if the calculated v/c ratio in the Build Alternative is at least 0.05
greater than in the No Build Alternative, or the increase in average delay at the intersection is at least 10 seconds
greater based on the jurisdictional mobility measure.

I-205 Toll Project
Figure 3-7. Summary of Intersection Effects in 2027 and 2045 in the Area of Potential Impact

I-205 Toll Project
Figure 3-8. Summary of Intersection Effects in 2027 and 2045 the Area of Potential Impact
within Oregon City, West Linn, Gladstone

I-205 Toll Project
Table 3-7. Summary of Intersection Impacts

Meets Standards Does Not Meet
with No Build, Standards in No
but Not with Build, Worsens
Build in Build
ID[1] Intersection Traffic Control 2027 2045 2027 2045
18 7th St and Main St Signalized X
19 OR 99E and I-205 Northbound Ramps Signalized X X
20 OR 99E and I-205 Southbound Ramps Signalized X
21 OR 99E and 15th St Stop Controlled X
23 OR 99E and 10th St Signalized X
25 OR 99E and Arlington St Signalized X
32 SE 82nd Dr and I-205 Northbound Ramps Signalized X
35 SW Stafford Rd and SW Mountain Rd Stop Controlled X X
36 SW Borland Rd and SW 65th Ave Signalized X
37 12th St and Willamette Falls Dr All-Way Stop Controlled X
38 I-5 Northbound Ramps and Nyberg St Signalized X
39 I-5 Southbound Ramps and Nyberg St Signalized X
41 McLoughlin Blvd (OR 99E) and 14th St Signalized X X
42 SW Stafford Rd and SW Childs Rd Roundabout X
43 SW Stafford Rd and SW Rosemont Rd Roundabout X X
44 OR 43 and McVey Ave Signalized X X
45 OR 43 and A Ave Signalized X
46 OR 99E and South End Rd Signalized X X
47 OR 99E and New Era Rd Stop Controlled X X
48 OR 99E and Ivy St Signalized X X
49 OR 99E and Lone Elder Rd Stop Controlled X X
[1] Each intersection ID number corresponds to the location numbers identified in Figure 3-1.
Of the 50 study intersections, the majority would not experience new impacts under the Build Alternative
compared to the No Build Alternative in 2027 or 2045. As shown in Figure 3-7, Figure 3-8, and Table 3-7,
4 intersections would experience impacts only in 2027; 7 intersections would experience impacts only in
2045; and 10 intersections would experience impacts in both 2027 and 2045 under the Build Alternative
compared to the No Build Alternative. Section 3.1.4 describes potential mitigation strategies for these
impacts.
Transit
Analysts modeled future transit conditions in the API by projecting travel times on key roadways, MMLOS,
and ridership. Section 5.3.4 of Appendix C, I-205 Toll Project Transportation Technical Report, provides
more detailed information about projected transit operations.
Transit travel times in 2045 would differ between the No Build and Build Alternatives depending on
location and time of day. In general, the Build Alternative would have:
• Shorter travel times than the No Build Alternative in the I-205, OR 213, SW Stafford Road, and
SW Borland Road corridors during both the AM and PM peak periods.
• Longer travel times than the No Build Alternative in the Willamette Falls Drive, OR 43, and OR 99E
corridors, although certain segments would experience shorter travel times during the AM and/or PM
peak periods.

I-205 Toll Project
• Longer travel times than the No Build Alternative on southbound Main Street in downtown Oregon
City from 14th Street to OR 99E during the PM peak period, and longer travel times to a lesser
degree on northbound Main Street between 11th Street and 15th Street during the AM peak period.
Analysts modeled transit MMLOS only for OR 43, Willamette Falls Drive, and OR 99E because I-205,
OR 213, SW Stafford Road, and SW Borland Road in the API do not currently have transit stops, so the
MMLOS analysis is not applicable. There would be better overall MMLOS on OR 43 under the Build
Alternative (MMLOS A) than the No Build Alternative (MMLOS B). Overall transit MMLOS would be the
same under both alternatives in 2045 for Willamette Falls Drive (MMLOS E) and OR 99E (MMLOS C).
However, for OR 99E, transit MMLOS would differ by segment. In the southbound direction between
11th Street and Main Street, transit MMLOS would be worse under the Build Alternative (MMLOS E) than
the No Build Alternative (MMLOS D). In the northbound direction south of the Railroad Avenue
intersection, transit MMLOS would be worse under the Build Alternative (MMLOS D) than the No Build
Alternative (MMLOS C).
Future transit ridership levels in the API would be similar between the No Build Alternative and the Build
Alternative. For transit routes that use I-205, the number of transit boardings would be less than 2%
higher under the Build Alternative than under the No Build Alternative. For transit routes that do not use
I-205, the number of transit boardings would be less than 1% higher for the Build Alternative compared to
the No Build Alternative. Routes that use I-205 would benefit from improved I-205 travel times under the
Build Alternative.
All of the study intersections would have the same pedestrian LTS under both alternatives in 2045 except
for the all-way stop intersection at 12th Street and Willamette Falls Drive, which would have a worse
pedestrian LTS under the Build Alternative (pedestrian LTS 3) than the No Build Alternative (pedestrian
LTS 2) because there would be more traffic volume under the Build Alternative.
Most pedestrian study corridors would experience no differences in MMLOS between the No Build and
Build Alternatives, except in two areas:
• Westbound SW Borland Road from Ek Road to SW Stafford Road would experience worse
pedestrian MMLOS under the Build Alternative than the No Build Alternative (change from a range of
MMLOS C to E to MMLOS E). This one-mile section of rural roadway has little pedestrian activity and
limited pedestrian facilities; however, conditions for the pedestrians that do use portions of this
roadway segment would worsen somewhat due to an overall increase in traffic under the Build
Alternative.
• Southbound OR 99E from 11th Street to Main Street in downtown Oregon City would experience
worse pedestrian MMLOS under the Build Alternative than the No Build Alternative (change from
MMLOS C to MMLOS E). This 0.4 mile section of roadway has sidewalks (about 5 feet wide) with no
buffer from moving traffic for most of its length.
There would be no difference in bicycle LTS between the No Build Alternative and Build Alternative.
information about projected active transportation operations.
Truck Freight Mobility

Most of the truck freight routes within the API would experience shorter travel times or no substantial
changes in travel times under the Build Alternative compared to the No Build Alternative, as shown in

I-205 Toll Project
Table 3-8. Section 5.3.6 of Appendix C, I-205 Toll Project Transportation Technical Report, provides more
detailed information about projected freight operations.
Travel times on I-205 would be 26% to 53% shorter under the Build Alternative than the No Build
Alternative, depending on the peak period and direction. Northbound I-5 travel times would be shorter in
both the AM and PM peak periods compared to the No Build Alternative. Southbound I-5 (from the OR
217 interchange to Boone Bridge) travel times would vary, with the AM peak period generally
experiencing longer travel times and the PM peak period generally experiencing shorter travel times.
Northbound OR 99E would experience overall shorter travel times between Canby and Gladstone in the
AM peak period, with the greatest differences occurring between Canby and S 2nd Street. Southbound
OR 99E would experience slightly longer overall travel times in both the AM and PM peak periods, with
the largest difference of nearly 3 minutes occurring through Oregon City between W Arlington Street and
S 2nd Street during the AM peak period.
Table 3-8. Truck Freight Corridor Travel Times for 2045 Build and No Build Alternatives
(minutes)
Build No Build % Difference
Corridor From To 7-9 AM 4-6 PM 7-9 AM 4-6 PM 7-9 AM 4-6 PM
I-205 NB I-5 ramps SE 82nd Drive 10.7 12.7 14.9 27.2 -28%† -53%†
I-205 SB SE 82nd Drive I-5 ramps 10.7 10.5 14.5 14.2 -26%† -26%†
OR 213 NB Glen Oak Rd I-205 Interchange 8 6.2 9.7 6.5 -18%† -5%†
I-205
OR 213 SB Glen Oak Rd 5.8 6.1 6 6.1 -3%† 0%
Interchange
OR 217
I-5 NB Boone Bridge 18.5 13.5 22.4 14.1 -17%† -4%†
interchange
I-5 NB 1 Boone Bridge I-205 NB off-ramp 7.1 8.1 9.3 8.2 -24%† 0%
OR 217
I-5 NB 2 I-205 NB off-ramp 11.4 5.4 13.1 6.0 -13% †
-10%†
interchange
OR 217 Willamette River
I-5 SB 11.7 12.7 10.8 14.8 8%* -14%†
interchange Bridge
OR 217
I-5 SB 1 I-205 SB off-ramp 5.8 6.3 4.9 6.2 18%* 2%*
interchange
Willamette River
I-5 SB 2 I-205 SB off-ramp 5.9 6.4 5.9 8.6 0% -26%†
Bridge
OR 99E NB Grant St (Canby) Concord Rd 25.9 21.6 29.4 21.3 -12%† 1%
OR 99E
Grant St (Canby) S 2nd Street 11.2 11.3 13.8 11.2 -19%† 1%
NB 1
OR 99E
S 2nd Street W Arlington St 9.9 5.5 10.7 5.3 -7%† 4%*
NB 2
OR 99E
W Arlington St Concord Rd 4.8 4.8 4.9 4.8 -2% 0%
NB 3
OR 99E SB Concord Rd Grant St (Canby) 27.8 23.2 24.8 21.9 12%* 6%*
OR 99E
Concord Rd W Arlington St 4.8 4.7 4.9 4.8 -2% -2%
SB 1
OR 99E
W Arlington St S 2nd Street 11.7 7.4 8.9 6.1 31%* 21%*
SB 2
OR 99E
S 2nd Street Grant St (Canby) 11.3 11.1 11.0 11.0 3%* 1%
SB 3
Notes: Values shaded green† indicate a better travel time under the Build Alternative compared to the No Build
Alternative, and values shaded red* indicate a worse travel time under the Build Alternative compared to
the No Build Alternative. Changes of 2% or less were considered negligible and are not marked.

I-205 Toll Project
Transportation Safety
The safety analysis for 2027 and 2045 conditions included calculating predicted crash frequencies
(number of crashes) for the study intersections, key study roadways, and I-205. The analysis estimates
predicted average crash frequency as a function of traffic volume and roadway characteristics (e.g.,
number of lanes, median type, intersection control, number of approach legs). Section 5.3.7 of Appendix
C, I-205 Toll Project Transportation Technical Report, provides more detailed information about projected
transportation safety.
Study Intersection Predictive Analysis

The number of predictive crashes would vary between the Build Alternative and No Build Alternative in
both 2027 and 2045 due to local traffic volume differences related to rerouting of I-205 traffic to avoid
tolls. In 2027, the largest intersection differences would occur at the intersection of OR 99E and the I-205
southbound ramps, where there would be about three more predictive crashes under the Build
Alternative, and at the OR 213 and I-205 northbound ramps, where there would be about six fewer
predictive crashes under the Build Alternative compared to the No Build Alternative. In 2045, the largest
intersection differences would occur at the intersections of 10th Street and at the I-205 southbound
ramps, where there would be about three more predictive crashes under the Build Alternative, and at the
OR 43 and I-205 northbound ramps intersection, where there would be about four fewer predictive
crashes.
Study Roadway Predictive Analysis

The number of predictive crashes would be similar under both the No Build and Build Alternatives in both
2027 and 2045 for most study roadway segments. In 2027, the largest differences would occur along
OR 99E, where there would be about 36 more predictive crashes under the Build Alternative compared to
the No Build Alternative, and on OR 213, where there would be about 2 fewer predictive crashes under
the Build Alternative compared to the No Build Alternative. In 2045, the largest differences would occur
along Willamette Falls Drive and OR 99E, where there would be about seven and five more predictive
crashes on each roadway respectively under the Build Alternative compared to the No Build Alternative.
There would be about two fewer predictive crashes on OR 43 under the Build Alternative compared to the
No Build Alternative.
I-205 Predictive Analysis

In 2045, there would be about 26% fewer predictive crashes (representing 144 total crashes) along I-205
in the API under the Build Alternative compared to the No Build Alternative due to lower traffic volumes
associated with tolling and lane configuration changes associated with the Build Alternative. The
predictive number of crashes at I-205 ramps would be similar (about four fewer crashes under the Build
Alternative) between both alternatives.

I-205 Toll Project
Safety Impacts
Analysts identified safety impacts at intersections and key roadways segments under the Build Alternative
based on predictive 2027 and 2045 crash data and whether they met primary or secondary criteria 24 for
differences in safety performance, as described in more detail in Section 5.4.4 of Appendix C, I-205 Toll
Project Transportation Technical Report. When an intersection or segment would meet one or more of the
primary criteria, even if it would not meet any secondary criteria, mitigation would be considered. When
an intersection or segment would not meet the primary criteria but would meet one or more of the
secondary criteria, conditions would be monitored to determine if mitigation should be considered. Table
3-9 and Table 3-10 show intersections and roadway segments that would meet the primary and/or
secondary criteria under the Build Alternative in 2027 and 2045.
Table 3-9. Intersections with Safety Impacts under Build Alternative Based on Criteria
Evaluation
2027 2045
Primary Secondary Primary Secondary
ID[1] Intersection Criteria Criteria Criteria Criteria
18 7th Street and Main St X
27 OR 99E and Jennings Ave X X
35 SW Stafford Rd and SW Mountain Rd X X
38 I-5 Northbound ramps and SW Nyberg St X X
39 I-5 Southbound ramps and SW Nyberg St X X
42 SW Stafford Rd and SW Childs Rd X
43 SW Stafford Rd and SW Rosemont Rd X
48 OR 99E and S Ivy Street X X X
49 OR 99E and S Lone Elder Rd X
[1] See Figure 3-1 for intersection location by number.
Table 3-10. Key Roadway Segments with Safety Impacts under Build Alternative Based on
Criteria Evaluation
2027 2045
Primary Secondary Primary Secondary
Roadway Roadway Segment Limits Criteria Criteria Criteria Criteria
SE Glen Echo Ave to Main St
OR 99E X
(overcrossing)
OR 99E W Gloucester Street to W Dartmouth St X
OR 99E W Arlington Street to Main Street X
OR 99E N Redwood St to Ivy St X X X
SW Stafford Rd SW Johnson Rd to SW Childs Rd X
MP = mile post
24
Primary Criteria: When the total fatality/severe injury crashes would increase by 0.05 crash per year (equivalent
to one fatality/severe injury crash every 20 years), and/or if the intersection or segment is identified as a Safety
Priority Index System location and the total fatality/severe injury crashes would increase by 0.01 crash per year
(equivalent to one fatality/severe injury crash every 100 years).
Secondary Criteria: If the intersection exceeds the critical crash rate under existing conditions and if the total
fatality/severe injury crashes would increase by any amount; if the segment is classified as a safety corridor and if
the total fatality/severe injury crashes increase by any amount; and/or if the intersection does not meet the
mobility standard and would worsen with the Project, and if the total fatality/severe injury crashes would increase
by any amount.

I-205 Toll Project
3.1.3 Summary of Effects

Table 3-11 provides a comparison of all anticipated transportation impacts and benefits by alternative.
Table 3-11. Summary of Transportation Effects by Alternative

Effects No Build Alternative Build Alternative
Short-Term • None • The number and speed of I-205 through lanes would generally
Effects be maintained throughout construction of the Project.
• Nighttime lane closures of I-205, SW Borland Road, and
Woodbine Road in accordance with Oregon Standard
Specifications for Construction would be necessary during
demolition of existing structures and erection of new bridge
beams.
• Limited full I-205 roadway closures would be required, with
short-term detours in place as needed.
• Transportation effects resulting from implementation of tolling
before completion of the I-205 improvements would be
comparable to those caused by the Build Alternative in 2027
and would last for 2 to 3 years starting in approximately 2024.
Direct • 16 of 50 study • 1 of 50 study intersections that would not meet standards under
Impacts and intersections would not the No Build Alternative would meet standards under the Build
Benefits– meet jurisdictional Alternative during the AM peak hour.
2027 Analysis mobility standards • 5 of 50 intersections that would meet standards under the No
Results during the AM and/or Build Alternative would not meet standards under the Build
PM peak hour. Alternative during the AM and/or PM peak hours.
• 15 of 50 intersections would not meet mobility standards in the
AM and/or PM peak hour under both alternatives. Of those,
9 intersections would get comparatively worse under the Build
Alternative.
• Based on the predictive safety analysis, 4 of the
50 intersections were identified to experience impacts under the
Build Alternative.
• Based on the predictive safety analysis, 4 segments along
OR 99E and 1 segment along SW Stafford Road were identified
to experience impacts under the Build Alternative.
Direct • 24 of 50 study • 1 of 50 study intersections that would not meet standards under
Impacts and intersections would not the No Build Alternative would meet standards under the Build
Benefits – meet jurisdictional Alternative during the PM peak hour.
2045 Analysis mobility standards • 3 of 50 intersections that would meet standards under the No
Results during the AM and/or Build Alternative would not meet standards under the Build
PM peak hour. Alternative during the AM and/or PM peak hours.
• All of the northbound • 23 of 50 intersections would not meet mobility standards in the
I-205 segments except AM and/or PM peak hour under both alternatives. Of those,
the on-ramp segment 13 intersections would get comparatively worse under the Build
from OR 213 would Alternative.
meet the mobility
• Travel times and operating LOS would improve on I-205 in the
standard of a v/c ratio of
AM and PM peak hours in both directions.
0.99 during the AM and
PM peak hours. • All of the northbound I-205 segments would meet the HDM v/c
ratio mobility standard of 0.75 except for 3 segments in the
• All of the southbound
AM peak hour and 2 segments in the PM peak hour.
I-205 segments except
the segment after the • All of the southbound I-205 segments would meet the HDM v/c
on-ramp from OR 213 ratio mobility standard of 0.75 except for 1 segment in the AM
would meet the mobility peak hour and 5 segments in the PM peak hour.
standard of a v/c ratio of • The 10th Street and southbound I-205 off-ramp termini
0.99 during the PM intersection would experience off-ramp queues that would spill
peak hour. back onto I-205, causing impacts on mainline operations
(AM peak hour only).

I-205 Toll Project

• Pedestrian LTS at the • Travel-time reliability along I-205 in the peak periods would
intersection of 12th improve compared to the No Build Alternative. During the
Street and Willamette PM peak period in the northbound direction, travel time
Falls Drive would be variability over the 2-hour time period would be 47% lower, and
better than under the travel-time variability during any single point in time would be
Build Alternative. 75% lower.
• Overall, transit MMLOS would be better under the Build
Alternative than the No Build Alternative. Two transit roadway
segments would experience lower MMLOS under the Build
Alternative.
• Peak-period travel times along Main Street in Oregon City
would be longer under the Build Alternative.
• Two roadway segments would experience lower pedestrian
MMLOS, and 1 intersection would experience worse pedestrian
LTS.
• Expected crash frequencies would be 26% lower on I-205.
Indirect • Rerouting to other • Due to tolling, slight changes in mode choice away from single-
Impacts and roadways due to occupancy vehicles would occur.
Benefits congestion on I-205 • Vehicle users may avoid peak-period travel to avoid paying
would occur under the tolls.
No Build Alternative.
• For transit routes in the API, transit ridership would be slightly
higher under the Build Alternative than under the No Build
Alternative.
API = area of potential impact; LOS = level of service; LTS = level of traffic stress; HDM = Highway Design Manual;
MMLOS = multimodal level of service; ODOT = Oregon Department of Transportation; v/c = volume-to-capacity
3.1.4 Avoidance, Minimization, and/or Mitigation Measures

This section describes potential mitigation strategies to avoid, minimize, or mitigate roadway, transit,
active transportation, and safety impacts identified in Section 3.1.2. The impacts and potential mitigation
strategies are categorized as near-term (related to 2027 impacts) and longer-term (related to 2045
impacts). ODOT will identify final mitigation strategies in coordination with the local jurisdictions and with
input from comments on this Environmental Assessment. The Revised Environmental Assessment will
include ODOT’s final mitigation commitments and their potential environmental effects.
Roadway Mitigation
One of the first actions that ODOT would take is to set up a transportation system monitoring program to
be in place prior to the initial implementation of tolls on I-205. This program would track conditions on
roadways in the API, as agreed upon with local jurisdictions, to assess the extent of rerouting and its
effect on the system. This program would be used to identify impacts of tolling prior to and after the
construction of the planned I-205 improvements. Based on this data ODOT would have the ability to
identify and implement new mitigation requirements and/or move up mitigation planned for a later date. In
addition, ODOT may establish a group consisting of local leaders, staff, and/or elected officials to meet
with ODOT staff immediately after tolling is implemented to be a direct line of communication with ODOT
to address rerouting concerns. Any mitigation proposed to address near-term impacts that is determined
to also help alleviate pre-completion tolling impacts could be implemented before tolling begins.
Implementation of mitigation strategies may cause secondary impacts at adjacent intersections or

roadways. Secondary impacts from implementing mitigation measures may require additional avoidance,
minimization, or mitigation measures. An assessment of the effects associated with mitigation will be
included in the Revised EA.

I-205 Toll Project
The summaries of potential roadway mitigation measures for intersections and roadway segments are
grouped into following geographic areas:
• OR 99E/Oregon City/Gladstone area (Table 3-12)
• OR 99E/Canby area (Table 3-13)
• Willamette Falls Drive/West Linn area (Table 3-14)
• SW Stafford Road and SW Borland Road area (Table 3-15)
• OR 43/Lake Oswego area (Table 3-16)
• Tualatin area (Table 3-17)

I-205 Toll Project
Table 3-12. Proposed Mitigation for OR 99E/Gladstone/Oregon City Area

Mitigation Type Analysis Year
Impact Active Transportation

Location Traffic Transit Pedestrian Bike Safety 2027 2045
OR 99E/ None proposed None proposed None proposed None proposed Rear end and angle type X
Jennings Ave crashes were
predominant. Add 3-inch
yellow reflective sheeting
to signal backplates.
OR 99E None proposed None proposed None proposed None proposed Install a raised median and X
between SE trees alongside the
Jennings roadway.
Avenue and
SE Glen Echo
Avenue
OR 99E/ None proposed None proposed None proposed None proposed Rear end and angle type X
Gloucester St crashes were
predominant. Add 3-inch
yellow reflective sheeting
to signal backplates
OR 99E None proposed None proposed None proposed None proposed Crash patterns involved X
between SE pedestrians that resulted
Glen Echo in a fatality or severe
Avenue and W injury; two of those
Dartmouth crashes occurred during
Street dusk/dark. Install a raised
median, trees alongside
the roadway, amid-block
crossing, and lighting on
roadway.
OR 99E/ Reconfigure the east leg Transit signal priority Modify the signal None proposed Reconfigure intersection X
Arlington St approach to include a (pending agreement on timing to provide
separate left-turn lane with acceptable technology) leading pedestrian
protected phasing and a intervals at all
shared through-right-turn lane protected pedestrian
and reconfigure the west leg crossings
to be one-way eastbound with
right-turn only.

I-205 Toll Project

OR 99E None proposed None proposed None proposed None proposed Crash patterns involved X
between W pedestrians that resulted
Arlington in a fatality or severe
Street and injury; two of those
Main Street crashes occurred during
dusk/dark. Install a raised
median, trees alongside
the roadway, a mid-block
crossing, and lighting on
roadway.
OR 99E North None proposed Widen to provide None proposed Improve signing None proposed X
of Dunes Dr southbound transit queue and striping for
jump space (i.e., an area cyclists to use
that allows transit to northbound ramp
“jump” ahead of cars with from bike lane to
an advance green light) sidewalk before it
just north of Dunes Dr reaches the
Clackamas River
Bridge
OR 99E/ None proposed Transit signal priority None proposed None proposed None proposed X
Dunes Dr (pending agreement on
acceptable technology)
OR 99E/ I-205 Provide transit lane bypass of Transit signal priority None proposed None proposed Rear end and angle type X
Southbound on-ramp meter on (pending agreement on crashes were
Ramps southbound on-ramp. technology) predominant. Add 3-inch
Provide northbound bus yellow reflective sheeting
pocket at intersection and to signal backplates.
implement advance green
light

I-205 Toll Project

OR 99E/ I-205 Provide southbound dual left- Transit signal priority None proposed None proposed Rear end and angle type X
Northbound turn lanes; westbound dual (pending agreement on crashes were
Ramps left-turn lanes; northbound technology), advance predominant. Add 3-inch
dual right-turn lanes (starting green for southbound yellow reflective sheeting
at 15th St); allow northbound transit to signal backplates.
permitted turns (i.e., allow a
left turn on a flashing yellow
arrow signal when there is a
safe gap in opposing traffic)
plus an overlap phase (i.e.,
allow a left-turn movement
from one street at the same
time as a right-turn movement
from the intersecting street).
OR 99E/ Convert 15th St to one-way None Proposed Provide pedestrian None proposed None proposed X
15th St westbound between Main St refuge island between
and OR 99E; start a fourth the 2 right-turn lanes
northbound lane on OR 99E on 15th St, include
north of 15th St that becomes RRFB for pedestrian
the second northbound right- crossing safety
turn lane at the intersection of
OR 99E and I-205
northbound ramps.
OR 99E/ Start third northbound lane Transit signal priority None proposed None proposed None proposed X
14th St just north of 14th St, which (pending agreement on
becomes one of two right-turn technology)
lanes to the I-205 northbound
on-ramp.
OR 99E/ None proposed Transit signal priority None proposed None proposed None proposed X
12th St (pending agreement on
technology)
OR 99E/ Extend southbound left-turn None proposed Widen/Improve None proposed Sidewalk improvements X
10th St lane to 12th St; monitor to southbound sidewalk between 10th St and
assess the effects of the on OR 99E between Railroad Ave are expected
improvement over time and 10th Street and to improve pedestrian
determine if additional long- Railroad Avenue safety.
term mitigation would be
required.

I-205 Toll Project

OR 99E from None proposed None proposed Coordinate with the City of Oregon City to Install coordination or X X
10th St. to implement the OR 99E Bike and adaptive signal timing or
Railroad Ave Pedestrian Improvements Project, which urban traffic signals. Install
would improve active transportation speed feedback sign.
facilities on the southbound side of OR
99E.
Main St/ 7th St None proposed None proposed Implement pedestrian improvements, as None proposed X
noted for OR 99E from 10th St to Railroad
Ave above to improve overall mobility in the
area.
Main St/ Add traffic signal (pending Transit signal priority for Signal provides None proposed None proposed X
10th St completion of additional southbound left turns protected crossing;
analysis) (pending agreement on include pedestrian
acceptable technology) signal and leading
pedestrian interval
SE 82nd Dr Add an additional westbound None proposed None proposed None proposed None proposed X
and I-205 through lane that extends
northbound through the SE 82nd Dr and
ramps[1] the I-205 southbound ramps
and a left-turn lane on the
northbound off-ramp onto SE
82nd Dr. These lane additions
could be accommodated by
restriping the westbound
approach and widening the
roadway onto the shoulder
and by restriping the
northbound approach.
RRFB = rectangular rapid flashing beacon
[1] Due to uncertainty regarding the projected traffic volumes, ODOT proposes to monitor this location and only implement the proposed mitigation if the actual
conditions warrant it.

I-205 Toll Project
Table 3-13. Proposed Mitigation for OR 99E/Canby Area

Analysis Year
Improvement Type Impact
Active Transportation Safety 2027 2045
Location Traffic Transit Pedestrian Bike
OR 99E and Signalize intersection; add None proposed None proposed None proposed None proposed X
South End Rd southbound through lane
and northbound right-turn
lane. Reduce the lane
widths to account for
physical constraints and
include advanced warning
for signal.
OR 99E Advance warning signing/ None proposed None proposed None proposed Crash patterns along this X
between South flashers for new signal at segment of the corridor were
End Rd and South End Rd primarily rear end. Adding
Haines Rd (northbound). lighting and speed feedback sign
is expected to improve safety.
OR 99E and Provide a roundabout; Provide the following transit- Install crosswalks None proposed Converting the current stop- X
Haines/New related improvements: and RRFBs to controlled intersection to a
Era Rd • Landing pads at bus improve pedestrian roundabout is expected to
stops (i.e., paved area at access to bus stops improve safety.
the bus stop where and safety for
passengers board or exit crossing
the bus)
• Crosswalks with RRFB to
facilitate crossing of
OR 99E
• Extend sidewalks to
New Era Rd
OR 99E None proposed None proposed None proposed None proposed Crash patterns along this X
between N segment of the corridor were
Redwood St primarily angle and turning type
and SE Berg crashes. Install coordination or
Pkwy adaptive signal timing or urban
traffic signals. Install mid-block
crossing. Install speed-feedback
sign. Traffic signal Improvements
along signalized intersections
within this segment are expected
to improve traffic safety.

I-205 Toll Project
Analysis Year
OR 99E and Consider operational None proposed Provide more Add green dashed Angle type crashes were X
Ivy St improvements at OR 99E prominent crosswalk bike crossing predominant at this intersection.
and Pine St to facilitate markings markings across Add 3-inch yellow reflective
more traffic use of that OR 99E. sheeting to signal backplates.
intersection to reach Left-turning traffic calming
downtown Canby, thereby treatment (e.g., hardened
alleviating some traffic centerline) and traffic signal
impact at Ivy St. Improvements at this location are
expected to improve traffic
safety.
OR 99E and Square up existing skewed None proposed None proposed None proposed Traffic operations improvements X
Lone Elder Rd approach and provide listed for this location are
southbound refuge lane for expected to improve traffic
westbound left turns safety.
mph = miles per hour; RRFB = rectangular rapid flashing beacon

I-205 Toll Project
Table 3-14. Proposed Mitigation for Willamette Falls Drive/West Linn Area
Analysis Year
Willamette Falls None proposed None proposed To improve crosswalk None proposed The pedestrian X
Dr/ 12th St visibility/prominence, install solar mobility
panel stop signs with red-edge improvements
light features listed for this
location are also
proposed as safety
improvements.
12th St between None proposed None proposed Potential improvements include Add bicycle lane along The pedestrian and X
Willamette Falls add RRFB for crosswalk at school 12th St from Willamette bicycle mobility
Dr and Tualatin (at 12th St and 5th St.), add Falls Dr to Tualatin Ave improvements
Ave "school zone" sign with 20-mph to facilitate safe routes listed for this
speed limit when flashing to school as well as location are also
(advanced warning); add another access to Willamette proposed as safety
prominent crosswalk (6th Ave), Park. improvements.
extend Willamette Falls Dr
streetscape down 12th St to the
school, including adding curb
extensions
I-205 ramps at I-205 off-ramp queues None proposed None proposed None proposed None proposed X
10th St[1] could potentially extend
beyond capacity and
affect I-205 mainline
operations by 2045 at
the 10th Street and
I-205 southbound off-
ramps intersection
during the AM peak
hour. Monitor this area
to determine when or if
mitigation is needed.
mph = miles per hour; RRFB = rectangular rapid flashing beacon
[1] Due to uncertainty regarding the projected traffic volumes, ODOT proposes to monitor this location and only implement mitigation if the actual conditions
warrant it.

I-205 Toll Project
Table 3-15. Proposed Mitigation for SW Stafford Road and SW Borland Road Area
Analysis Year
SW Stafford Rd/ None proposed None proposed Install RRFB on east and north legs None proposed The pedestrian and bicycle X
SW Rosemont of the roundabout, improve lighting mobility improvements listed
Rd for pedestrians, install raised for this location are also
crosswalks around intersection, proposed as safety
improve lighting improvements.
SW Stafford Rd/ Convert to a None proposed None proposed None proposed Converting the current stop- X
SW Mountain Rd roundabout controlled intersection to a
roundabout is expected to
improve safety.
SW Borland Rd None proposed None proposed Contribute to RTP Constrained None proposed None proposed X
between SW Project: 65th Ave, Tualatin River to I-
65th Ave and 205 (RTP ID 11428):
SW Stafford Rd
SW Borland Rd/ Install an all-way None proposed None proposed None proposed The traffic improvements X
Ek Rd stop or roundabout proposed for this location are
pending further also expected to improve
analysis safety.
SW Borland Rd None proposed None proposed Contribute to RTP Contribute to RTP The pedestrian and bicycle X
between SW Strategic/Clackamas County Strategic/Clackamas mobility improvements listed
Stafford Rd and Transportation System Plan: Borland County for this location are expected
Tualatin River Rd, Stafford Rd to West Linn city Transportation to improve safety for active
Bridge limits (RTP/CC TSP 1082): Add System Plan: transportation modes.
paved shoulders in accordance with Borland Rd, Stafford
the active transportation plan Rd to West Linn city
limits (RTP/CC TSP
1082): Add paved
shoulders in
accordance with the
active transportation
plan

I-205 Toll Project
Table 3-16. Proposed Mitigation for OR 43/Lake Oswego Area

Analysis Year
OR 43 between A Signal coordination (or adaptive None None proposed None proposed None proposed X
Ave and McVey signal control) on OR 43 at the proposed
Ave, including three signals between and
intersections ofincluding A Ave and McVey Ave
OR 43/A Ave and (at Foothills Rd, Northshore Rd,
OR 43/ McVey and Middlecrest Rd/Wilbur St).
Ave Coordination with railroad would
be required to implement the
proposed improvements.
OR 43/McVey Ave None proposed None Improve pedestrian crossings, None proposed The pedestrian and X
proposed including completing crosswalks mobility improvements
and pedestrian signals around listed for this location
the intersection if feasible, and are expected to
also adding LPI (contingent on improve safety for
benefit analysis approved by active transportation
ODOT); enhance signing for modes.
motorist awareness of
pedestrians and signalize
currently unprotected crossing of
the southbound right-turn lane
from OR 43 to McVey Ave.
Signalizing the southbound to
westbound slip lane will be
considered for better pedestrian
safety.
LPI = leading pedestrian interval; RRFB = rectangular rapid-flashing beacon

I-205 Toll Project
Table 3-17. Proposed Mitigation for the Tualatin Area

Analysis Year
Nyberg St/ I-5 Potential traffic impact identified None proposed Monitor conditions to None Rear end and angle X
Southbound in 2027 but not 2045. City of assess need for proposed type crashes were
Ramps Tualatin is reconfiguring this future improvements. predominant at this
intersection. Recommend location. Add 3-inch
monitoring subsequently to yellow reflective
identify if mitigation is needed. sheeting to signal
backplates.
Nyberg St/ I-5 Potential traffic impact identified None proposed Monitor conditions to None Rear end and angle X
Northbound in 2027 but not 2045. assess need for proposed type crashes were
Ramps Recommend monitoring future improvements. predominant at this
subsequently to identify if location. Add 3-inch
mitigation is needed. yellow reflective
sheeting to signal
backplates.
SW 65th Ave/ SW Monitor for need for potential Complete None None proposed X
Borland Rd long-term mitigation, including None proposed crosswalks and proposed
restriping the westbound pedestrian signals
approach as one left-turn lane around the
and one shared through/right-turn intersection if
lane and adding an exclusive feasible, and LPI
northbound right-turn lane. (contingent on
Additional changes to signal benefit analysis
phasing/timings would be approved by ODOT).
required. This improvement
would likely require some sliver
right-of-way acquisitions.
LPI = leading pedestrian interval

I-205 Toll Project
Transit Mitigation
Multiple factors affect transit MMLOS, including transit speed and reliability, and the ability for pedestrians
to safely access transit stops. Implementing transit priority treatments and improving pedestrian facilities
along the following transit corridor segments would improve transit MMLOS:
• OR 99E from 11th Street to Main Street (southbound direction) (2027 impact): Currently, the
only TriMet route using this stretch of roadway is Route 33. However, TriMet is planning to revise the
route and remove it from this portion of OR 99E. Nonetheless, transit MMLOS and pedestrian access
would be improved along this stretch by improving sidewalks (see Table 3-12).
• OR 99E from Railroad Avenue to MP 12.74 (northbound direction): Currently, the only TriMet
route using this stretch of roadway is Route 33. However, TriMet is planning to revise the route and
remove it from this portion of OR 99E. The removal of this route from this portion of OR 99E would
remove any transit-related impact from the Project.
Active Transportation Mitigation

Potential pedestrian impacts were identified along the roadway segments listed below (associated
improvements are also contained in the mitigation measures summarized in Tables 3-12, 3-13, and 3-15,
as noted):
• Consider paving the shoulders on SW Borland Road between SW Stafford Road and Ek Road (extent
to be determined through ODOT coordination with local jurisdictions) (see Table 3-15).
• Improve pedestrian conditions at OR 99E from 11th Street to Main Street as identified above in the
Transit Mitigation section to improve transit MMLOS (see Table 3-12).
• Due to geometric and other constraints, active transportation mitigation opportunities may potentially
be assessed at the following intersections to improve overall operations for all modes:
- SW Stafford Road and SW Rosemont Road (see Table 3-15)
- Main Street and 7th Street
- McLoughlin Boulevard and 10th Street (see Table 3-12)
- OR 99E and Ivy Street (see Table 3-13)
Safety Mitigation
Potential safety impacts under the Build Alternative in 2027 were identified at the intersections and
roadway segments listed in the Safety Impacts subsection of Section 3.1.2. Safety impacts identified for
the year 2045 were also documented, and those locations will be monitored to determine if they require
mitigation in the longer-term.
Based on the criteria presented in the Safety Impacts subsection of Section 3.1.2 and presented in more
detail in Section 5.4.4, Safety Effects, of Appendix C, I-205 Toll Project Transportation Technical Report,
several locations were identified for evaluation of safety-specific mitigation based on the 2027 safety
analysis. Some of these locations were also identified as needing operational mitigation, as well as
operational improvements. For these locations, the Project Team conducted a follow-up safety analysis
incorporating the recommended operational improvements. For some locations, the operational
improvements positively affected safety to the extent that the location no longer met either of the primary
safety criteria. These locations included the following intersections, which were therefore not analyzed for
further safety mitigation:
• OR 99E and Arlington Street
• SW Stafford Road and Rosemont Road

I-205 Toll Project
For the other intersections and segments, the Project Team reviewed existing crash data to identify crash
patterns that would indicate a roadway or intersection safety deficiency. Potential mitigation strategies
were selected from ODOT’s Highway Safety Improvements Program Countermeasures and Crash
Reductions Factor, which outlines a list of crash reduction factors that have been recognized as effective
countermeasures by ODOT (ODOT 2022d).
The following sections list treatments that could be implemented to improve safety at locations identified
as meeting the primary safety criteria under 2027 Build Alternative conditions. These are preliminary
safety mitigation measures, and a feasibility analysis would need to be conducted to assess the viability
of implementing these measures and to confirm consistency with other planned projects. Safety mitigation
measures are also listed in Table 3-12 through Table 3-17.
Proposed Safety Treatments

Add 3-inch Yellow Retroreflective Sheeting to Signal Backplates
Adding 3-inch yellow retroreflective sheeting to signal backplates could reduce all crashes by 15 percent.
This treatment enhances signal visibility during daytime and nighttime conditions, and it may alert drivers
of the signalized intersection during a power outage (ODOT 2022d). A signal backplate is a metal piece
that frames the signals and can be installed with a reflective border to improve the visibility of traffic lights,
especially in bright conditions.
Improve Signal Hardware: Lenses, Reflectorized Back plates, Size, and Number
Signal improvements consist of treatments such as twelve-inch signal lenses, LED lenses on all signals,
reflectorized back plates on all signal heads, supplemental signal heads, remove night flashing
operations, signal timing adjustments and adding right turn lane signal to reduce right-turn conflicts.
Implementing three to four of these treatments can reduce all crashes by 25 percent. All these treatments
can reduce crashes by increasing signal visibility and improving operations (ODOT 2022d).
Add Street Trees

Adding infill trees alongside the roadway where there is space available could reduce crashes of all
severities by up to 10 percent. Trees provide traffic calming and narrow a driver’s visual field, providing
distinct roadway edges, which help drivers guide their movements and assess their speed (ODOT
2022d).
Install Rectangular Rapid Flashing Beacon

Installing a mid-block pedestrian crossing with a Rectangular Rapid Flashing Beacon (RRFB) (3-lane or
wider roadway) could reduce pedestrian and bicycle crashes of all severities by 10 percent. RRFBs
enhance safety by increasing driver awareness of potential pedestrian conflicts (ODOT 2022d)
Install Lighting on a Roadway Segment

Installing lighting on the roadway segment could reduce night crashes of all severities by 28 percent.
Lighting allows for greater visibility to the driver of potential conflicts (ODOT 2022d).
Provide a Raised Median, Urban Multi-Lane Road

Installing a raised median on an urban multi-lane road could reduce crashes of all severities by 22
percent. Medians can reduce the frequency and magnitude of conflict points at driveways and
intersections (ODOT 2022d).

I-205 Toll Project
Speed Feedback Signs

Installing a speed feedback sign would reduce all crashes of all severities by 10 percent. Speed feedback
signs enhance safety by managing speeds and reducing the risk of speed related crashes (ODOT
2022d).
Install Coordination or Adaptive Signal Timing of Urban Traffic Signals

Installing coordination or adaptive signal timing or urban traffic signals could reduce crashes of all
severities and types by 17 percent. Coordinated signals produce vehicle platoons keeping traffic at a
constant speed, which reduce rear-end conflicts. Vehicle platooning also allows for larger gaps for drivers
making permitted turning maneuvers (ODOT 2022d).
3.2 Air Quality

The air quality API, shown in Figure 3-9, includes the roadway segments that could experience changes
in congestion (e.g., traffic volumes and speeds) under the Build Alternative, as described in Section 3.1.2.
Per FHWA guidance, the air quality analysis includes areas within the API expected to experience a
meaningful change 25 in a type of hazardous air pollutants called Mobile Source Air Toxics (MSAT)26
(FHWA 2016). The API is designated as an attainment area for all criteria pollutants under the Clean Air
Act. 27 However, ODOT conducted an analysis of criteria pollutant emissions to better understand the
effects of the Build Alternative. Chapter 4 of Appendix D, I-205 Toll Project Air Quality Technical Report,
and Appendix D1, I-205 Toll Project Criteria Pollutant Emissions Memorandum, provide a detailed
description of the methodology used for the analysis.
MSAT emissions have typically been decreasing over time due to the implementation of vehicle
standards, improved technology, and vehicle turnover. At the two monitoring sites within and closest to
the API (shown on Figure 3-9), criteria pollutants did not exceed federal air quality standard levels in
2020, although there were elevated concentrations of carbon monoxide, ozone, and particulate matter 2.5
microns or less in size (PM2.5), which the Oregon Department of Environmental Quality (DEQ) determined
were due to wildfire smoke (DEQ 2021). Chapter 5 of Appendix D and Appendix D1 provide a more
detailed description of existing air quality conditions in the API.
25
The FHWA guidance defines meaningful change in emissions as approximately plus or minus 10% between the
future No Build Alternative and Build Alternative.
26
MSATs are 1,3-butadiene, acetaldehyde, acrolein, benzene, diesel particulate matter, ethylbenzene,
formaldehyde, naphthalene, and polycyclic organic matter.
27
Under the Clean Air Act, the U.S. Environmental Protection Agency has established the National Ambient Air
Quality Standards (NAAQS), which specify maximum concentrations for carbon monoxide, particulate matter 10
microns or less in size (PM10), particulate matter 2.5 microns or less in size (PM2.5), ozone, sulfur dioxide, lead,
and nitrogen dioxide. These pollutants are referred to as criteria pollutants. Highway projects in attainment areas
are considered to be in conformity with the Clean Air Act and are not required to perform detailed analysis to
demonstrate compliance with the NAAQS.

I-205 Toll Project
Figure 3-9. Air Quality Area of Potential Impact

I-205 Toll Project

The air quality impact analysis evaluated the projected MSAT emissions from the Build Alternative as
compared to the projected emissions from the No Build Alternative in both the interim year (2027) and
design year (2045) to provide details about expected emissions changes over time.
No Build Alternative
Under the No Build Alternative, MSAT emissions in 2045 would be lower than 2027 and existing
emissions. Although VMT in 2045 in the API would be over 16% higher than it would be in 2027, MSAT
emissions would decrease due to the implementation of vehicle standards, improved technology, and
vehicle turnover. Modeled criteria pollutant emissions would also generally be lower in 2045 than in 2027
and under existing conditions. The one exception would be PM10, for which average summer day
emissions would be higher in 2045 and 2027 than under existing conditions.
Build Alternative
Short-Term Effects
Construction activities would cause temporary increases in particulate matter in the form of fugitive dust
(from ground clearing and preparation, grading, stockpiling of materials, on-site movement of equipment,
and transportation of construction materials), as well as exhaust emissions of criteria pollutants from
material delivery trucks, construction equipment, and workers’ private vehicles during the construction
period of approximately 4 years. Construction contractors for the Project would be required to comply with
Division 208 of OAR 340, which places limits on fugitive dust that causes a nuisance or violates other
regulations. In addition, contractors would be required to comply with Oregon Standard Specifications for
Construction (ODOT 2021c) for air quality (Section 290.30) and to implement air pollution control
measures that include vehicle and equipment idling limitations and that minimize vehicle track-out and
fugitive dust (ODOT 2021c).
Long-Term Effects
As shown in Table 3-18, the overall MSAT emissions would be lower under the Build Alternative in 2027
and 2045 than the No Build Alternative because of lower VMT under the Build Alternative compared to No
Build Alternative.

I-205 Toll Project
Table 3-18. MSAT Emissions (tons per year)

Percentage
Percentage Difference
Difference 2027 2045 No
2027 2027 No Build to 2045 2045 Build to
Pollutant No Build Build Build No Build Build Build
Annual VMT[1] 1,051,694,624 965,576,193 -8% 1,222,083,927 1,162,440,219 -5%
1,3-Butadiene 0.033 0.030 -8% 0.000 0.000 0%
Acetaldehyde 0.379 0.357 -6% 0.328 0.298 -9%
Acrolein 0.038 0.036 -5% 0.022 0.020 -8%
Benzene 0.985 0.899 -9% 0.707 0.647 -8%
Diesel Particulate 2.084 2.029 -3% 1.246 1.156 -7%
Matter
Ethylbenzene 0.710 0.647 -9% 0.602 0.543 -10%
Formaldehyde 0.616 0.577 -6% 0.410 0.373 -9%
Naphthalene 0.062 0.058 -7% 0.027 0.025 -8%
Polycyclic Organic 0.027 0.025 -7% 0.011 0.010 -7%
Matter
Source: Appendix D, I-205 Toll Project Air Quality Technical Report (Section 6.2.2)
[1] Annual VMT for the No Build Alternative and Build Alternative was estimated based on roadways within the air
quality API with modeled traffic volume changes. By contrast, VMT in the transportation analysis (Table 3-1) is based
on the entire Portland region's roadway network to provide a systemwide analysis of transportation behavior.
Evaluating the entire regional roadway network for the air quality analysis would result in emissions estimates for
many roadways not affected by the Project, diluting the results of the analysis, and not allowing for a meaningful
comparison between alternatives.
To determine the effects of traffic rerouting on MSAT emissions after construction of the Build Alternative,
analysts modeled emissions of benzene and diesel particulate matter, the pollutants with the greatest
emissions in all scenarios analyzed, by roadway type and vehicle type in 2027. 28 Table 3-19 shows daily
VMT by roadway type and vehicle type for No Build and Build Alternatives in 2027. While the Build
Alternative would have higher total non-highway VMT compared to the No Build Alternative, the higher
non-highway VMT would be more than offset by lower total highway VMT. In addition, the higher non-
highway VMT would be primarily from passenger vehicles. Non-highway VMT from heavy trucks, which
generally produce higher emissions, would be lower.
Table 3-19. 2027 Daily Vehicle Miles Traveled Changes within Area of Potential Impact
2027 No 2027 No 2027 Build
Build Build Non- 2027 No 2027 Build Non- 2027 Build
Vehicle Type Highway Highway Build Total Highway Highway Total
Passenger 1,553,978 1,190,246 2,744,224 1,160,118 1,332,361 2,492,479
Medium 29,453 10,546 39,999 31,214 9,924 41,139
Heavy 71,564 25,565 97,129 87,873 23,927 111,799
All 1,654,995 1,226,357 2,881,352 1,279,205 1,366,212 2,645,417
28
2027 data only was used for this portion of the analysis because the emissions would be greater in 2027 than in
2045, making it more feasible to show the distribution of vehicle and roadway types.

I-205 Toll Project
As shown in Table 3-20 and Table 3-21, total benzene and diesel particulate matter emissions for all
vehicle types on all roadway types under the Build Alternative would be lower than or equal to the No
Build Alternative in 2027. Although heavy truck VMT on highways would be approximately 22% higher
under the Build Alternative, the diesel particulate emissions from heavy trucks on highways would be only
2% higher because of the less congested conditions (U.S. Department of Energy 2015). Non-highway
emissions in 2027 would be slightly higher under the Build Alternative than the No Build Alternative
primarily because of the higher VMT for passenger vehicles on these roads.
Table 3-20. 2027 Benzene Emission Details (tons)

2027 No 2027 No
Build Build Non- 2027 No 2027 Build 2027 Build 2027 Build
Vehicle Type Highway Highway Build Total Highway Non-Highway Total
Passenger 0.460 0.454 0.914 0.318 0.514 0.832
Medium 0.029 0.014 0.043 0.025 0.013 0.038
Heavy 0.020 0.009 0.029 0.019 0.009 0.028
All 0.508 0.477 0.985 0.363 0.536 0.899
Table 3-21. 2027 Diesel Particulate Matter Emission Details (tons)

2027 No 2027 No
Vehicle Build Build Non- 2027 No 2027 Build 2027 Build 2027 Build
Type Highway Highway Build Total Highway Non-Highway Total
Passenger 0.24 0.23 0.46 0.16 0.26 0.42
Medium 0.11 0.05 0.16 0.10 0.05 0.15
Heavy 1.02 0.44 1.46 1.04 0.41 1.46
All 1.37 0.71 2.08 1.31 0.72 2.03
There may be localized areas where ambient concentrations of MSAT could be different under the Build
Alternative compared to the No Build Alternative. The localized changes in MSAT concentrations would
likely be most pronounced on roadways where traffic volumes would be higher under the Build Alternative
relative to the No Build Alternative due to rerouted trips. However, the magnitude and the duration of
these potential increases compared to the No Build Alternative cannot be reliably quantified due to
incomplete or unavailable information in forecasting project-specific MSAT concentrations and related
health impacts.
Modeled criteria pollutant emissions would also be 0.3% to 7% lower under the Build Alternative
compared to the No Build Alternative in 2027 and 0.3% to 12% lower in 2045, as shown in Table 3-22.
Appendix D1 provides detailed emissions estimates for criteria pollutants by season. Localized increases
in air pollutant emissions can occur where traffic volumes increase or where vehicles spend more time
idling at signalized intersections. Increased delay or degraded LOS at an intersection may cause elevated
air pollutant concentrations in these vicinities; however, localized pollutant concentrations were not
modeled because it is not required for projects located in attainment areas and because it is unlikely that
emissions from an individual project would exceed the NAAQs.

I-205 Toll Project
Table 3-22. Annual Modeled Criteria Pollutant Emissions

2027 2045
No Build Build No Build
Alternative Alternative Percent Alternative Build Percent
(tons per (tons per Change from (tons per Alternative Change from
Pollutant year) year) No Build year) (tons per year) No Build
Carbon
Monoxide (CO) 11,120 10,988 -1% 7,150 7,082 -1%
Oxides of
Nitrogen (NOx) 966 956 -1% 813 786 -3%
Sulfur Dioxide
(SO2) 4 4 -5% 4 4 -4%
Volatile Organic
Compounds
(VOC) 2,243 2,237 -0.3% 1,594 1,589 -0.3%
Total PM10[1] 94 88 -7% 98 86 -12%
Total PM2.5[2] 48 47 -2% 37 36 -4%
Source: Appendix D1, I-205 Toll Project Criteria Pollutant Emissions Memorandum
[1] Total PM10 emissions are the sum of PM10 exhaust, PM10 brakewear, and PM10 tirewear
[2] Total PM2.5 emissions are the sum of PM2.5 exhaust, PM2.5 brakewear, and PM2.5 tirewear
PM2.5 = particulate matter 2.5 microns or less in size; PM10 = particulate matter 10 microns or less in size

Table 3-23 provides a comparison of anticipated air quality impacts and benefits by alternative.
Table 3-23. Summary of Air Quality Effects by Alternative

Short-Term Effects • None • Short-term impacts from higher levels of
fugitive dust and exhaust emissions during
construction.
Long-Term Effects • None • 2027: Net MSAT emissions would range
from 3% to 9% lower than the No Build
Alternative. Highway emissions would range
Alternative, and non-highway emissions
would range from 1% to 13% higher than the
No Build Alternative. Estimated modeled
criteria pollutant emissions would be 0.3% to
7% lower than the No Build Alternative.
• 2045: Net MSAT emissions would range
Alternative. Highway emissions would range
Alternative, and non-highway emissions
would be up to 8% higher than the No Build
Alternative. Estimated modeled criteria
pollutant emissions would be 0.3% to 12%
lower than the No Build Alternative.
MSAT = mobile source air toxic

I-205 Toll Project

Construction contractors would be required to comply with federal, state, and local regulations and
implement best management practices (BMPs) to manage and reduce vehicle emissions and fugitive
dust. No additional mitigation for construction is required. To reduce the impact of construction delays on
traffic flow and resultant emissions, road or lane closures will be restricted to non-peak traffic periods
when possible.
Estimated air pollutant concentrations from the Build Alternative would not have an adverse effect on air
quality and are projected to be lower than the No Build Alternative; therefore, no mitigation is proposed for
long-term Project operations.
3.3 Climate Change

Global climate change is the observed century-scale rise in the average temperature of the Earth’s
climate system and its related effects, including rising sea levels, drought, changes in local weather
patterns, and increased extreme storm events. In the Pacific Northwest, climate change has adverse
effects on the economy, including industries such as recreation and agriculture, and natural resources.
Extreme weather events can lead to flooding, landslides, drought, and wildfire, all of which can have a
negative effect on air quality, water, transportation, and energy infrastructure (May et al. 2018).
Greenhouse gases (GHG) absorb heat near the earth’s surface and trap that heat in the atmosphere,
increasing global temperatures. GHG emissions from human activity such as the burning of fossil fuels,
which increases the concentration of atmospheric carbon dioxide (CO2), are a primary cause of climate
change.
Vehicles that run on fossil fuels emit a variety of gases during their operation, some of which are GHGs.
The GHGs associated with transportation are CO2, methane, and nitrous oxide, and they are often
reported as carbon dioxide equivalent (CO2e). CO2e is a unit that provides a common scale for measuring
the climate effects of different gases based on their global warming potential. The most recent Oregon
Global Warming Commission report indicates that transportation (including highway, rail, and air
transport) is the greatest contributor to GHG emissions in Oregon, followed by the residential and
commercial sectors (Oregon Global Warming Commission 2020).
Efforts to combat climate change typically occur programmatically at national, state, or regional levels.
These efforts include policies, plans, and mandates designed to help reduce GHG emissions. Although
climate change is a global issue being addressed at the regional, state, and national levels, analysts used
the same API as the air quality analysis, shown in Section 3.2, to evaluate GHG emissions associated
with the alternatives. Chapter 4 of Appendix E, I-205 Toll Project Energy and Greenhouse Gas Technical
Report, provides more detailed information about the API and methodology for this analysis.

There is no recognized scientific methodology for attributing specific climatological changes to the
emissions resulting from a particular transportation project. This analysis therefore measures potential
climate change effects in terms of potential changes in GHG emissions between existing conditions and
the No Build and Build Alternatives.

I-205 Toll Project
Energy consumption and GHG emissions were estimated for maintenance of the existing roadway (No
Build Alternative) and construction and maintenance of the Build Alternative using the FHWA
Infrastructure Carbon Estimator.29 Table 3-24 shows the yearly energy use and GHG emissions
associated with maintenance of the No Build Alternative. Maintenance calculations include the exhaust
and energy from vehicles performing routine maintenance activities such as sweeping, striping,
landscaping, and litter pickup, as well as periodic rehabilitation and resurfacing.
Table 3-24. No Build Alternative Annualized Maintenance Energy Use and GHG Emissions
GHG Emissions (MT
Energy Source Energy Use (mmBtu/year) CO2e/year)
Direct Energy
• Maintenance 2,391 233
Source: Appendix E, I-205 Toll Project Energy and Greenhouse Gas Technical Report (Section 6.2.1)
mmBtu = million British thermal units; MTCO2e = metric tons carbon dioxide equivalent
Table 3-25 presents emissions, reported as CO2e, for the No Build Alternative in 2027 and 2045, existing
(2015) conditions, 30 and annual VMT for context. Overall, future CO2e emissions would be lower than
existing emissions, but the emissions in 2045 would be higher than 2027 levels because by 2045, the
impacts on emissions from higher VMT would surpass the projected fuel economy benefits expected from
stricter vehicle standards.
Table 3-25. No Build Alternative CO2e Emissions

Parameter Existing (2015) 2027 No Build 2045 No Build
Annual VMT 893,462,632 1,051,694,624 1,222,083,927
Direct Tailpipe CO2e emissions (MT) 393,312 348,397 364,684
Indirect Fuel Cycle CO2e emissions (MT)[1] 106,194 94,067 98,465
Total CO2e emissions (MT) 499,506 442,464 463,149
[1] Indirect fuel cycle emissions refers to emissions released during fuel extraction, refining, and transport prior to use
by vehicles.
CO2e = carbon dioxide equivalent; MT = metric tons; VMT = vehicle miles traveled
Build Alternative
Short-Term Effects
Table 3-26 shows the annualized energy and GHG emissions estimates during construction of the Build
Alternative.
29
FHWA’s Infrastructure Carbon Estimator is a tool that estimates the lifecycle energy and GHG emissions from the
construction and maintenance of transportation facilities based on details about the project type and size. The tool
provides a planning-level analysis based on a nationwide database of construction bid documents, data collected
from state departments of transportation, and consultation with transportation engineers and lifecycle analysis
experts (FHWA 2022).
30
2015 was used for existing conditions because it is the base year for the version of the Portland Metro regional
travel demand model that was used for the analysis, and a more current base year was not available.

I-205 Toll Project
Table 3-26. Build Alternative Annualized Construction Energy Use and GHG Emissions
Energy Use GHG Emissions
Energy Source (mmBtu/year) (MT CO2e/year)
Upstream Energy
• Materials 1,479 168
Direct Energy
• Construction equipment 907 89
• Transportation 180 18
• Construction impacts on vehicle delay 13,916 1,062
Total 16,482 1,337
mmBtu = million British thermal units; MT CO2e = metric tons carbon dioxide equivalent
Long-Term Effects
Table 3-27 shows the annualized energy use and GHG emissions estimates for long-term maintenance of
the Build Alternative. The maintenance impacts from the Build Alternative would be higher than the No
Build Alternative due to the additional lane miles that must be maintained.
Table 3-27. Build Alternative Annualized Maintenance Energy Use and GHG Emissions
Energy Use
Energy Source (mmBtu/year) GHG Emissions (MT CO2e/year)
Direct Energy
• Maintenance 3,834 374
mmBtu = million British thermal units; MT CO2e = metric tons carbon dioxide equivalent
Table 3-28 compares CO2e emissions for the Build Alternative to the No Build Alternative in 2027 and
2045. Under the Build Alternative, CO2e emissions would be approximately 6% lower in 2027 and 4%
lower in 2045 compared to the No Build Alternative. These differences are consistent with the projected
differences in VMT for each analysis year.

I-205 Toll Project
Table 3-28. Build Alternative CO2e Emissions

Percent
Percent Difference
Difference 2045 No
2027 2027 No Build to 2045 Build to
Parameter 2027 No Build Build Build 2045 No Build Build Build
Annual VMT 1,051,694,624 965,576,193 -8% 1,222,083,927 1,162,440,219 -5%
Direct 348,397 326,604 -6% 364,684 349,473 -4%
Tailpipe CO2e
emissions
(MT)
Indirect Fuel 94,067 88,183 -6% 98,465 94,358 -4%
Cycle CO2e
emissions
(MT)
Total CO2e 442,464 414,787 -6% 463,149 443,831 -4%
emissions
(MT)
Notes: CO2e = carbon dioxide equivalent; MT = metric tons; VMT = vehicle miles traveled
Vehicles typically run less efficiently on non-highway roads because travel on those roadways involves
slower speeds and more stop-and-go activity. Therefore, trips rerouted from highway to non-highway
roads could lead to higher GHG emissions. Section 3.2.2 summarizes the differences in projected VMT
for passenger, medium, and heavy vehicles in the API. Although there would be higher non-highway VMT
under the Build Alternative, this higher VMT would be more than offset by lower highway VMT. In
addition, the higher non-highway VMT would be primarily from passenger vehicles. Non-highway VMT
from heavy trucks, which emit GHG at a higher rate, would be lower under the Build Alternative.
Overall, the Build Alternative would have net lower GHG emissions and VMT, which would contribute to
ODOT’s efforts to reduce GHG emissions and meet climate change goals, consistent with the Oregon
Statewide Transportation Strategy (ODOT 2013b) and ODOT’s Climate Action Plan (ODOT 2021d). The
lower predicted emissions can be attributed to lower congestion levels on I-205.

implement BMPs to reduce energy consumption and GHG emissions. No additional mitigation related to
climate change is proposed for short-term effects. GHG emissions from the Build Alternative would be
lower than from the No Build Alternative; therefore, no mitigation related to climate change is proposed for
long-term operations effects.

I-205 Toll Project
3.4 Economics
The economics API includes roadways forecasted to experience differences in traffic volumes of plus or
minus 5% or greater between the No Build and Build Alternatives, as shown on Figure 3-10. Analysts
evaluated some economic effects at larger regional levels and calculated others based on all users of the
Project, regardless of geography. Chapter 4 of Appendix F, I-205 Toll Project Economics Technical
Report, provides a more detailed description of the API and methodology used for the analysis.
Employment
From 2012 to 2018, 31 the API experienced a faster annual rate of employment growth (3.10%) than the
Portland-Vancouver-Hillsboro metropolitan statistical area (Portland MSA) (2.77%) and the state (2.64%)
(U.S. Bureau of Labor Statistics 2021). Manufacturing, health care and social assistance, and retail trade
were the three largest industry sectors in the API for total employment in 2018. Across the state, in the
Portland MSA, and in the API, the construction industry sector had the highest percentage growth rate
between 2012 and 2018.
Since early 2020, economic shutdowns related to the COVID-19 pandemic public health mandates have
affected employment growth in some state and regional industries. As of 2021, employment levels in the
manufacturing, leisure and hospitality, educational services, government services, and retail trade sectors
remained below pre-pandemic levels. The transportation and warehousing, professional services, and
construction sectors have recovered to equal or surpass pre-pandemic employment levels.
Households
From 2012 to 2018, annual growth in the number of households in the API (1.12%) slightly outpaced that
of the Portland MSA (1.06%) (U.S. Census Bureau n.d.-a). Both the API and Portland MSA showed a
higher rate of growth in the number of households than the state as a whole (0.75%). Median household
income within the API ($81,875) was higher than the Portland MSA ($70,724) and state ($59,393) in
2018. Annual median household income growth in the API was the same as the Portland MSA, with an
annualized growth rate of 2.9% from 2012 to 2018 (U.S. Census Bureau n.d.-b). For the median
household in the API, transportation costs made up 7.9% of the total household budget (approximately
$7,000 per year) in 2021. Transportation costs include vehicle ownership costs (68%) and vehicle
operating costs (32%).
31
Employment data for the state of Oregon and the Portland MSA is from the U.S. Bureau of Labor Statistics. Data
for the customized API boundary was generated from the U.S. Census Bureau’s Longitudinal Employer-
Household Dynamics data, which is available through 2018.

I-205 Toll Project
Figure 3-10. Economics Area of Potential Impact

I-205 Toll Project
Truck Freight
Truck freight movement depends on a well-functioning roadway network with consistent reliability
throughout the day, and good connectivity between producers and markets. As delays in the
transportation of goods accumulate in the supply chain, a cascade of additional costs affects the abilities
of producers, suppliers, and retailers to operate cost-effectively and on schedule. For businesses in the
supply chain affected by the reliability of truck service on I-205 in the API, existing traffic delays and other
trip disruptions exert a cost on the transportation of goods. The value of time for truck freight
transportation is estimated at $160 per hour (Guerrero et al. 2019).
The Portland MSA experienced steady growth in the general freight trucking sector and very strong
growth in the warehousing sector between 2012 and 2020 (U.S. Bureau of Labor Statistics 2021). Growth
in the warehousing sector has resulted from the steady increase in e-commerce activity over the last
decade, with an additional increase during the COVID-19 pandemic.
Local Traffic-Dependent Businesses

Analysts identified three commercial areas within the API that may be sensitive to changes in traffic
volumes: OR 99E in Canby, Main Street in Oregon City, and Willamette Falls Drive in West Linn. A
business’s sensitivity to differences in traffic volumes can depend on whether the business is destination
oriented (establishments to which consumers plan to travel in advance) or traffic-exposure oriented
(establishments to which consumers do not plan to travel in advance; also known as “opportunity” trips). In
the API, community or regional businesses, such as large grocery and “big box” stores, shopping centers,
banks, and other professional services, serve the highest share of destination-oriented trips, whereas small
specialty goods stores (such as hardware and sporting goods), gas stations, convenience grocery stores,
fast food restaurants, and auto dealerships serve the largest percentage of opportunity trips.

This section addresses the short-term, long-term, and indirect economic effects of the No Build and Build
Alternatives on local businesses, residents, and truck freight transport. Short-term effects, applicable only
to the Build Alternative, comprise the regional economic effect of construction and other capital activities
related to the implementation of the Project. Long-term effects comprise the differences in user and social
effects between the No Build Alternative and the Build Alternative. Indirect effects comprise the economic
effect of changes in household spending on transportation costs under the Build Alternative compared to
the No Build Alternative and public investment related to the Project.
Long-Term Effects
The No Build Alternative would result in increasingly longer travel times and increased congestion for
travelers on this segment of I-205 compared with current conditions (see Section 3.1.2). Over time,
projected increases in vehicle trips, traffic congestion, and deteriorating system performance would
accrue as additional costs, including longer travel times, additional vehicle operating and maintenance
costs and vehicle emissions, lower truck travel-time reliability, and increases in crashes between roadway
vehicles. Figure 3-11 illustrates the monetized value of these impacts related to the No Build Alternative
from 2027 to 2045. The graph shows the current conditions in the API as the baseline for comparison to
the No Build Alternative.

I-205 Toll Project
Figure 3-11. Monetized Value of the Effects of Increasing Traffic Volumes over Time, Comparing
the No Build Alternative to Current Conditions (in discounted millions 2021$)
Source: Appendix F, I-205 Toll Project Economics Technical Report (Section 6.1.2)
Note: Discounted rates allows for comparison of today’s valuation of a dollar to a future dollar valuation.
To maintain consistency of the output values with the input values and standardized factors and to
account for the value of money over time, the future values are discounted at an annual rate of 7%32 and
reported in constant 2021 dollars. Discounting future values allows for comparison to today’s valuation of
a dollar and accounts for unknown future risks, including variability in the value of money and the
forecasted operational conditions. Effectively, the discounted rate illustrates a conservative evaluation of
future effects. The average annualized value of the costs incurred by users between 2027 and 2045
would be about $468.1 million in current 2021 dollars (or $143.7 million in discounted 2021 dollars).
Under the No Build Alternative, I-205 in the API would be maintained by the dedicated Highway Trust
Fund; 33 therefore, the value of direct transportation costs to households within the API or wholesale retail
businesses in the region would not change. Without tolls, transportation costs as a percentage of
household income (7.9%) would remain the same under the No Build Alternative as under existing
conditions.
32
ODOT uses a standard annual discount rate of 7% for all economic analyses, which is also consistent with
USDOT discounting guidelines.
33
The Highway Trust Fund finances most federal government spending for highways. Revenues for the trust fund
come from transportation-related excise taxes, primarily federal taxes on gasoline and diesel fuel (Tax Policy
Center 2020).

I-205 Toll Project
Indirect Effects
The costs of truck freight transportation would increase because of the projected increase in traffic
congestion on I-205 in the API. Traffic delays would result in an average of $9.4 million (in 2021 dollars;
$3.7 million in discounted 2021 dollars) in higher costs per year for the retailers, vendors, and suppliers in
the supply chain, compared to the Build Alternative. Because businesses typically pass on transportation
costs to consumers, those changes in traffic conditions could manifest as higher per-unit costs and lower
total retail revenues on goods transported through I-205 in the API, if the increased cost results in
reduced demand.
Build Alternative
Short-Term Effects
Project construction would generate short term economic benefits in the Portland MSA through the
purchase of supplies and materials, and through employment of construction workers. Table 3-29 shows
the economic effects of construction activities for the Build Alternative related to employment, labor
income, and economic output (total value of goods and services). These economic benefits are classified
into direct effects (industry spending on labor and materials), indirect effects (household spending on
consumer goods), and induced effects (the increased personal income in the regional economy resulting
from the direct and indirect effects).
Table 3-29. Total Economic Effects Related to Toll System Construction (2024-2027)
Effect Categories Employment (Job-Years)[1] Labor Income (2021$) Economic Output (2021$)
Direct Effects 1,044 $285,281,000 $750,000,000
Indirect Effects 4,050 $93,427,000 $307,151,000
Induced Effects 2,890 $129,990,000 $433,613,000
Total Effects 7,985 $508,699,000 $1,490,764,000
[1] Job-years refers to the equivalent of an employee working full-time for 2,080 hours in a year. For example, a full-
time employee working for 3 years would be equal to three job-years, while three part-time employees working a total
of 2,080 hours in a year would be equivalent to one job-year.
Long-Term Effects
Changes in regional travel behavior under the Build Alternative (see Section 3.1.2) would result in user
and social benefits, including reduced emissions, shorter travel times, improved truck on-time reliability,
vehicle operating cost savings, fewer crashes, and prevention of pavement damage. Figure 3-12
illustrates the monetized value of the effects of traffic over time under the Build Alternative from 2027 to
2045 as compared to the No Build Alternative, with the current conditions in the API serving as the
baseline. The average annualized value of the benefits incurred by users between 2027 and 2045 would
be about $104.9 million in current 2021 dollars (or $41.2 million in discounted 2021 dollars).

I-205 Toll Project
Figure 3-12. Monetized Value of the Effects of Increasing Traffic Volumes over Time, Comparing
the Build Alternative to the No Build Alternative and Current Conditions (in
discounted millions 2021$)
Under the Build Alternative, there would be higher levels of opportunity (traffic exposure-oriented)
consumer spending in three commercial districts because of projected higher traffic volumes compared to
the No Build Alternative: OR 99E in Canby, Main Street in Oregon City, and Willamette Falls Drive in
West Linn. This additional consumer spending would translate into increased employment, labor income,
and economic output in these areas under the Build Alternative compared to the No Build Alternative, as
shown in Table 3-30.
Table 3-30. Annualized Economic Benefits Related to Consumer Spending under the Build
Alternative Relative to No Build Alternative (2027 to 2045)
Effect Category Employment (Job-Years) Labor Income (2021$) Economic Output (2021$)
Direct Effects 2.0 $57,000 $157,000
Indirect Effects 0.4 $23,000 $73,000
Induced Effects 0.6 $28,000 $84,000
Total Effects 3.0 $108,000 $313,000
Table 3-31 shows the effects of the additional toll payments on household costs in the API, based on the
average number of weekday vehicle-trips per household on I-205 and average cost of toll payments. The
calculated average annual toll payment is based on numerous variables, including the average weekday
vehicle-trips per household, distribution of trips on I-205 and alternative routes, forecasted traffic on I-205 by
vehicle class, projected gross toll revenues by vehicle class, and projected regional cost inflation. As a
result, it should not be considered demonstrative of the actual toll payments in any particular year but rather
an average converted to current-year dollars to allow for comparison to current median household spending.

I-205 Toll Project
Table 3-31. Household Effects Related to Toll Revenue Operations

Metric Values
Households in API with One or More Vehicles 113,140
Average Total Annual Weekday Vehicle-Trips per Household in API 1,285
Average Annual Weekday Vehicle-Trips on I-205 per Household in API 206
Estimated Average Annual Weekday Toll Fees per Household in Opening Year (in 2021 dollars)* $575
* The projected toll revenues include assumptions about population growth and other factors related to the forecasted
traffic conditions, developed as part of the Project’s toll revenue forecast. The values are in constant 2021 dollars
based on the forecasted toll rate for the project opening in 2027.
API = area of potential impact
Table 3-32 shows the estimated change in annual transportation costs for the average household in the
API under the No Build Alternative and the Build Alternative. Transportation costs as a percentage of the
total budget for households at the median income level would be 7.9% under the No Build Alternative
compared to 8.6% under the Build Alternative. This 0.7 percentage point difference represents
approximately 9% higher transportation costs for a median household in the API under the Build
Alternative compared to the No Build Alternative.
Table 3-32. Comparison of Median Household Budget and Transportation Costs in the Area of
Potential Impact under the No Build Alternative and Build Alternative (in 2021$,
rounded)
Transportation
Average Annual Total Annual Costs as
Median Household Household Percentage of
Household Transportation Average Annual Transportation Total Household
Alternative Budget in API Costs Toll Payments Costs Budget
No Build $88,400 $7,000 — $7,000 7.9%
Alternative
Build $88,400 $7,000 $600 $7,600 8.6%
Alternative
Note: Total annual household transportation costs and average annual toll payments shown in the table may be
affected by rounding.
Indirect Effects
Table 3-33 shows estimated changes in spending related to toll operations under the Build Alternative by
ODOT, households, and wholesale traders between 2027 and 2045. The ODOT spending category shows
estimated expenditures of toll revenues related to government administration, construction, and professional
services. The household spending category indicates that because regional households would spend an
additional portion of their transportation budget on toll payments, they would in turn reduce their spending in
other categories, such as retail, entertainment and recreation, and restaurants and food services. The
wholesale trade spending category indicates that the industry would experience a reduction in revenues
because commercial vehicles would pass on the cost of tolls to these wholesale traders.

I-205 Toll Project
Table 3-33. Change in Estimated Annualized Spending by Industry (2027 to 2045)

Gross Toll Revenues Toll Payments[1]
Source of Spending (millions 2021$) (millions 2021$)
Total ODOT Spending $131.7 —
ODOT Government Enterprises[2] $26.3 —
ODOT Road and Bridge Construction $92.2 —
ODOT Professional Services $13.2 —
Total Household Spending — ($93.2)
Household Retail Purchases — ($32.6)
Household Entertainment and Recreation — ($18.6)
Household Restaurant and Food Services — ($41.9)
Total Wholesale Trade Spending — ($38.5)
Annual Net Change in Spending $131.7 ($131.7)
[1] The estimated toll payments by households and the wholesale trade sector are based on the forecasted toll rates
for the multiple vehicle classes and forecasted traffic volumes. They are an annualized estimate used for the
purposes of the analysis to evaluate the transfer of payments from the toll payees to ODOT and are not indicative of
future revenues or toll rates in any particular year.
[2] “Government Enterprises” are defined by the Bureau of Economic Analysis as the government agencies
responsible for administering, overseeing, and managing public programs within a given area; the RIMS II multipliers
evaluate the regional spending patterns related the performance of these activities. The classification is equivalent to
Sector 92 Public Administration under the 2017 North American Industry Classification System.
ODOT = Oregon Department of Transportation
ODOT’s collection of toll revenue from households and truck freight operators and subsequent investment
of this revenue into the transportation network represents a shift in economic activity. Table 3-34
summarizes the changes in public and private spending as reflected in employment, labor income, and
total economic output in the Portland MSA. The total net change in economic output and labor income
would be minimal. There would be a negative effect on job-years supported, largely because of projected
lower household spending in the retail, entertainment, and food services sectors and higher expenditures
in the transportation and professional services sectors. The values for households and wholesale trade
represent only the effect of the increased costs in transportation: they do not include the improvements in
I-205 traffic performance that are expected to increase the value for users and the region. Additionally,
while the employment effects on the wholesale retail sector would be distributed beyond the region,
decreased congestion and improved on-time reliability are expected to increase demand in the
warehousing and wholesale trade sectors, benefiting businesses throughout the supply chain.
Table 3-34. Summary of Annualized Economic Effects related to Toll Revenue Operations
(2027 to 2045)
Employment Labor Income Economic Output
Effect Category (Job-Years) (millions 2021$) (millions 2021$)
ODOT Investment of Revenue 1,249 $75.5 $262.9
Household Spending -1,699 -$59.1 -$190.1
Wholesale Trade Spending -313 -$29.6 -$70.3
Annual Net Change -763 -$3.2 $2.4
Note: The change in employment assumes a linear change in employment in the industries supported by
household spending (Retail, Entertainment and Food Services). These impacts are spread across the API
and, therefore, represent the aggregated total job-years, not individual FTEs, and their related labor income.
FTE = full-time equivalent; ODOT = Oregon Department of Transportation

I-205 Toll Project

Table 3-35 provides a comparison of anticipated positive and negative economic effects by alternative.
Under the No Build Alternative, the values represent the baseline conditions in the future without the
implementation of the Project. Under the Build Alternative, the values represent the differences resulting
from the implementation of the Project relative to the No Build Alternative.
Table 3-35. Summary of Economics Effects by Alternative

Effects No Build Alternative Build Alternative[1]
Short-Term Effects None Toll System Implementation Economic
Benefits
• Total employment: 7,985 job-years
• Total labor income: $508.7 million
• Total economic output: $1,490.8 million
Long-Term Effects Traffic Impacts on Users and Society Toll Operations Economic Benefits on Users
• Annual undiscounted net costs: and Society
$468.1 million • Annual undiscounted net benefits:
• Annual discounted net costs: $104.9 million
$143.7 million • Annual discounted net benefits: $41.2 million
Truck Freight Impacts Consumer Spending Economic Benefits
• Annual undiscounted additional costs • Annual employment change: 3 job-years
for less reliable truck freight service: • Annual labor income: $0.1 million
$9.4 million
• Annual economic output: $0.3 million
• Annual discounted additional costs for
Truck Freight Benefits from Toll Operations
less reliable truck freight service:
• Annual undiscounted additional cost savings
$3.7 million
for more reliable truck freight service:
Household Impacts $9.9 million
• No change in transportation costs as
• Annual discounted additional cost savings
a percentage of median household
for more reliable truck freight service:
income under the No Build Alternative
$3.9 million
compared to existing conditions
Household Impacts from Toll Operations
• Additional average (rounded) annual
spending on transportation costs: $600
• Change in transportation costs as a
percentage of median household income (as
of 2018): 0.7% higher
• Percent change in annual median household
transportation costs: About 9% higher
Indirect Effects None Toll Revenue Operations Economic Benefits
• Annual employment: (763 job-years)
• Annual labor income: ($3.2 million)
• Annual economic output: $2.4 million
[1] All dollar values are in 2021 dollars and discounted where noted.

With the mitigation measures proposed in Sections 3.1.4 (Transportation), 3.7.4 (Social Resources and
Communities), and 3.8.4 (Environmental Justice) of the Environmental Assessment relating to
transportation access and household costs, no additional mitigation measures for economics are
warranted.

I-205 Toll Project
3.5 Noise
The Project meets the definition of a Type I project as established in 23 CFR 772 and defined in the
ODOT Noise Manual (ODOT 2011) because Project improvements include the construction of new
through lanes. Therefore, the Project is required to analyze traffic noise and any associated effects along
I-205, as well as noise abatement measures to address impacts.
The noise API includes the I-205 right-of-way and a 500-foot buffer from the right-of-way between the
SW Stafford Road and OR 213 interchanges to account for any noise impacts that would occur from
Project improvements. In addition, the noise API includes non-highway roads that would receive rerouted
traffic under the Build Alternative. In accordance with 23 CFR 772, the Type I noise analysis and potential
noise abatement only apply to improvements along I-205 and the associated noise impacts on adjacent
land uses and not the roadways expected to experience rerouting because of the Project. Figure 3-13
shows the API and its zoning, which is generally reflective of existing land uses. Existing land uses in the
API consist primarily of single- and multifamily residences and community and recreational facilities
(including one park, one school, and one church/preschool/daycare facility), as well as one hotel and one
retirement home. Land uses such as residences and community facilities are considered noise
sensitive. 34 Chapter 4 of Appendix G, I-205 Toll Project Noise Technical Report, provides a more detailed
description of the API and methodology used for the analysis.
Figure 3-13. Noise Area of Potential Impact
Source: Metro Regional Land Information System
34
Properties where frequent exterior human use occurs and where a lowered noise level would be beneficial are
noise-sensitive land uses (FHWA 2006).

I-205 Toll Project
Existing (2017) peak truck hour traffic data was used to model the loudest-hour noise levels at all noise-
sensitive land uses adjacent to I-205 in the noise API. Existing traffic noise levels range from 44 A-
weighted decibels equivalent sound level (dBA Leq) 35 to 74 dBA Leq. The highest traffic noise levels occur
at outdoor land uses located closest to I-205.

To predict future noise levels under the No Build Alternative and Build Alternative, analysts used noise
models developed for the 2018 Categorical Exclusion for the I-205 Improvements Project and 2045 traffic
volumes, speeds, and vehicle mix presented in Appendix C, I-205 Toll Project Transportation Technical
Report. Chapter 6 of Appendix G, I-205 Toll Project Noise Technical Report, provides more detailed
analysis about projected future noise levels under the alternatives.
Under the No Build Alternative in 2045, predicted traffic noise levels would range from 44 dBA Leq to
74 dBA Leq. When compared to existing conditions, changes in noise levels would range from a decrease
of 6 dBA Leq to an increase of 4 dBA Leq36 depending on location. The increases generally would occur
because of higher projected traffic volumes near those locations. The decreases would occur because of
a new noise wall constructed as part of the I-205: Phase 1A Project.
Along non-highway roads in the noise API, changes in traffic noise levels would range from a decrease of
2 dBA to an increase of 5 dBA relative to existing noise levels. At most locations, the difference in noise
levels would range from no change to an increase of 2 dB relative to existing conditions. The largest
reduction in No Build Alternative noise levels (2 dBA decrease) would occur along the segment of SW
Borland Road north of the I-205 Tualatin River Bridges, and the largest increase (5 dbA) would occur
along the segment of SW Borland Road north of Ek Road because of projected differences in traffic
volumes on these segments.
Build Alternative
Short-Term Effects
Construction activities such as clearing vegetation, grading, paving, pile driving, bridge reconstruction,
excavation, rock blasting, and setting toll gantry foundations would generate noise during the
approximately 4-year construction period. Construction of the Project may result in elevated noise levels
at noise-sensitive land uses such as residences or schools that are adjacent to the right-of-way.
Construction noise levels would depend on the type, amount, and location of these activities.
Approximately 15 to 20 days of rock blasting on northbound I-205 between Sunset Avenue and West A
Street in West Linn is anticipated to occur during summer and fall of the first year of construction and
would be scheduled during daytime hours.
Maximum noise levels from construction equipment would range from 69 dBA to 105 dBA at 50 feet.
However, because various pieces of equipment would be turned off, idling, or operating at less than full
power at any time, and because construction machinery is typically used to complete short-term tasks at
any given location, average noise levels during the day would be less than those maximum noise levels.
35
dBA is an expression of the loudness of sounds in an environment as perceived by the human ear. When a noise
varies over time, the Leq is the average sound level over a period of measurement.
36
The human ear can barely perceive a 3-dBA increase, while a 5-dBA or 6-dBA increase is readily noticeable and
perceived by as if the noise were about 1.5 times as loud. A 10-dBA increase appears to be a doubling in noise
level to most listeners.

I-205 Toll Project
Construction noise at locations farther away would decrease at a rate of 6 dBA per doubling of distance
from the source.
To avoid and minimize noise impacts during construction of the Project, the construction contractor would
be required to comply with local noise ordinances, ORS Chapter 467, OAR Chapter 340 - Division 035,
and Oregon Standard Specifications for Construction (ODOT 2021c) for noise control (Section 290.32). In
addition, construction equipment would comply with pertinent equipment noise standards of the U.S.
Environmental Protection Agency. A blasting plan for the rock blasting would be implemented to limit the
timing, sequence, and force of each blast.
Long-Term Effects
According to the ODOT Noise Manual, a noise impact occurs when the future noise level for a project
results in any exceedance of ODOT’s Noise Abatement Approach Criteria (NAAC) at a noise-sensitive
land use (e.g., residences, parks, schools) or results in a substantial increase37 in noise levels over
existing noise levels (ODOT 2011). Exceedances of the ODOT NAAC or substantial increases in noise
levels are evaluated for noise abatement.
Predicted traffic noise levels under the Build Alternative in 2045 would range from 44 dBA Leq to 75 dBA
Leq and would exceed ODOT’s NAAC at various residences, an outdoor pool at an apartment building, a
church/preschool/daycare, a park, and a school; therefore, noise abatement must be considered with the
Project (see Section 3.5.3).
Under the Build Alternative in 2045, no roadways would experience a substantial increase in noise. Along
I-205, Build Alternative noise levels would range from 6 dBA lower to 6 dBA higher than existing noise
levels, and 3 dBA Leq lower to 5 dBA Leq higher than the No Build Alternative, depending on location.
Along non-highway roads in the API, changes in traffic noise levels under the Build Alternative would
range from 6 dBA lower to 6 dBA higher than existing noise levels because of changes in traffic volumes.
The largest reduction in noise levels would occur along the segment of Willamette Falls Drive east of 19th
Street, where traffic volumes would be lower than under the No Build Alternative, and the largest increase
would occur along the segment of SW Borland Road east of SW Stafford Road, where traffic volumes
would be higher than under the No Build Alternative. Figure 3-14 shows the estimated increases in traffic
noise levels on non-highway roads under the Build Alternative as compared to existing conditions. Most
locations would experience 0 to 3 dB higher noise levels under the Build Alternative compared to the No
Build Alternative, which would be barely perceptible to the human ear.
37
A substantial increase is defined by Oregon state regulations as an increase of 10 dBA or more (ODOT 2011).

I-205 Toll Project
Figure 3-14. Estimated Change in Future Non-Highway Traffic Noise Levels – Existing
Conditions to 2045 Build Alternative
Source: Appendix G, I-205 Toll Project Noise Technical Report (Section 6.3)

Per 23 CFR 772, noise abatement must be considered and evaluated for feasibility and reasonableness
where there would be noise impacts from a Type I project. At a minimum, ODOT is required to consider
noise abatement in the form of a noise wall. Because of the Build Alternative’s long-term noise effects,
three noise walls are recommended for consideration, as described in detail in Section 7.2 of Appendix G,
I-205 Toll Project Noise Technical Report:
• Noise Wall 2: Along the north side of southbound I-205 lanes north of Blankenship Road
• Noise Wall 3: Along the south side of northbound I-205 lanes south of where I-205 crosses
Blankenship Road
• Noise Wall 4: Along the north side of the southbound I-205 lanes south of Blankenship Road.
If conditions have changed substantially during final design of the Build Alternative, the noise walls may
no longer be feasible and reasonable and therefore would not be constructed. A final decision about the
noise walls will be made upon the completion of the Build Alternative’s final design, a cost-estimating
process, and the public involvement process.

I-205 Toll Project
3.6 Visual Quality

The study area for visual quality, called the area of visual effect, is the area that neighbors, including
people who live and/or engage in recreational activities nearby, see in the landscape looking toward
Project elements and the area that travelers see while driving past Project elements. Based on the
physical environment (landforms, land cover, atmospheric conditions) and the limits of human sight, the
Project area of visual effect is the area within 0.5 mile from the edge of the existing I-205 right-of way
between SW Stafford Road and OR 213. Chapters 3 and 4 of Appendix G, I-205 Toll Project Abbreviated
Visual Impact Assessment, provides a more detailed description of the area of visual effect and
methodology used for the analysis.
The area of visual effect is characterized by a mix of residential areas of varying density, commercial and
industrial areas, and open spaces, including the Willamette River, public parks, and river access points.
Neighbors and travelers have different viewing experiences depending on where they are in the area of
visual effect. For residential and recreational neighbors in the area, existing mature trees and vegetation
block most views of I-205. Travelers on I-205 in the area of visual effect currently view a combination of
human-made features, including numerous ramps, bridges, lighting, fencing, and signage, and more
natural elements, such as water, vegetation, rock, agricultural fields, open grass areas, and mature trees.
Within the area of visual effect, I-205 is designated as a rural scenic roadway by Clackamas County
(Clackamas County 2020). The rural scenic roadway program strives to “promote the protection of
recreation values, scenic features and an open, uncluttered character along designated scenic roads”
(Clackamas County 2020). No roadway within the area of visual effect is designated as a National or
Oregon Scenic Byway.
A scenic viewpoint is located along the south side of I-205 in West Linn near MP 7.5. The viewpoint is
accessed by an I-205 off-ramp to a road and parking area south of I-205 that serve the viewpoint. The
viewpoint looks downward at the Willamette Falls, located roughly 1/3 mile east. Vehicles traveling along
I-205 cannot see the Willamette Falls due to the angle of the slope between the roadway and the
Willamette Falls and/or the existing vegetation adjacent to the roadway.

Under the No Build Alternative, the visual environment would remain similar to existing conditions, and
the visual quality of the area of visual effect would not be affected.
Build Alternative
Effects on visual quality from the Build Alternative would be based on the viewer’s sensitivity to changes
resulting from the new project elements, including the widening of I-205 to three lanes, reconstruction
and/or removal of existing bridges, the addition of traveler information signs, and the new toll gantries and

I-205 Toll Project
supporting infrastructure. Using FHWA’s visual impact assessment guidelines, analysts categorized the
visual effects as beneficial, adverse, or neutral (FHWA 2015). 38
Short-Term Effects
Construction of the Build Alternative would change the visual landscape surrounding I-205 in the area of
visual effect because of removal of trees and vegetation and because of the presence and use of
construction vehicles and equipment, nighttime lighting, signage, and construction staging areas. These
visual elements would be present within the existing I-205 right-of-way during construction and would
change the visual environment for travelers with a view of the construction area. Detours, traffic shifts,
and roadway reconfigurations would require greater traveler attention and potentially distract from typical
views along portions of I-205 during active construction. However, remaining trees, vegetation, and/or
slope would block most views of construction activities for neighbors.
Most additional nighttime construction lighting would be considered negligible in the context of existing I-
205 lighting, except in the portions of I-205 that pass through more rural areas, such as those west of
West Linn, where existing nighttime lighting is more limited. With the implementation of measures
discussed in Section 3.6.3, short-term visual effects would be neutral for I-205 travelers and neighbors.
No effects on the scenic viewpoint would occur under the Build Alternative during construction.
Construction activities would occur north of the viewpoint; access and the parking area would be
maintained; and the view of the Willamette Falls from the viewpoint would not be altered during
construction.
Long-Term Effects
The Build Alternative would not substantially change the visual character of the area of visual effect,
which currently contains the existing highway and supporting infrastructure such as signage and lighting.
Because roadway infrastructure would be constructed with materials, forms, and colors that are similar to
existing elements within the area of visual effect, the Build Alternative would be compatible with the
existing environment for travelers along I-205. Therefore, the overall long-term visual effects would be
neutral for I-205 travelers.
Although vegetation removal to accommodate the expanded highway, toll gantries, and supporting
infrastructure would occur in the I-205 right-of-way, views of I-205 from adjacent residential and
commercial areas that are currently screened would remain screened under the Build Alternative for most
neighbors. The mitigation measures in Section 3.6.3 would help to reduce adverse effects for a small
number of residential neighbors who may see additional human-made visual elements associated with
the Build Alternative, including nighttime lighting. In general, the Build Alternative would be consistent and
compatible with the existing visual environment for most neighbors. Therefore, the overall long-term visual
effects would be neutral for I-205 neighbors.
38
Beneficial changes are where visual quality is improved by enhancing visual elements or where experiences are
improved by the creation of new or improved views of resources.
Adverse changes can result when visual quality is degraded through incompatible visual elements or by blocking
or altering views in a negative manner that can be perceived as inharmonious, disorderly, and incoherent.
Neutral changes are those that are compatible with the existing visual environment, reflecting little change, and
which neighbors perceive as harmonious, orderly, and coherent with the existing visual environment.

I-205 Toll Project
The Build Alternative would have no long-term effects on the scenic viewpoint. The widening of I-205
would occur north of the existing roadway, and the access and parking supporting the viewpoint would
remain. No changes to the view of Willamette Falls from the viewpoint would occur.
Improvements to I-205 under the Build Alternative would be developed in accordance with applicable
standards of Clackamas County’s rural scenic roadway program.

ODOT would implement the following actions to minimize impacts on visual quality during construction:
• Preserve existing vegetation where possible and minimize the clearing of mature trees.
• Direct work and safety lighting toward work areas and away from residential areas where nighttime
construction is necessary. Shield light sources to avoid light spillover.
• Screen views of construction equipment and materials from pedestrians and residential areas, as
practical.
ODOT would implement the following actions to minimize long-term impacts on visual quality:
• Design materials, colors, forms, heights, and shapes of the roadway infrastructure to blend in with the
existing human-made structures and conform to the appropriate land use designation.
• Minimize artificial lighting where practical.
• Shield and direct gantry lighting downward to minimize light spill to adjacent areas.
3.7 Social Resources and Communities

The API for social resources and communities, shown in Figure 3-15, encompasses the largest resource
API (used for the air quality and economics analyses) to assess the full range of potential effects on the
human environment. The API extends from the southern part of Portland along I-205 through Gladstone,
West Linn, and Oregon City and includes areas in Milwaukie and Happy Valley; along OR 99E through
Canby; and along I-5 near Lake Oswego, Tigard, Tualatin, and Wilsonville. Chapter 4 of Appendix I, I-205
Toll Project Social Resources and Communities Technical Report, provides more detailed information
about the API and methodology for the social resources and communities analysis.
Social Resources
Each city and some unincorporated areas in the API provide a variety of social resources, including social
services providers, public service providers (defined in this analysis as police and fire services, libraries,
museums, and community centers), religious organizations, schools, parks and recreational facilities, and
medical facilities. Chapter 5 of Appendix I, I-205 Toll Project Social Resources and Communities
Technical Report, includes more detailed descriptions and maps of social resources within the API.
Communities
Table 3-36 summarizes demographic data for the API in comparison to Clackamas County, Multnomah
County, Washington County, Marion County, the Portland MSA, and Oregon and Washington states. The
table identifies percentages of historically excluded and underserved populations, referred to in this

I-205 Toll Project
analysis as Equity Framework Communities (EFC), 39 which include adults (age 65+), children (age 18
and under), people experiencing a disability, people with limited English proficiency, and households with
no vehicle access. Although EFCs are located through the API, Figure 3-15 shows the geographic areas
in the API that have larger percentages of EFCs than their respective counties as a whole. Section 3.8
discusses a subset of EFCs called environmental justice populations, which include low-income
populations and racial and ethnic minority populations.
In general, the population in the API has similar or lower percentages of all EFCs, than the four counties,
Portland MSA, and Oregon and Washington State as a whole. Chapter 5 of Appendix I, I-205 Toll Project
Social Resources and Communities Technical Report, provides more information and maps showing
where these populations are concentrated geographically in the API.
Analysts also identified the following geographic communities in the API that could experience effects on
social resources and communities based on projections of future intersection traffic conditions, as
described in Section 3.1.2:
• Canby is a small city in Clackamas County with a land area of approximately 4 square miles and a
population of about 18,000 (U.S. Census Bureau 2021, 2022). Residential communities make up
most of the city, with a walkable downtown business district along OR 99E and a cluster of
manufacturing and industrial businesses in the southwest corner (City of Canby 2019).
• Gladstone is a small suburban city in Clackamas County with a land area of approximately 3 square
miles and a population of about 12,000 (U.S. Census Bureau 2021, 2022). Residential communities
make up most of the city, with commercial districts along McLoughlin Boulevard (OR 99E) and near
the I-205 and 82nd Drive interchange (City of Gladstone 2014).
• Lake Oswego is a small suburban city adjacent to the southwest boundary of Portland primarily in
Clackamas County (with portions extending into Multnomah and Washington Counties), with a land
area of approximately 11 square miles and a population of about 40,000 (U.S. Census Bureau 2021,
2022). Residential communities make up most of the city, with a mixed-use, walkable downtown
district featuring businesses and offices along OR 43 (City of Lake Oswego 2019).
• Oregon City is the county seat for Clackamas County with a land area of approximately 9 square
make up most of the city, with a mix of businesses, museums, government buildings, a transit center,
and social services clustered near the walkable historic downtown district along the eastern city
boundary and the Willamette River (City of Oregon City 2020).
• Tualatin is a small suburban city in Washington County with a land area of approximately 8 square
make up most of the city, with commercial areas clustered near I-5 and a large manufacturing district
on the west side (City of Tualatin 2022).
39
The Oregon Toll Program at ODOT published an Equity Framework in December 2020, which discusses
communities and populations that are currently or have historically been disproportionately affected by local
transportation projects (ODOT 2020c).

I-205 Toll Project
Figure 3-15. Social Resources and Communities Area of Potential Impact
Sources: ESRI 2018; U.S. Census Bureau 2021

I-205 Toll Project
Table 3-36. Demographic Groups in the Area of Potential Impact

Clackamas Multnomah Washington Marion Portland Washington
Population API County County County County MSA[1] Oregon State State
Total Population 344,280 410,463 804,606 589,481 339,641 2,445,761 4,129,803 7,404,107
Total Households 136,786 157,408 326,229 219,053 118,038 938,646 1,611,982 2,848,396
People Experiencing 11% 12% 12% 10% 14% 12% 14% 13%
a Disability
Older Adults (65+) 17% 18% 13% 13% 15% 15% 17% 15%
Children (18 and 21% 22% 19% 23% 25% 22% 21% 23%
under)
Limited English 2% 2% 4% 4% 5% 3% 3% 4%
Proficiency
Households with No 7% 5% 13% 6% 6% 8% 7% 7%
Vehicle Access[2]
Source: U.S. Census Bureau, American Community Survey 2015 to 2019
[1] Portland MSA refers to the Portland-Vancouver-Hillsboro, OR-WA Metropolitan Statistical Area.
[2] Percentages of Households with No Vehicle Access based on number of households.
API = area of potential impact; MSA = Metropolitan Statistical Area

I-205 Toll Project
• Unincorporated Clackamas County includes non-urban lands, with primarily residential and forested
lands in the Stafford area and agricultural and residential lands east and west of Canby on OR 99E
within the API (Clackamas County 2022a). The Stafford area of unincorporated Clackamas County is
located north of I-205 and east of West Linn. This area is a primarily residential rural community,
classified as a hamlet.
• West Linn is a small city in Clackamas County with a land area of approximately 7 square miles and a
population of about 27,000 (U.S. Census Bureau 2021, 2022). Residential communities make up
most of the city, with commercial areas clustered near the two I-205 interchanges in the city and on
OR 43 near the northern city limits, an industrial area along the Willamette River on the southern
edge of the city, and many parks throughout the city (City of West Linn 2015).

This section summarizes the effects of the No Build and Build Alternatives on social resources and
communities within the API. The effects discussions focus on elements related to projected differences in
local traffic patterns between the alternatives (access to social resources, travel time scenarios, rerouting
traffic to local streets, and roadway safety) and on elements related to tolling (cost of tolls, ability to
understand and use the electronic toll system). Chapter 4 of Appendix I, I-205 Toll Project Social
Resources and Communities Technical Report, provides more detailed information about the
methodology used to determine these effects, and Chapter 6 of Appendix I, I-205 Toll Project Social
Resources and Communities Technical Report, provides additional information about the analyses
described in this section.
Access to Social Resources
The Project Team used Metro’s regional travel demand model to determine the average number of jobs
and social resources (community places40 and medical facilities) that households would be able to access
by automobile or transit during peak hours or non-peak hours under existing conditions to allow for a
comparison to the No Build and Build Alternatives in 2045. Access is measured by calculating a regional
average number of resources that can be reached within a given travel-time from home locations in the
region and API.
When comparing the No Build Alternative to existing conditions, the model accounted for the expected
future growth in land use and transportation system investments consistent with the adopted 2018
Regional Transportation Plan. A more detailed description of the methodology and results of the
accessibility analysis is included in Attachment B of Appendix I, I-205 Toll Project Social Resources and
Communities Technical Report.
40
Community places are defined as places that provide services or items including but not limited to libraries,
grocery stores, credit unions, and medical facilities (Metro 2018c). For this analysis, medical facilities were
analyzed separately from community places.

I-205 Toll Project
Under the No Build Alternative in 2045 compared to existing conditions:

• During peak hours, all households in the API would experience access to more high-paying jobs and
access to similar or fewer low- and medium-paying jobs41 within a 30-minute drive. Compared with
the general population, EFC households would experience access to slightly fewer low- and medium-
paying jobs.
• During off-peak hours, all households, including EFC households, in the API would experience
access to more jobs of all pay levels within a 30-minute drive.
• During both peak and off-peak hours, all households, including EFC households, in the API would
experience access to fewer community places and medical facilities within a 20-minute drive.
• All households, including EFC households, in the API would experience access to more job centers,
community places, and medical facilities within a 30- or 45-minute transit trip during both peak and
off-peak hours.
Consistent with Metro’s approved long-range planning documents (i.e., Regional Transportation Plan),
the future scenario modeling assumes that regional population and employment growth would continue
over time, which would result in more jobs, community places, and medical facilities throughout the API in
2045, as detailed in Attachment B of Appendix I, I-205 Toll Project Social Resources and Communities
Technical Report. Growth in the number of jobs and community resources can improve accessibility;
however, the population and employment growth are also expected to result in higher demand for travel
across modes, which would challenge the transportation system and can result in longer delays that
would affect accessibility.
Travel-Time Scenarios
The Project Team determined the shortest travel time for 16 representative trips under existing conditions
and the No Build Alternative in 2045. Representative scenarios included trips that started in areas with
higher concentrations of EFCs and ended in areas with social resources such as parks, hospitals,
libraries, large employment centers, or retail locations in a variety of geographic areas within the API,
including Canby, Gladstone, Lake Oswego, Oregon City, Tualatin, and West Linn. Representative
scenarios do not include all possible trips that would be taken in the region but serve as a snapshot of
potential travel-time savings.
Analysts used Google Maps to identify the shortest trip path from start point (home) to end point (activity
destinations) that would include the proposed tolled bridges on I-205 (Abernethy and Tualatin River
Bridges), referred to as the Toll Path. It was assumed that the Toll Path in the No Build Alternative would
not have tolling but would involve traveling on I-205 where the tolled bridges are proposed under the Build
Alternative. Analysts also used baseline conditions from the Metro Regional Travel Demand Model to
identify the shortest path that would not include traveling on I-205 where the tolled bridges are proposed,
referred to as the Toll-Free Path. A more detailed description of the methodology and results of the
Travel-Time Analysis is included in Attachment C of Appendix I, I-205 Toll Project Social Resources and
Communities Technical Report.
41
Low-wage jobs pay between $0 and $39,999 annually, medium-wage jobs pay between $40,000 and $65,000
annually, and high-wage jobs pay over $65,000 annually (Metro 2018c).

I-205 Toll Project
Under the No Build Alternative in 2045, travel times for the general population and EFCs in the API
between their homes and the 16 representative activity locations would be similar to or longer than travel
times under existing conditions on both the Toll Path and Toll-Free Path. Similar to the Access to Social
Resources analysis, these changes would occur because of projected population and employment growth
and increased congestion on I-205 and connecting roadways in 2045 compared to existing conditions, as
described further in Section 3.1.2.
Rerouting Traffic to Local Streets

AM and PM peak-period travel times on both directions of I-205 between I-5 and 82nd Drive would be
longer under the No Build Alternative in 2045 compared to existing conditions (as discussed in Section
3.1.2), which would have impacts on access to social resources and communities for people using I-205.
As a result, local communities would continue to experience rerouting to other roadways as drivers
attempt to avoid higher congestion levels on I-205 under the No Build Alternative.
Under existing conditions, 5 intersections (in Lake Oswego, Oregon City, unincorporated Clackamas
County, and West Linn) fail to meet jurisdictional mobility standards42 for intersection performance during
the AM peak hour, and 10 intersections (in Gladstone, Oregon City, unincorporated Clackamas County,
and West Linn) fail to meet mobility standards during the PM peak hour. Most of those intersections
would continue to fail to meet local standards, and some intersections would experience worse
congestion under the No Build Alternative than existing conditions in both 2027 and 2045. This
congestion would result in continued impacts on all people traveling to nearby social resources and
communities.
Roadway Safety
The number of crashes on the portion of I-205 and local roadways studied in the API is generally
expected to be slightly higher under the No Build Alternative in 2045 compared to existing conditions
because of the anticipated higher traffic volumes. The No Build Alternative could have impacts on health
and safety for all populations related to the use of these roadways to access social resources and
communities.
Build Alternative
Short-Term Effects
Construction would require short-term lane and roadway closures on I-205 and some nearby local
roadways, typically during nighttime hours, as described in Section 3.1.2. Full roadway closures would be
scheduled during overnight periods when many social resources are closed to the public. Short-term
detours would be in place during the closures, and access to all social resources and geographic
communities, including emergency services, would be maintained. ODOT would prepare a temporary
traffic management plan to minimize construction impacts that would affect nearby social resources and
communities.
42
Mobility standards for intersections vary by jurisdiction, with most measured as volume-to-capacity ratios and
others as level of service, which are defined in Section 3.1.1.

I-205 Toll Project
Construction activities would temporarily increase noise levels and dust in and near construction areas;
however, any impacts on nearby social resources and geographic communities (such as Stafford and
West Linn) are expected to be minor because contractors would be required to comply with ODOT
regulations regarding noise and air pollution, as discussed further in Sections 3.2.2 and 3.5.2.
Because limited temporary construction easements would be required for the Build Alternative, as
described in Section 3.9.2, there would be minimal physical impacts on neighboring communities. No
relocations of businesses or residences would be required.

ODOT anticipates starting tolling on the Abernethy Bridge and possibly tolling on the Tualatin River
Bridges for 2 to 3 years (between 2024 and 2027) while completing construction of the Build Alternative,
as discussed in Section 3.1.2. Compared with the 2027 No Build Alternative, traffic volumes would
generally be higher on segments of SW Borland Road, SW Stafford Road, OR 99E, OR 213, and OR 43
if both bridges are tolled during the pre-completion period, with the largest differences expected on
SW Borland Road east of SW Stafford Road near Stafford Hamlet in unincorporated Clackamas County
and on OR 99E west of Lone Elder Road just south of Canby. These changes could affect people
traveling to social resources in these areas, which primarily include religious institutions and schools. The
area that includes the segment of 99E west of Lone Elder Road has a higher percentage of EFCs (older
adults) than Clackamas County as a whole.
Long-Term Effects
In general, households in the API would experience the same or improved access to jobs, community
places, and medical facilities, depending on the time of day and mode of travel, under the Build
Alternative compared to the No Build Alternative in 2045. In addition, EFC households would experience
slightly greater accessibility to most job types, community places, and medical resources compared with
general population households within the API and Portland MSA.
In general, these changes in accessibility under the Build Alternative would occur because of lower levels
of traffic congestion on I-205 and some neighboring roadways, as described in Section 3.1.2. The model
also accounts for regional growth in population and employment through 2045. The transportation
improvements included in the Build Alternative would enable households to access similar or greater
numbers of jobs and social resources within a given travel time during peak and off-peak hours compared
to the No Build Alternative.
A more detailed description of the methodology and results of the accessibility analysis is included in
Attachment B of Appendix I, I-205 Toll Project Social Resources and Communities Technical Report.
With the added capacity in both directions and tolling on I-205, the Build Alternative would result in faster
I-205 highway travel times in 2045 in both the AM and PM peak periods compared to the No Build
Alternative. These improved travel times could facilitate faster access to social resources and
communities for travelers using I-205 under the Build Alternative.

I-205 Toll Project
All populations, including EFCs, in the API would experience the same or shorter travel times for trips on
the Toll Path (routes that include the proposed tolled bridges on I-205) from their homes via private
vehicle or transit to 16 representative activity locations, such as parks, job sites, medical offices, and
religious organizations, under the Build Alternative as compared to the No Build Alternative in 2045.
Because there would be less congestion on I-205 and some roadways used to access I-205 under the
Build Alternative, most of the representative trips on I-205 would take similar or less time compared to the
No Build Alternative, as described in Section 3.1.2. Travelers would experience longer travel times for 3
of the 16 scenarios on the Toll-Free Path (routes that do not include the proposed tolled bridges on I-205)
under the Build Alternative compared to the No Build Alternative. Most of the scenarios focus on travel by
private vehicle, but for comparison, three scenarios were evaluated for transit travel times based on
existing fixed transit routes for the representative trip. It is assumed that the transit trips would not use the
Toll Path based on existing transit routing.
A more detailed description of the methodology and results of the Travel-Time Analysis is included in
Attachment C of Appendix I, I-205 Toll Project Social Resources and Communities Technical Report.

Under the Build Alternative in 2027 and 2045, some traffic would reroute to local streets in order to avoid
tolls, resulting in potential changes in access to nearby social resources in Canby, Gladstone, Lake
Oswego, Oregon City, Tualatin, West Linn, and unincorporated Clackamas County (near Stafford Hamlet
and Canby) during the AM and PM peak hours compared to the No Build Alternative.
Most of the 50 study intersections would meet local jurisdictional mobility standards under both the No
Build and Build Alternatives in the future, as described further in Section 3.1.2. Areas of Oregon City and
unincorporated Clackamas County near I-205 and portions of OR 99E near Canby would have the largest
numbers of intersections with worse operations under the Build Alternative as compared to the No Build
Alternative in 2027 and/or 2045. The subsections below summarize the rerouting effects on access to
social resources for each geographic community in the API, including a discussion of transit and active
transportation effects where there were differences between the alternatives. Appendix I, I-205 Toll
Project Social Resources and Communities Technical Report, provides more detailed descriptions of the
affected intersections and maps showing the locations of these affected intersections in relationship to
areas with higher concentrations of EFCs.
Canby. In central Canby, the OR 99E and Ivy Street intersection would not meet standards in both
alternatives and would have worse traffic operations under the Build Alternative than the No Build
Alternative during the PM peak hour in 2027 and 2045. Although severe congestion 43 would occur under
both alternatives at this intersection, the Build Alternative would have longer delays (by more than
2 minutes in 2027 and about 40 seconds in 2045) compared to the No Build Alternative. These longer
delays would have impacts on people and public service providers, such as emergency vehicles, traveling
to nearby social resources, which currently include retail stores and restaurants, medical clinics, parks,
religious organizations, a fire station, and schools. There are EFCs with a higher percentage of people
experiencing a disability, older adults, people with LEP, and children than in Clackamas County as whole
near this intersection.
43
The term severe congestion refers to intersections that do not meet local mobility standards and generally have
Level of Service of E or F according to the I-205 Toll Project Transportation Technical Report.

I-205 Toll Project
Gladstone. One Gladstone intersection, the OR 99E and W Arlington Street intersection, would not meet
standards under the Build Alternative and would meet standards under the No Build Alternative during the
PM peak hour in 2027. Although severe congestion would occur at this intersection under both
alternatives in 2027, the Build Alternative would have longer delays (by about 30 seconds) than the No
Build Alternative. This difference would have impacts on people traveling to nearby social resources,
which currently include religious institutions, schools, and a nursing home. A second Gladstone
intersection, the 82nd Drive and I-205 northbound ramps intersection, would not meet standards under
both alternatives in 2027 and 2045 during the PM peak hour and would have worse operations under the
Build Alternative than the No Build Alternative during the PM peak hour in 2045. Although moderate 44 to
severe congestion would occur at this intersection under both alternatives, the Build Alternative would
have longer delays (by about 40 seconds) in 2045. This difference would have impacts on people
traveling to nearby social resources, which currently include a sports club. These intersections are not
located in a geographic area with higher percentages of EFCs than Clackamas County as a whole.
Lake Oswego. One Lake Oswego intersection, OR 43 and McVey Avenue, would not meet standards in
both alternatives and would be worse under the Build Alternative than the No Build Alternative during the
AM peak hour in 2027 and 2045. A second Lake Oswego intersection, OR 43 and A Avenue, would meet
local mobility standards under the No Build Alternative but would not meet those standards under the
Build Alternative during the AM peak hour in 2027. By 2045, that intersection would not meet local
mobility standards under both alternatives and would be worse under the Build Alternative than the No
Build Alternative during the AM peak hour. Although moderate to severe congestion would occur at these
intersections under both alternatives, the Build Alternative would have longer delays (by less than 30
seconds) compared to the No Build Alternative. These differences would have an impact on people
traveling to nearby social resources, which include shopping centers, restaurants, an arts center, and
offices. Neither intersection is in a geographic area with a higher percentage of EFCs than Clackamas
County as a whole.
Oregon City. In the downtown area of Oregon City, four intersections would have worse traffic operations
under the Build Alternative compared to the No Build Alternative:
• 7th Street and Main Street intersection: In 2027, this intersection would not meet standards under
the Build Alternative and would meet standards under the No Build Alternative during the PM peak
hour, and moderate congestion would occur.
• OR 99E and 10th Street intersection: In 2045, this intersection would not meet standards under the
Build Alternative and would meet standards under the No Build Alternative during the PM peak hour,
with slightly longer delays (less than 5 seconds).
• OR 99E (McLoughlin Boulevard) and 14th Street intersection: In 2027, this intersection would not
meet standards under both alternatives during the PM peak hour. Delays would be longer (by more
than 1 minute) and congestion would be more severe under the Build Alternative compared with the
No Build Alternative. In 2045, this intersection would not meet standards under both alternatives
during the AM and PM peak hours, and there would be longer delays (by up to about 20 seconds)
under the Build Alternative compared to the No Build Alternative.
44
The term moderate congestion refers to intersections that do not meet local mobility standards and generally have
Level of Service D according to the I-205 Toll Project Transportation Technical Report.

I-205 Toll Project
• OR 99E and 15th Street intersection: During the AM peak hour in 2045, this intersection would not
meet standards under the Build Alternative and meet standards under the No Build Alternative, and
longer delays (by nearly 3 minutes) would occur under the Build Alternative. During the PM peak hour
in 2045, this intersection would have severe congestion and would not meet standards under both
alternatives, but there would be longer delays (by about 1 minute) under the Build Alternative
compared to the No Build Alternative.
Two additional intersections just outside of the downtown area would not meet standards under both
alternatives and would experience worse traffic operations under the Build Alternative:
• OR 99E and I-205 northbound ramps: Although moderate to severe congestion would occur under
both alternatives during the PM peak hour in 2027, there would be worse congestion under the Build
Alternative during the PM peak hour compared with the No Build Alternative, which would have
impacts on people traveling to nearby social resources, including shopping centers, restaurants, and
parks. Although severe congestion would continue to occur under both alternatives at this intersection
in 2045, the Build Alternative would have worse congestion and delays (by about 25 seconds during
the AM peak hour) than the No Build Alternative.
• OR 99E and I-205 southbound ramps: Although congestion would be moderate to severe under
both alternatives during the 2027 PM peak hour, delays would be worse (by about 1 minute) under
the Build Alternative compared to the No Build Alternative during the PM peak hour and would have
an impact on people traveling to nearby social resources, including shopping centers, restaurants,
and parks.
Worsening traffic performance under the Build Alternative would have an impact on people traveling to
nearby social resources, which currently include shops, restaurants, the Clackamas County Court House,
City Hall, a community center, religious organizations, nursing homes, and parks.
Transit travel times along OR 99E near these affected intersections would be similar under the Build and
No Build Alternatives in 2045. However, transit MMLOS would be lower under the Build Alternative as
compared to the No Build Alternative on southbound OR 99E from 11th Street to Main Street and on
northbound OR 99E from Railroad Avenue to MP 12.74 in downtown Oregon City. Additionally, there
would be longer travel times under the Build Alternative compared to the No Build Alternative on
northbound Main Street from 11th Street to 15th Street during the AM peak hour and on southbound Main
Street from 14th Street to OR 99E during the PM peak hour in 2045. These travel-time delays would have
an impact on transit access to social resources in the downtown Oregon City area during those times.
One segment of the OR 99E corridor, 11th Street to Main Street in Oregon City, would experience worse
pedestrian level of service under the Build Alternative than under the No Build Alternative in 2045
because of increasing traffic volumes.
None of the downtown Oregon City intersections are in a geographic area with a higher percentage of
EFCs than Clackamas County as a whole. However, adjacent areas have a higher proportion of people
experiencing a disability than Clackamas County as a whole. Because of the larger concentration of
social services in Oregon City compared to the rest of the API, it is expected that EFC populations would
regularly travel through this area and may experience impacts from higher congestion levels under the
Build Alternative.
Tualatin. Two Tualatin intersections (I-5 northbound ramps and Nyberg Street and I-5 southbound ramps
and Nyberg Street) would meet standards under the No Build Alternative and not meet standards under
the Build Alternative during the PM peak hour in 2027. The Build Alternative would have longer delays (by
less than 10 seconds at the I-5 northbound ramps and about 20 seconds at the I-5 southbound ramps)

I-205 Toll Project
than the No Build Alternative. These differences could have an impact on people and public service
providers, such as emergency vehicles, traveling to nearby social resources, including medical facilities,
parks, and shopping centers. The southbound ramps intersection is in a geographic area with a higher
percentage of low-income populations, minority populations, and people experiencing a disability than
Clackamas County as a whole. Effects specific to low-income populations and minority populations are
discussed in Section 3.8.2.
One other Tualatin intersection, the SW Borland Road and SW 65th Avenue intersection, would meet
standards during the AM peak hour under the No Build Alternative and would not meet mobility standards
under the Build Alternative in 2045. Although severe congestion would occur at this intersection under
both alternatives, the Build Alternative would have longer delays (by about 20 seconds) in 2045. This
difference would have impacts on people or public service providers, such as emergency vehicles,
traveling to nearby social resources, which currently include a medical center, schools, an assisted living
facility, and parks. This intersection is not in a geographic area with a higher percentage of EFCs than
Clackamas County as a whole.
West Linn. Two West Linn intersections would have better operations under the Build Alternative than
the No Build Alternative. The OR 43 and I-205 southbound ramps intersection would have shorter delays
in 2027 during the AM peak hour (by about 15 seconds) and in 2045 during the PM peak hour (by almost
1 minute). These shorter delays would provide benefits for people traveling to nearby social resources,
which currently include parks, schools, religious organizations, and shopping centers. The Hidden
Springs Road and Santa Anita Drive intersection would have shorter delays (by about 10 seconds) in
2045 during the PM peak hour. This difference would provide benefits for people and public service
providers, such as emergency vehicles, traveling to nearby social resources, which currently include a fire
station, parks, and schools.
One West Linn intersection (12th Street and Willamette Falls Drive) would not meet standards under both
alternatives and would have comparatively worse traffic operations under the Build Alternative than the No
Build Alternative during the PM peak hour in 2045. Although severe congestion would occur under both
alternatives at this intersection during the PM peak hour, the Build Alternative would have longer delays (by
about 2 minutes) than the No Build Alternative. This difference would have an impact on people or public
service providers, such as emergency vehicles, traveling to nearby social resources, which currently include
a fire station, a school, religious organizations, medical offices, and restaurants. In addition, the 12th Street
and Willamette Falls Drive intersection would experience a higher level of pedestrian traffic stress under the
Build Alternative compared to the No Build Alternative in 2045 because of higher traffic volumes, which
would potentially impact people walking to nearby social resources. This intersection is not in a geographic
area with a higher percentage of EFCs than Clackamas County as a whole.
Unincorporated Clackamas County. In unincorporated Clackamas County in the Canby area, three
intersections on OR 99E outside of the city limits would not meet standards in both alternatives and would
have comparatively worse traffic operations under the Build Alternative:
• OR 99E and South End Road intersection: Although severe congestion would occur under both
alternatives at this intersection during the AM and PM peak hours in 2027 and 2045, the Build
Alternative would have more congestion than the No Build Alternative and would have an impact on
people traveling to nearby social resources, which currently include religious organizations.

I-205 Toll Project
• OR 99E and New Era Road intersection: Although severe congestion would occur under both
alternatives at this intersection during the PM peak hour in 2027 and 2045, the Build Alternative
would have more congestion than the No Build Alternative and would have an impact on people
traveling to nearby social resources, which currently include religious organizations.
• OR 99E and Lone Elder Road: Although severe congestion would occur under both alternatives at
this intersection during the AM and PM peak hours in 2027 and 2045, the Build Alternative would
have more congestion during the 2027 and 2045 AM peak hours than the No Build Alternative. There
are limited social resources near this rural intersection. However, the greater congestion levels could
have an impact on people traveling to social resources in nearby Aurora or Canby. The area
surrounding this intersection has a higher percentage of older adults than Clackamas County as a
whole.
In the Stafford Hamlet area, three intersections on SW Stafford Road would have worse traffic operations
under the Build Alternative than the No Build Alternative:.
• SW Stafford Road and SW Mountain Road intersection: During the PM peak hour in 2045, this
intersection would meet standards under the Build Alternative and not meet standards under the No
Build Alternative. However, during the AM peak hour in 2027 and 2045, this intersection would not
meet standards under both alternatives. Although severe congestion would occur under both
alternatives at this intersection, the Build Alternative would have more severe congestion and longer
delays (by about 20 to 40 seconds) compared to the No Build Alternative and would have an impact
on people traveling to nearby social resources, which currently include schools and religious
organizations. Transit travel times on both directions of Stafford Road between the Tualatin River and
SW Mountain Road would be about the same under both alternatives during the AM peak hour and
would improve under the Build Alternative compared to the No Build Alternative during the PM peak
hour, which would benefit people traveling to social resources via transit.
• SW Stafford Road and SW Childs Road intersection: During the AM and PM peak hour in 2045,
this intersection would not meet standards under both alternatives. Although medium to severe
congestion would occur under both alternatives at this intersection, the Build Alternative would have
longer delays (by less than 20 seconds) compared to the No Build Alternative and would have an
impact on people traveling to nearby social resources, which currently include parks, schools, and
religious organizations.
• SW Stafford Road and SW Rosemont Road intersection: During the AM peak hour in 2027 and
the AM and PM peak hours in 2045, this intersection would not meet standards in both alternatives.
Although moderate congestion would occur under both alternatives at this intersection, the Build
Alternative would have longer delays (by about 10 seconds to more than 1 minute) compared to the
No Build Alternative. During the PM peak hour in 2027, this intersection would not meet standards
under the Build Alternative but would meet standards under the No Build Alternative. This congestion
in 2027 and 2045 would have an impact on people traveling to nearby social resources, which
currently include parks, schools, religious organizations, and an assisted living facility.
Pedestrians would experience a worse level of service in 2045 on southbound SW Borland Road from
SW Stafford Road to Ek Road under the Build Alternative compared to the No Build Alternative, which
could cause delays in their access to nearby social resources. None of the affected Stafford intersections
are in geographic areas with a higher percentage of EFCs than Clackamas County as a whole.

I-205 Toll Project
Roadway Safety
All communities in the API would benefit from 26% lower number of crashes (representing about 144
fewer crashes) on I-205 in the API, including fewer crashes resulting in injuries, under the Build
Alternative compared to the No Build Alternative, as described in the Transportation Safety subsection of
Section 3.1.2.
The total number of annual predictive crashes at local intersections and roadway segments in the API
would vary by location but would generally be similar under the Build Alternative as compared to the No
Build Alternative in 2027 and/or 2045, as discussed in the Transportation Safety subsection of Section
3.1.2. Four intersections and portions of OR 99E and SW Stafford Road in Canby, Gladstone, Tualatin,
unincorporated Clackamas County would experience safety impacts in 2027 that would require
consideration of mitigation, according to criteria identified in Section 3.1.2. Because there would be a
combination of benefits and impacts depending on location, and safety impacts would be mitigated, the
Build Alternative would generally have no adverse effects on health and safety on local roadways and
intersections.
Cost of Tolls
Social and public service providers and households, including EFCs, could experience higher costs as a
percentage of their operating or household transportation budgets compared to the No Build Alternative if
they choose to travel on the tolled I-205 bridges, as discussed in Sections 3.4.2 and 3.8.2. However,
overall, the improved I-205 traffic performance under the Build Alternative is expected to lead to economic
benefits that would reduce costs for social resource providers and community members. These benefits
include lower vehicle emissions, shorter travel times, vehicle operating cost savings, and fewer crashes
on I-205.
The cost of tolls would have impacts on low-income households, which could also include populations on
a fixed income, such as older adults and people experiencing a disability. This potential impact and the
proposed mitigation are discussed in Sections 3.8.2 and 3.8.4.
Effects related to the cost of tolls would start when tolling is implemented (2 to 3 years before completing
construction of the planned I-205 improvements, as discussed further in the Tolling During Construction
of Roadway Improvements subsection of Short-Term Effects.)
Ability to Use Electronic Toll System

Because roadway signage will be in English, the tolling system could introduce challenges for persons
with limited English proficiency in the API. Through community engagement and outreach for the Project,
analysts also identified potential technological barriers related to the electronic toll system for the general
population and for EFCs. People who are less proficient with technology may have difficultly registering
for an account, purchasing a transponder, and paying bills online. These technological barriers could
discourage use of the tolling system among all populations and contribute to rerouting from I-205 to avoid
the toll system. These effects would start when tolling is implemented (2 to 3 years before completing
of Roadway Improvements subsection of Short-Term Effects.)

Table 3-37 provides a comparison of anticipated social resources and communities impacts and benefits
by alternative.

I-205 Toll Project
Table 3-37. Social Resources and Communities Effects by Alternative

Short-Term Effects None • Temporary noise and dust increase in the
vicinity of construction activities on I-205 but
minimal construction impacts on neighboring
social resources and communities
• Brief I-205 roadway closures and detours, with
maintenance of access to all social resources
and geographic communities, including
emergency services.
Long-Term Effects Compared to existing conditions, there Compared to the No Build Alternative, there would
would be: be:
• Differences in access (a mix of • Similar or greater access to social resources
greater, less, and similar) to social (e.g., job centers, community places, medical
resources (e.g., job centers, facilities) for EFCs and the general population
community places, medical because of projected regional growth and
facilities) for EFCs and the general transportation improvements related to the Build
population in 2045 Alternative in 2045
• Similar or longer travel times to • Similar or shorter travel times to representative
representative activity centers (e.g., activity centers (e.g., parks, businesses, medical
parks, businesses, medical facilities) for all populations traveling on routes
facilities) for EFCs and the general with the proposed tolled bridges because of
population traveling on the I-205 in reduced traffic congestion on I-205 in 2045
the Project area in 2045 • Potential higher transportation costs for social
Longer travel times and more and emergency service providers, which may be
crashes on I-205, which would have offset by other user and social benefits
an impact on access to social associated with improved I-205 traffic
resources and communities in 2045 performance (e.g., reduced emissions, shorter
travel times, vehicle operation cost savings,
fewer crashes)
• Potential impacts from the cost of tolls on low-
income households, which could include older
adults and people experiencing a disability,
which would start when tolling is implemented (2
to 3 years before completing construction of the
planned I-205 improvements)
• Potential language and technological barriers to
using and understanding the electronic toll
system, which would start when tolling is
implemented (2 to 3 years before completing
construction of the planned I-205 improvements)
• Potential delays and longer travel times near
intersections, which could affect access to social
resources in Canby, Gladstone, Lake Oswego,
Oregon City, Tualatin, West Linn, and
unincorporated Clackamas County (near
Stafford Hamlet and Canby) in 2027 and/or 2045
during the AM and/or PM peak hours
• Similar numbers of crashes on most local streets
in 2027 and 2045, and a lower number of
crashes on I-205 in 2045. Four intersections and
portions of OR 99E and SW Stafford Road in
Canby, Gladstone, Tualatin, unincorporated
Clackamas County would experience safety
impacts in 2027 that would require consideration
of mitigation.
EFC = Equity Framework Communities

I-205 Toll Project

Short-Term Impacts
implement BMPs to manage and reduce construction-related impacts, including noise, air quality, and
traffic control measures. No additional mitigation is required.
To facilitate use of the toll system by persons with limited English proficiency, ODOT would conduct
outreach in multiple languages (e.g., Simplified and Traditional Chinese, Russian, Spanish, Vietnamese)
and plain language to provide advance information about construction activities and potential effects.
Long-Term Impacts
Section 3.1.4 provides a list of potential measures to avoid, minimize, or mitigate roadway, transit, and active
transportation impacts under the Build Alternative, which would also help to avoid, minimize, or mitigate
impacts on social resources and communities near affected intersections in particular geographic areas.
As part of the Oregon Toll Program development, ODOT has committed to providing a low-income toll
program. Section 3.8.4 provides more information about the status of development of this program.
The following additional measures would be implemented prior to and/or during tolling to avoid or
minimize long-term impacts on social resources and communities:
• ODOT would continue public outreach through final design and construction to mitigate barriers to
using the electronic toll system, including:
- Conducting outreach in multiple languages (e.g., Simplified and Traditional Chinese, Russian,
Spanish, Vietnamese) and plain language to provide information about the Toll Program,
including how to purchase a transponder, establish an account, and use the system. This
outreach would also include raising awareness about travel options in the region to help offset the
cost of tolls, such as a subsidized vanpool program that reduces costs for participants and tools
operated by the Get There Oregon program to match commuters with carpool opportunities.
- Implementing an electronic toll system interface (e.g., website, mobile application, printed
materials) that is simple, easy to use, uses plain language and a combination of text and simple
graphics, and complies with Section 508 of the Rehabilitation Act of 1973.45
- Distributing information about the I-205 Toll Project throughout toll operations, in coordination with
other transportation projects (e.g., Oregon Toll Program, Regional Mobility Pricing Project) in the
region via community-based organizations, public and social service offices, religious
organizations, and schools.
- Directly advertising in newspapers and radio stations that have an audience representative of
limited English proficiency populations and establishing hotlines with multilingual customer
service agents (e.g., Simplified and Traditional Chinese, Russian, Spanish, Vietnamese) in
advance of the start of tolling.
• ODOT would establish permanent customer service centers across the region to mitigate barriers to
using the electronic toll system, so drivers could:
- Purchase transponders, establish prepaid accounts, and pay invoices in person and/or with cash.
- Call customer service centers for assistance navigating the toll system and answer questions
about how the program works.
45
Section 508 of the federal Rehabilitation Act of 1973 includes regulations to ensure agencies provide information
that is accessible to and usable by people experiencing a disability. See more at www.section508.gov.

I-205 Toll Project
3.8 Environmental Justice

The API for the environmental justice analysis, shown in Figure 3-16, encompasses the largest resource API
(used for the air quality and economics analyses) to assess the full range of potential effects on environmental
justice populations. The environmental justice analysis identifies and examines all potential adverse effects on
low-income 46 and minority 47 populations to determine whether the Build Alternative would result in
disproportionately high and adverse effects on low-income and/or minority populations 48 in accordance with
Executive Order 12898.49 Chapter 4 of Appendix J, I-205 Toll Project Environmental Justice Technical Report,
provides more detailed information about the methodology used for the environmental justice analysis.
Existing low-income populations and minority populations were identified in the API through a no-
threshold approach. 50 In general, the population in the API has similar or lower percentages of
environmental justice populations than the four counties, Portland MSA, and Oregon and Washington
State as a whole, as shown in Table 3-38. Appendix J, I-205 Toll Project Environmental Justice Technical
Report, provides more information and maps showing the percentage of environmental justice
populations throughout the API.
In addition, analysts identified concentrations of environmental justice populations using the Meaningful
Greater approach, 51 which identifies geographic areas with a higher percentage of one or more low-income
populations and/or minority populations compared to the county in which they are located, as shown in Figure
3-16. Table 3-38 shows the county average percentages of low-income and minority populations. Attachment
D of Appendix J, I-205 Toll Project Environmental Justice Technical Report, provides more information about
which environmental justice populations had higher concentrations in a given area.
46
The Project defines low-income using the U.S. Department of Health and Human Services poverty guidelines and
200% the poverty level set by the U.S. Department of Health and Human Services to be consistent with U.S.
Census Data, to align with regional and stakeholder definitions of low-income (TriMet and Metro) and to be more
inclusive of the costs of living. For a family of four, the poverty level set by the U.S. Department of Health and
Human Services is $26,200 per year; 200% of this amount is $52,400 per year (U.S. Department of Health and
Human Services 2020).
47
A minority is a person who is Black, Hispanic or Latino (regardless of race), Asian American, American Indian and
Alaskan Native, or Native Hawaiian or Other Pacific Islander (U.S. Department of Transportation 2012). This
analysis also included people who identified as two or more of these categories.
48
The term “low-income and/or minority” populations is used because someone could identify with multiple
communities at once, while also being categorized as different demographic populations simultaneously. For
example, a person could be categorized as a minority and low-income, as well as the other populations like
seniors or limited English proficiency. As people can have and experience multiple identities, there is complexity in
adequately aggregating and disaggregating demographic data to adequately and meaningfully describe people’s
identities and communities.
49
EO 12898 directs federal agencies to identify and address the disproportionately high and adverse human health
or environmental effects of their actions on minority and low-income populations, to the greatest extent practicable
and permitted by law.
50
A no-threshold approach means that the identification of environmental justice populations is not limited to only
census tracts that have a defined threshold percentage of low-income and/or minority persons. The no-threshold
approach minimizes the possibility of inadvertently missing concentrations of low-income and/or minority persons
within census tracts that do not meet a predefined threshold (U.S. Environmental Protection Agency 2016).
51
A Meaningfully Greater analysis considers environmental justice impacts in census tracts where levels of low-
income or minority populations are “meaningfully greater” than corresponding county or regional averages—
usually expressed in percentage ranges (U.S. Environmental Protection Agency 2016).

I-205 Toll Project
Figure 3-16. Environmental Justice Concentrations within the Area of Potential Impact

I-205 Toll Project
Table 3-38. Environmental Justice Demographic Groups in the Area of Potential Impact
Clackamas Multnomah Washington Marion Portland Oregon Washington
Population API County County County County MSA[1] State State
Total 344,280 410,463 804,606 589,481 339,641 2,445,761 4,129,803 7,404,107
Population
Total 136,786 157,408 326,229 219,053 118,038 938,646 1,611,982 2,848,396
Households
Racial Minority 10% 9% 19% 18% 8% 15% 11% 19%
Ethnic Minority 10% 9% 12% 17% 27% 12% 13% 13%
(Hispanic or
Latino)
People 20% 19% 30% 22% 36% 25% 30% 26%
Experiencing
Low Income
(Below 200% of
Poverty Level)*
People 8% 8% 14% 9% 14% 11% 13% 11%
Experiencing
Low Income:
Poverty Level*
Source: U.S. Census Bureau, American Community Survey 2015 to 2019
* Demographic groups that are considered environmental justice populations analysis.
[1] Portland MSA refers to the Portland-Vancouver-Hillsboro, OR-WA Metropolitan Statistical Area.

This section describes the effects of the No Build and Build Alternatives on environmental justice
populations within the API. The effects discussions focus on elements related to projected differences in
local traffic patterns between the alternatives (access to social resources, travel time scenarios, rerouting
traffic to local streets, and roadway safety) and on elements related to tolling (cost of tolls, ability to
understand and use the electronic toll system).Effects on environmental justice populations related to
noise and air quality were evaluated in Appendix J, I-205 Toll Project Environmental Justice Technical
Report. As discussed in Sections 3.2.2 and 3.5.2 of Appendix J, there would be no adverse air quality and
noise effects in the API.
The analysis of effects of tolling costs and the toll system and of overall transportation effects on I-205
and local roadways at an API level is based on the no-threshold approach (i.e., it considers effects on
environmental justice populations regardless of location). The analysis of the effects on access, travel-
time, rerouting to local streets, and safety is generally based on the meaningfully greater approach (i.e.,
considering effects on geographic areas with higher percentages of environmental justice populations
than the county in which they are located).
The Project Team used Metro’s regional travel demand model to conduct an accessibility analysis, which
determined the number of jobs and social resources (community places and medical facilities) that
environmental justice households could access by automobile or transit during peak hours and non-peak
hours under existing conditions to allow for a comparison to the No Build and Build Alternatives in 2045.
Access is measured by calculating a regional average number of resources that can be reached within a
given travel-time from home locations in the region and API. When comparing the No Build Alternative to
existing conditions, the model accounted for the expected future growth in land use and transportation

I-205 Toll Project
system investments consistent with the adopted 2018 Regional Transportation Plan. A more detailed
description of the methodology and results of the accessibility analysis is included in Attachment D of
Appendix J, I-205 Toll Project Environmental Justice Technical Report.
Under the No Build Alternative in 2045 compared to existing conditions:
• During peak hours, areas with higher concentrations of environmental justice households in the API
would experience access to fewer jobs of all pay levels.
• During off-peak hours, areas with higher concentrations of environmental justice populations in the
API would experience access to more jobs of all pay level within a 30-minute drive.
• Areas with higher concentrations of environmental justice households in the API would experience
access to more job centers, community places, and medical facilities within a 30- or 45-minute transit
trip during both peak and off-peak hours under the No Build Alternative relative to existing conditions.
Consistent with Metro’s approved long-range planning documents (i.e., Regional Transportation Plan),
the future scenario modeling assumes that regional population and employment growth would continue to
occur over time, which would result in more jobs, community places, and medical facilities throughout the
API in 2045. Growth in the number of jobs and community resources can improve accessibility; however,
the regional model assumes population and employment growth would result in higher demand for travel
across modes, which would challenge the transportation system and could result in longer delays that
would affect accessibility for environmental justice populations.
The Project Team determined the shortest travel time for 16 representative trips under existing conditions
and the No Build and Build Alternatives in 2045. 52 Eight of the representative scenarios included trips that
started in geographic areas with higher concentrations of environmental justice populations and ended in
areas with social resources such as parks, hospitals, libraries, large employment centers, or retail
locations. Representative scenarios do not include all possible trips that would be taken in the region but
serve as a snapshot of potential travel-time savings.
Analysts used Google Maps to identify the shortest trip path from start point (home) to end point (activity
destinations) that would include the proposed tolled bridges on I-205 (Abernethy and Tualatin River
Bridges). They used baseline conditions from the Metro Regional Travel Demand Model to identify the
shortest path that would not include the proposed tolled bridges on I-205. This approach enabled a
comparison of routes both with and without tolling. A detailed description of the methodology and results
is included in Attachment E of Appendix J, I-205 Toll Project Environmental Justice Technical Report.
Under the No Build Alternative in 2045, travel times for 8 trips starting in areas with higher concentrations
of environmental justice populations would be similar to or longer than under existing conditions. Similar
to the Access to Social Resources analysis, these changes would occur because of projected population
and employment growth. Trips would generally take more time because of increased congestion on I-205
and connecting roadways in 2045 compared to existing conditions, as described in Section 3.1.2.
52
There were 16 representative scenarios to estimate potential travel-time effects on Equity Framework
Communities, and the general population, eight of which representing low-income and/or minority populations.
Representative scenarios included trips that started in environmental justice areas and ended in social resource
areas such as parks, hospitals, libraries, large employment centers, retail locations, etc. Representative scenarios
do not include all possible trips that would be taken in the region but serve as a snapshot of potential travel-time
savings.

I-205 Toll Project

AM and PM peak-period travel times on both directions of I-205 between I-5 and 82nd Drive would be
longer under the No Build Alternative in 2045 compared to existing conditions (as described in Section
3.1.2), which would have adverse effects on environmental justice populations accessing social resources
using I-205. Vehicles currently reroute from I-205 to other roadways during higher demand periods when
traffic congestion is present.
Under existing conditions, 5 intersections (in Lake Oswego, Oregon City, unincorporated Clackamas
County, and West Linn) do not meet jurisdictional mobility standards53 for intersection performance during
the AM peak hour, and 10 intersections (in Gladstone, Oregon City, unincorporated Clackamas County,
and West Linn) do not meet mobility standards during the PM peak hour. One of the failing intersections,
the 82nd Drive and I-205 southbound ramps intersection, is located in an area with a higher concentration
of environmental justice populations. Most of those intersections would continue to fail to meet local
standards, and some intersections, including the 82nd Drive and I-205 southbound ramps intersection,
would experience worse congestion under the No Build Alternative than existing conditions in both 2027
and 2045.
The intersections that would fail to meet standards for intersection performance during the AM peak hour
and PM peak hour under the No Build Alternative, especially the ones located in Oregon City where a
concentration of social resources is present, would result in continued adverse effects on environmental
justice populations traveling to nearby social resources.
Roadway Safety
The number of crashes on the portion of I-205 and local roadways studied in the API is generally
expected to be slightly higher under the No Build Alternative in 2045 compared to existing conditions
because of the anticipated higher traffic volumes, as discussed further in Section 3.1.2. The No Build
Alternative could have adverse effects on health and safety for all populations in the API, including
environmental justice populations, related to the use of these roadways.
Build Alternative
Short-Term Effects
Construction impacts such as short-term lane and roadway closures (as discussed in Section 3.1.2),
minor increases in dust and noise levels (as discussed in Section 3.2.2 and 3.5.2), and minimal physical
impacts on nearby properties (as described in Section 3.9.2) would be limited to the area immediately
surrounding the construction work areas. No relocations of businesses or residences in environmental
justice communities would be required for construction. No areas with higher concentrations of
environmental justice populations were identified adjacent to the construction areas for the Build
Alternative. Construction effects on environmental justice populations would be the same as for the
general population.

ODOT anticipates starting tolling on the Abernethy Bridge and possibly tolling on the Tualatin River
Bridges for 2 to 3 years (between 2024 and 2027) while completing construction of the Build Alternative,
as discussed in Section 3.1.2. If both bridges are tolled during construction, traffic volumes would
53
Mobility standards for intersections vary by jurisdiction, with most measured as volume-to-capacity ratios and
others as level of service, which are defined in Section 3.1.2.

I-205 Toll Project
generally be higher on two segments of OR 99E that pass through areas with higher concentrations of
environmental justice populations in Canby and Gladstone, as well as on SW Borland Road, SW Stafford
Road, OR 213, and OR 43 compared to the No Build Alternative.
Tolling would result in higher transportation costs for low-income populations who choose to use routes
with tolled bridges during construction of the roadway improvements, and would continue after the
completion of the roadway improvements as discussed in the Cost of Tolls section below, which indicates
an adverse effect. Other effects on environmental justice populations resulting from the pre-completion
tolling scenarios would be 2 to 3 years in duration and comparable to those under the Build Alternative in
2027, as described in Section 3.1.2 and the Rerouting sub-section of Long-Term Effects.
Long-Term Effects
Areas with higher concentrations of environmental justice populations would generally experience the
same or improved access to jobs, community places, and medical facilities under the Build Alternative as
compared to the No Build Alternative in 2045 because implementation of the Build Alternative would
result in less congested conditions on I-205 and some neighboring roadways. The model for the
accessibility analysis also accounts for regional growth in population and employment through 2045.
Environmental justice populations would experience slightly greater accessibility compared with general
population households within the API and Portland MSA.
The only instance where environmental justice households would experience less access under the Build
Alternative as compared to the No Build Alternative and as compared to general population households in
the API is in the number of medium-paying jobs within an off-peak 45-minute transit trip (less than 1%
fewer jobs, representing about 100 fewer jobs, relative to the No Build Alternative). However,
environmental justice households would experience greater accessibility to medium-paying jobs within a
30-minute drive (3.89% more jobs) and within a 45-minute transit trip (0.60%more jobs) during peak
hours, and within a 30-minute drive (0.96% more jobs) during off-peak hours under the Build Alternative
as compared to the No Build Alternative. The difference in accessibility to medium-paying jobs within an
off-peak 45-minute transit trip between environmental justice households and the general population
households is less than 1%, and environmental justice populations experience greater accessibility to
medium-paying jobs via other travel methods. Therefore, any adverse effect would be minimized.
Overall, environmental justice households would generally experience similar or slightly improved
accessibility to jobs, community places, and medical facilities as compared to general population
households in the API.
A more detailed description of the methodology and results of the accessibility analysis is included in
Attachment E of Appendix J, I-205 Toll Project Environmental Justice Technical Report.
Based on the results of the travel-time analysis described in the No Build Alternative section,
environmental justice populations in the API would experience the same or shorter travel times for trips
from their homes via private vehicle or transit to 8 representative activity locations under the Build
Alternative as compared to the No Build Alternative in 2045. Five scenarios would result in shorter travel
times on routes that include the proposed tolled bridges (Abernethy and Tualatin River Bridges) on I-205
because there would be less congestion on I-205 under the Build Alternative in 2045, as discussed in
Section 3.1.2. For the other four scenarios, travel times would not change because they represent trips
that are assumed not to use tolled routes in the future, including fixed transit routes.

I-205 Toll Project
Environmental justice populations and the general population would benefit from similar or shorter travel
times on representative trips that use the proposed tolled bridges and on representative trips that use
transit.
Cost of Tolls
Tolling would result in higher transportation costs as a portion of household spending. Low-income
populations, as represented by households with incomes at the federal poverty level and at 200% of the
poverty level, would have a greater increase in the percentage of income spent on transportation when
compared to households in the API with median income, as discussed in Section 3.4.2 and shown in
Table 3-39.
Table 3-39. Percentage of Income Spent on Transportation

Percentage of Income Percentage of Income
Spent on Spent on
Transportation Transportation Costs
Without the Toll (No with the Toll (Build
Household Type Income Level Build Alternative) Alternative)
Median Household Income for the $88,400 7.9% 8.6%
API[1]
Poverty Threshold for a Household $26,200 17.3% 19.7%
of 4
200% Poverty (low-income) for a $52,400 10.6% 11.8%
Household of 4
[1] Median household income values were derived from the tolling impacts analysis in Appendix F, I-205 Toll Project
Economics Technical Report, as summarized in Section 3.4.2, which measures the economic impacts of the Project.
For the purposes of the analysis, the Project Team assumed the same average number of annual
weekday vehicle trips per household (206 trips) and average annual toll fees per household in nominal
dollars, as described in Section 3.4.2, but did not take into consideration households changing their
routes and/or changing their behaviors to avoid the toll, which would decrease the percentage of their
income they would otherwise spend on tolls. The toll costs would vary depending on the route, time of
day, and frequency of trips involving a toll. For some people, switching travel modes (e.g., to transit or
bicycling) or traveling at off-peak hours would not be a viable option if transit service is limited or bicycle
infrastructure is deficient or nonexistent; traveling by a different mode is inefficient due to longer travel
times; or they need to commute to work during peak hours when toll rates would be highest.
Public engagement activities with environmental justice populations also identified fairness of toll evasion
enforcement as a concern for environmental justice populations. If motorists do not pay the toll on time, or
at all, the percentage of income they spend on transportation costs could be further affected with late fees
or other enforcement methods. Additionally, some groups expressed concern about the potential for racial
or ethnic discrimination in the enforcement of toll payment collection. Environmental justice populations
could be disproportionately affected if they face greater barriers due to additional tolling-related fees
and/or experience different levels of toll evasion enforcement than the general population.
Effects related to the cost of tolls would start when tolling is implemented (2 to 3 years before completing
of Roadway Improvements subsection of Short-Term Effects.) The improved I-205 traffic performance
under the Build Alternative is expected to lead to user and social benefits—such as lower vehicle
emissions, shorter travel times, vehicle operating cost savings, and fewer crashes, as described in
Section 3.4.2—that reduce costs for community members, including environmental justice populations.
There is no FHWA or ODOT guidance on measuring transportation affordability in environmental justice

I-205 Toll Project
analyses. However, because the toll under the Build Alternative could result in households at or below the
federal poverty level spending a higher percentage of their income on transportation than median-income
households, there would be an adverse effect on low-income populations with limited alternatives to using
a tolled facility. In accordance with Oregon House Bill 3055, ODOT prepared a Low-Income Toll Report
that summarizes the engagement, analysis, and research conducted to inform the options for
consideration and best practices to address potential impacts of the Oregon Toll Program on low-income
populations, as discussed further in Section 3.8.4 (ODOT 2022c).

With the added capacity in both directions and tolling on I-205, the Build Alternative would result in faster
travel times in 2045 in both the AM and PM peak periods compared to the No Build Alternative. These
improved travel times could facilitate faster access to social resources for environmental justice
populations using I-205 under the Build Alternative. However, under the Build Alternative in 2027 and
2045, some traffic would reroute to local streets in order to avoid tolls, resulting in potential adverse
effects for areas with higher concentrations of environmental justice populations in Canby and Tualatin,
as well as environmental justice populations traveling to a hub of social resources in Oregon City.
Appendix J, I-205 Toll Project Environmental Justice Technical Report, provides maps showing the
locations of these affected intersections in relationship to areas with higher concentrations of
environmental justice populations.
Areas of Oregon City near I-205 and portions of OR 99E near Canby would have the largest numbers of
intersections with worse operations under the Build Alternative as compared to the No Build Alternative in
2027 and/or 2045, as described in more detail in Sections 3.1.2 and 3.7.2. Two intersections in areas with
higher percentages of environmental justice populations than the county as a whole (I-5 southbound
ramps and Nyberg Street in Tualatin, and OR 99E and Ivy Street in Canby) would have worse operations
under the Build Alternative than the No Build Alternative in 2027 and/or 2045.
Six intersections in or near the downtown area of Oregon City would have worse traffic operations under
the Build Alternative as compared to the No Build Alternative in 2027 and/or 2045. Although the area
containing these intersections is not in an area with higher concentrations of environmental justice
populations, Oregon City has a concentration of social resources that serve low-income and/or minority
populations, such as the Clackamas County Court House, City Hall, an Oregon Department of Human
Services office, a community center, multiple social service providers, religious organizations, nursing
homes, and parks. Longer delays at these intersections under the Build Alternative would have an impact
on environmental justice populations traveling to access social resources in Oregon City. In addition, one
segment of the OR 99E corridor, 11th Street to Main Street in Oregon City, would experience worse
pedestrian LOS under the Build Alternative as compared to the No Build Alternative in 2045 because of
higher traffic volumes (Section 3.1.1 provides more information on these metrics).
Intersection impacts related to rerouting would occur throughout the API, as discussed above and in
Section 3.1.2, and most adverse effects would occur outside of areas with high concentrations of
environmental justice populations. Additionally, mitigation identified in Section 3.8.4 is expected to avoid
and minimize adverse effects related to rerouting traffic to local streets. All populations, including
environmental justice populations, in the API are expected to experience adverse effects to the same
degree from rerouting as well as the benefits associated with the mitigation.

I-205 Toll Project
Roadway Safety
The total number of annual predictive crashes at intersections and roadway segments in the API would
vary by location but would generally be similar under the Build Alternative as compared to the No Build
Alternative in 2027 and 2045, as discussed in Section 3.1.2. Three intersections in areas with higher
percentages of environmental justice populations than Clackamas County as a whole would experience
safety impacts: OR 99E and Jennings Avenue in Gladstone, I-5 southbound ramps and Nyberg Street in
Tualatin, and OR 99E and Ivy Street in Canby. In addition, OR 99E, which has segments that cross
through areas in Canby and Gladstone with higher percentages of environmental justice populations than
Clackamas County as a whole, is projected to experience more crashes under the Build Alternative as
compared to the No Build Alternative in 2027 and 2045, as described in the Transportation Safety
subsection of Section 3.1.2. The additional crashes would affect environmental justice populations living
and traveling through the area.
The number of crashes on I-205 in the API, including crashes resulting in fatalities and injuries, is
expected to be 26% lower (representing about 144 fewer crashes) under the Build Alternative as
compared to the No Build Alternative due to the proposed highway improvements. The lower number of I-
205 crashes would benefit all populations, including environmental justice populations.
Overall, the Build Alternative would generally lead to a reduction in crashes on I-205, resulting in benefits
for all populations, including environmental justice populations, and the higher number of predictive
crashes on some roadways would have an impact on both the general population and environmental
justice populations to the same degree.
Ability to Use Electronic Toll System

The tolling system would rely on electronic, cashless technology. The electronic toll system could create
barriers for the unbanked population 54 and for those who do not have access to conventional financial
services, which could include members of environmental justice communities. Putting down a deposit to
set up an account may also create a barrier for drivers who are experiencing low income. The lack of a
cash payment option may make it difficult for the unbanked or other people experiencing low-income to
purchase a transponder or to pay invoices and could discourage them from using the tolled bridges.
These effects would start when tolling is implemented (2 to 3 years before completing construction of the
planned I-205 improvements, as discussed further in the Tolling During Construction of Roadway
Improvements subsection of Short-Term Effects.)
With the mitigation described in Section 3.8.4, adverse effects related to the ability to use the electronic
toll system would be minimized or avoided because users would have the option to set up and pay for toll
accounts with cash and without reliance on electronic systems.

Table 3-40 provides a comparison of anticipated environmental justice impacts and benefits by
alternative.
54
Unbanked households are those where no one in the household has a checking or savings account at a bank or
credit union (Federal Deposit Insurance Corporation 2019).

I-205 Toll Project
Table 3-40. Environmental Justice Effects

Potential Potential Adverse
Adverse Effect on
Effect on Environmental
Environmental Summary of Overall General Justice
Topic Effects Location Population? Populations? Environmental Justice Analysis Conclusion
Construction Short-term lane and roadway Construction Yes Yes Potential adverse effect on environmental justice
Effects closures, temporary increases areas on and populations. No areas with higher concentrations of
in noise levels, and temporary near I-205 in the environmental justice populations were identified
increase in dust in or near Environmental adjacent to the construction areas, but environmental
construction areas. Justice API justice populations could travel through the
construction area.
Access to Social Similar or greater access to Social Resources No No No adverse effect on environmental justice
Resources most job types, community and populations. Both the general population and
places, and medical facilities Communities/ environmental justice populations would experience
for all populations because of Environmental similar effects under the Build Alternative compared to
projected regional growth and Justice API the No Build Alternative. In some instances,
transportation improvements environmental justice populations would experience
under the Build Alternative greater benefits than the general population, as
compared to the No Build described in the Access to Social Resources
Alternative in 2045. subsection of Section 3.8.2.
Travel-Time Similar or shorter travel times Social Resources No No No adverse effect on environmental justice
Scenarios to representative activity and populations. Both the general population and
centers (e.g., parks, Communities/ environmental justice populations would experience
businesses, medical facilities) Environmental similar effects under the Build Alternative compared to
for trips on routes using the Justice API the No Build Alternative, as described in the Travel-
proposed tolled bridges on Time Scenarios subsection of Section 3.8.2.
I-205 because of less I-205
traffic congestion under the
Build Alternative compared to
the No Build Alternative in
2045.
Cost of Tolls Higher transportation costs as Social Resources Yes Yes Potential adverse effect on environmental justice
a percentage of household and populations. The toll and associated toll fees under the
spending for all drivers who Communities/ Build Alternative could result in households at or below
use the tolled bridges on I-205, Environmental the federal poverty level spending a higher percentage
which would start when tolling Justice API of their income on transportation than median income
is implemented (2 to 3 years households. Toll evasion enforcement could affect
before completing construction those who cannot pay the toll fees on time by imposing
of the planned I-205 additional late fees.
improvements).

I-205 Toll Project

Adverse Effect on
Rerouting Traffic Potential delays and longer Study Yes Yes Potential adverse effect on environmental justice
to Local Streets travel times near some local intersections and populations. The general population and
intersections under the Build roadways in the environmental justice populations would both be
Alternative compared to the No Transportation affected by rerouting traffic to local streets though
Build Alternative, which could API longer delays and longer travel times at local
affect access to social intersections. Two intersections in areas with a greater
resources by all populations in percentage of environmental justice populations than
2027 and/or 2045. the county as a whole would experience worse traffic
operations under the Build Alternative than under the
No Build Alternative in 2027 and/or 2045. Six
intersections in Oregon City would experience worse
traffic operations under the Build Alternative than
under the No Build Alternative in 2027 and/or 2045, as
described in Section 3.1.2 and 3.7.2, which would in
turn affect how environmental justice populations
access social services in the downtown area of
Oregon City.
Roadway Safety Overall similar roadway safety Study Yes Yes Potential adverse effect on environmental justice
on most local intersections and intersections and populations. The lower number of I-205 crashes would
roadways and fewer crashes roadways in the benefit all populations, including environmental justice
on I-205 under the Build Transportation populations. Safety impacts were identified at
Alternative compared to the No API intersections in Canby, Gladstone, and Tualatin in
Build Alternative in 2027 areas that have higher concentrations of
and/or 2045. Safety impacts environmental justice populations. Higher numbers of
that would require considering predictive crashes on segments of OR 99E in Canby
mitigation identified at four and Oregon City under the Build Alternative compared
intersections and portions of to the No Build Alternative, as described in Section
OR 99E and SW Stafford 3.1.2, would affect environmental justice populations
Road in 2027. living in and traveling through the area.

I-205 Toll Project

Adverse Effect on
Active No difference in bicycle level of Study Yes Yes Potential adverse effect on environmental justice
Transportation stress between No Build and intersections and populations. The general population and
Build Alternatives. Higher roadways in the environmental justice populations would both be
pedestrian level of stress at Transportation affected by worsening of pedestrian conditions at a
one intersection and higher API few locations under the Build Alternative compared to
pedestrian LOS at two areas the No Build Alternative, as described further in
under the Build Alternative Section 3.1.2. OR 99E between 11th Street and Main
compared to the No Build Street, which is in Oregon City near social resources
Alternative. that serve environmental justice populations, would
experience worse pedestrian LOS in 2045.
Noise Minimal noise differences Noise API No No No adverse effect on environmental justice
would occur under the Build populations. Both the general population and
Alternative compared with the environmental justice populations would experience
No Build Alternative. Three similar effects under the Build Alternative compared to
noise walls recommended for the No Build Alternative.
construction under the Build
Alternative would result in
lower highway noise levels for
nearby residences in
unincorporated Clackamas
County and West Linn.
Air Quality Lower overall emissions of air Air Quality API No No No adverse effect on environmental justice
pollutants in 2027 and 2045 populations. Both the general population and
under the Build Alternative environmental justice populations would experience
compared to the No Build similar benefits under the Build Alternative compared
Alternative. to the No Build Alternative.
Ability to Use Potential technological and Social Resources Yes Yes Potential adverse effect on environmental justice
Electronic Toll financial barriers associated and populations. The electronic toll system could create
System with an electronic, cashless toll Communities/ barriers for the unbanked population and for those who
system under the Build Environmental do not have access to conventional financial services,
Alternative. Justice API which could include members of environmental justice
communities.
API = Area of Potential Impact; I-205 = Interstate 205; LOS = level of service; OR = Oregon Route

I-205 Toll Project

ODOT would implement the actions summarized in Table 3-41 to avoid, minimize and/or mitigate effects
on environmental justice populations.
Table 3-41. Summary of Mitigation Measures to Address Adverse Effects on Environmental

Justice Populations
Effect Mitigation Measure
The Project could increase transportation • As part of the Oregon Toll Program development, ODOT has
costs as a percentage of overall committed to providing a low-income toll program when tolling
household spending for all drivers, which begins. ODOT presented an approach for developing a low-
would be higher for low-income drivers, income toll program in the Low-Income Toll Report submitted to
particularly those at or below the federal the Oregon Transportation Commission and Oregon State
poverty level. Legislature in September 2022 (ODOT 2022c).
The report presents options for consideration by the OTC, which
include: (1) providing a substantial toll discount (i.e., credits,
free trips, percentage discount, or tax credit) or a full exemption
for households with incomes equal to or below 200% of the
federal poverty level, (2) providing a smaller, more focused toll
discount for households with incomes above 200% and up to
400% of the Federal Poverty Level, and (3) using a verification
process that leverages existing low-income service programs or
exploring self-certification to qualify for enrollment.
Next steps for the low-income toll program include the following:
- Continuing partner and public engagement and meetings of
the Equity and Mobility Advisory Committee to inform low-
income toll program development (through at least 2023).
- Development of the back-office system and operations
management to support a low-income toll program (through
2023).
- Establishment of a Statewide Toll Rule Advisory Committee
to develop recommendations for the toll rate-setting process
and for the rules that apply to the low-income toll program
(through the end of 2023).
- Further analysis of income thresholds and discount options
through final traffic and revenue studies (through 2024 for
the I-205 Toll Project).
- Adoption of toll rates and rules for the I-205 Toll Project by
the Oregon Transportation Commission (in mid-2024).
- Ongoing monitoring after tolling begins to ensure it is
meeting equity and project goals (starting in 2024).
Toll evasion enforcement could affect • ODOT would establish a toll enforcement policy that addresses
those who cannot pay the toll fees on equity in enforcement of toll evasion and/or late payments.
time by imposing additional late fees.
Two intersections in areas with a greater • Transportation impacts would be mitigated as specified in
percentage of environmental justice Section 3.1.4.
populations than the county as a whole
would experience worse traffic
operations under the Build Alternative
than under the No Build Alternative in
2027 and/or 2045: the I-5 southbound
ramps and Nyberg Street intersection in
Tualatin and the OR 99E and Ivy Street
intersection in Canby.

I-205 Toll Project
Effect Mitigation Measure

Six intersections in Oregon City would • Impacts would be mitigated as specified in Section 3.1.4.
experience worse traffic operations under
the Build Alternative than under the No
Build Alternative in 2027 and/or 2045,
which would in turn affect how
environmental justice populations access
social services in the downtown area of
Oregon City.
OR 99E between 11th Street and Main • Impacts would be mitigated as specified in Section 3.1.4.
Street, which is in Oregon City near
social resources that serve
environmental justice populations, would
experience worse pedestrian LOS in
2045.
Three intersections in areas with higher • Impacts would be mitigated as specified in Section 3.1.4.
environmental justice concentrations in
Canby, Gladstone, and Tualatin would
experience safety impacts in 2027 and/or
2045. OR 99E, which has segments that
cross through areas in Canby and
Gladstone with higher concentrations of
environmental justice populations, would
have more crashes under the Build
Alternative in 2027 and 2045.
Potential barriers for unbanked • A cash-based option for paying tolls would be established.
populations in accessing a cashless toll
• Permanent customer service centers would be established
system and technological barriers related
across the region and within environmental justice communities.
to the electronic toll system.
These centers would be available for assistance over the phone
and in-person so drivers can use cash to purchase
transponders, pay invoices, and establish prepaid accounts.
• Customer service centers would also provide assistance
navigating the toll system and answers to questions related to
how the toll system works.
ODOT = Oregon Department of Transportation; MMLOS = multimodal level of service
3.8.5 Preliminary Environmental Justice Determination

This section provides a preliminary determination of the effects of the Build Alternative on low-income
and/or minority populations as described in EO 12898, consistent with the FHWA guidance memorandum
on Environmental Justice and NEPA, and other U.S. Department of Transportation and FHWA orders.
Since the start of the Project, ODOT has regularly reached out to and gathered input from environmental
justice populations. Chapter 4 identifies the Equity-Focused Engagement that occurred for the I-205 Toll
Project and Appendix J, I-205 Toll Project Environmental Justice Technical Report Attachment F, includes
a list of the specific outreach activities to environmental justice populations and summarizes issues and
topics discussed.
There would be no physical impacts (e.g., displacements or relocations) for environmental justice
populations. Any temporary increases in noise and dust in and near the construction areas would be
minor and would be minimized by construction BMPs. Construction areas would not be located adjacent
to areas with higher concentrations of environmental justice populations than their respective counties as
a whole. For these reasons, environmental justice populations would not experience any
disproportionately high and adverse construction effects.

I-205 Toll Project
The Build Alternative would have long-term, direct beneficial effects by reducing future congestion and
delays on I-205 as compared to the No Build Alternative on a critical regional transportation corridor for
the movement of people and goods. Environmental justice populations would experience slightly
improved access to jobs, community places, and medical facilities as compared to the No Build
Alternative and the general population. Environmental justice populations would also experience shorter
travel times along routes that include the tolled bridges on I-205 as compared to the No Build Alternative.
Environmental justice populations could experience delays and higher congestion levels on some local
streets that have worse operations under the Build Alternative: these effects would be addressed through
proposed transportation mitigation measures listed in Table 3-41. Although the Build Alternative would
result in adverse effects on households at or below the federal poverty level because of higher
transportation costs with the toll, these effects would be mitigated through implementation of a statewide
low-income toll program, as described in Table 3-41.
Specifically, a sizeable toll discount (e.g., credits, free trips, percentage discount or full exemption) would
help alleviate the burden of choosing between paying a toll and meeting basic needs for households with
incomes equal to or below the 200% federal poverty level. This option is strongly supported by the Equity
and Mobility Advisory Committee and by community members who participated in the focused public
engagement process (ODOT 2022c). An initial evaluation found that a monthly credit and a specific
number of free trips scored the highest (compared to percentage discount and full exemption) when
considering benefits for users, costs, operational impacts, and feasibility. Credits and free trips scored
higher than a percent discount because these options provide a possibility that program participant
accounts would not require a balance or a debit or credit card on file. These requirements can serve as
major barriers to program enrollment. In addition, credits and free trips allow users to make occasional
emergency or high-priority trips for free on the tolled roadway. Additional analysis and engagement are
needed to assess income thresholds and identify the discount type.
After considering the totality of the Build Alternative’s impacts, benefits, and associated mitigation, there
has been a preliminary determination that the Build Alternative would not result in disproportionately high
and adverse effects on any low-income population or minority population in accordance with the
provisions of EO 12898 and the FHWA guidance memorandum on Environmental Justice and NEPA.
3.9 Land Use

The land use API, which extends 100 feet beyond the I-205 right-of-way, includes area within the limits of
the City of West Linn, the City of Oregon City, and Clackamas County. Most of the land within the API has
been developed with I-205 infrastructure that includes travel lanes, shoulders, on- and off-ramps, and
vegetated medians. The API within Oregon City contains land zoned mixed-use, industrial, and road. In
West Linn, the right-of-way does not have a zoning designation. Outside of the right-of-way within the API
in the City of West Linn there is a mix of residential, commercial, mixed-use, and industrial zones. In
Clackamas County, the API has a rural zoning designation. Appendix K, I-205 Toll Project Land Use
Technical Memorandum, provides more detailed information about the API and methodology for this
analysis.
The following planning documents apply to land within the land use API:
• Applicable provisions of Oregon’s Statewide Planning Program
• Oregon Highway Plan and Amendments (ODOT 1999)
• Oregon Transportation Plan (ODOT 2006)

I-205 Toll Project
• Oregon City Comprehensive Plan (City of Oregon City 2022)

• Oregon City Transportation System Plan (City of Oregon City 2013)
• West Linn Comprehensive Plan (City of West Linn 2016a)
• West Linn Transportation System Plan (City of West Linn 2016b)
• Clackamas County Transportation System Plan (Clackamas County 2022b)
• Metro 2018 Regional Transportation Plan (Metro 2018a)
• Metro 2018 Urban Growth Management Functional Plan (Metro 2018d)
• ODOT 2021-2024 Active State Transportation Improvement Plan (ODOT 2020a)
• Stafford Hamlet Community Vision Plan (Stafford Hamlet 2020)
The API contains three parks, two school lands, one recreational area, two water trails, and three land-
based trails (Metro 2022). The three parks (West Bridge Park, McLean Park and House, and Jon Storm
Park), recreational area (Sportcraft Landing), two of the land-based trails (sections of the Willamette River
Greenway trail system in Oregon City and West Linn), and two water trails (Willamette River Water Trail
and Tualatin River Water Trail) have been designated as Section 4(f) properties,55 and two are also
considered Section 6(f) properties56 (McLean Park and House and Sportcraft Landing). McLean Park and
House is also a historic site that is individually eligible for listing on the National Register of Historic
Places. In addition, there are four historic properties in the API that are Section 4(f) resources as they are
eligible for listing on the National Register of Historic Places: the Historic West Linn City Hall and the Lynn
View Apartments, which are eligible individually; and the Burnham-Derr House and Hallowell-Robinson
House, which are eligible as part of a historic district. Section 4(f) and Section 6(f) resources and
properties in the API are shown in Figure 3-17.
55
Section 4(f) of the U.S. Department of Transportation Act of 1966 requires the consideration of the use of publicly
owned park and recreational lands, wildlife and waterfowl refuges, and historic sites in transportation project
development (FHWA n.d.-b). The U.S. Department of Interior designated the Willamette River as a National Water
Trail in 2007 and the Tualatin River as a National Water Trail in 2020 (U.S. Department of the Interior 2007; City
of Tualatin 2020). National Water Trails have been established to protect and restore rivers, waterways and
shorelines, as well as increase access to outdoor recreation on rivers, waterways, and shorelines (National Park
Service 2020). Public rivers which are designated as recreational trails are subject to the requirements of Section
4(f) (FHWA n.d.-c). Section 4(f) applies to publicly-owned, shared use paths or trails (or portions thereof)
designated or functioning primarily for recreation, unless the official with jurisdiction determines that it is not
significant for such purpose (FHWA n.d.-d). The primary purpose of the Willamette River greenway trails is
recreation; therefore, the greenway trails in the API are considered Section 4(f) resources.
56
Section 6(f) of the Land and Water Conservation Fund Act of 1964 requires that the conversion of lands or
facilities acquired with Land and Water Conservations Funds be approved by the National Park Service (FHWA
n.d.-c).

I-205 Toll Project
Figure 3-17. Section 4(f) and Section 6(f) Resources and Properties in the Area of Potential
Impact
The API includes various environmentally sensitive areas, including wetlands, streams, rivers, and
riparian areas. Under Title 13 of Metro’s Urban Growth Management Functional Plan, local jurisdictions
are required to designate Habitat Conservation Areas, which generally include rivers, streams, wetlands,
and adjacent resource areas, as well as upland wildlife habitat patches and habitats of concern (Metro
2018d). In addition, as part of its compliance with Goal 5 of the Oregon Statewide Land Use Planning
Goals, 57 West Linn has collectively designated streams, wetlands, and Significant Riparian Corridors as
Water Resource Areas (City of West Linn 2014). Local jurisdictions regulate development within Habitat
Conservation Areas as well as development within wetlands, streams, and rivers along with state and
federal agencies. See the Appendix P, I-205 Toll Project Wetlands and Water Resources Technical
Memorandum, and Appendix O, I-205 Toll Project Vegetation and Wildlife Technical Memorandum, for
information on the location of these environmentally sensitive areas within the API.
57
Goal 5 (Natural Resources, Scenic and Historic Areas, and Open Spaces) of the Oregon Statewide Land Use
Planning Goals requires local governments to develop inventories of natural resources, scenic and historic areas,
and open spaces and implement plans and policies to protect these resources, areas, and spaces (DLCD 1997).

I-205 Toll Project

Under the No Build Alternative, no activities would occur that would affect land use. The No Build
Alternative would generally not be consistent with applicable state, regional, and local transportation and
land use laws, plans, and policies, as described in more detail in Appendix K, I-205 Toll Project Land Use
Technical Memorandum.
Build Alternative
Short-Term Effects
Temporary construction easements totaling 4,515 square feet would be needed for the replacement of
the West A Street Bridge and removal of the Broadway Street Bridge. The easements would be on four
privately owned parcels located in West Linn that are zoned general commercial and residential, as
shown in Figure 3-18. Temporary construction easements would not constitute a conversion of land to
transportation use because the land would be used temporarily for construction purposes and not
permanently converted to right-of-way. Construction activities for the toll gantries and supporting
infrastructure would occur entirely within I-205 right-of-way and would not result in a conversion of land to
transportation use.
During construction, an approximately 0.1-mile portion of the Tualatin River Water Trail, a Section 4(f)
resource, would be temporarily affected during the removal and replacement of the two existing
northbound and southbound I-205 bridges over the Tualatin River. Construction activities for the
replacement bridges would require installation of temporary work bridges, including pilings occupying a
total of about 3,000 square feet in the Tualatin River. During construction, a minimum width of 30 feet of
the river would remain open to recreational users except for intermittent short-term full closures of the
river in the construction area. The overall duration of work in the Tualatin River would be approximately
2.5 years. During that time, there would be a total of approximately 20 weeks of full river closures, with
each closure lasting 1 to 2 weeks. Compared to the full Project construction time of approximately 4
years, the cumulative river closure time of approximately 20 weeks is of short duration. Additionally, the
closures would be limited to the area directly beneath and adjacent to the existing Tualatin River Bridges
and would be small compared to the remaining undisturbed length of the Tualatin River Water Trail (about
38.5 miles). Upon completion of construction, any temporary changes to the physical condition of the trail
resulting from construction activities would be restored.
The construction activities in the Tualatin River Water Trail would meet the criteria for a Section 4(f) de
minimis impacts under Section 23 Code of Federal Regulations (CFR) 774.17. Use of a Section 4(f)
property occurs when: (1) land is permanently incorporated into a transportation project; (2) there is a
temporary occupancy of land that is adverse in terms of the statute's preservation purpose; or (3) there is
a constructive use (a project's proximity impacts are so severe that the protected activities, features, or
attributes of a property are substantially impaired) (FHWA n.d.-b). De minimis impacts for public parks,
recreation areas, and wildlife and waterfowl refuges are defined as those that do not “adversely affect the
features, attributes, or activities qualifying the property for protection under Section 4(f).” A de minimis
impact determination is based on the degree or level of impact on a Section 4(f) property, including any
avoidance, minimization, mitigation, or enhancement efforts that are included in a project to address the
Section 4(f) use. The determination of a de minimis impact on the Tualatin River Water Trail requires
concurrence from the Tualatin Riverkeepers, the official with jurisdiction. ODOT will work with the Tualatin
Riverkeepers to obtain this concurrence.

I-205 Toll Project
With the exception of the Tualatin River Water Trail, access to all parks, school lands, recreational areas,
land-based trails, and water trails within and near the API would be maintained during construction of the
Build Alternative. No other Section 4(f) resources would be affected by construction. In addition, the Build
Alternative would also not result in any conversion of a Section 6(f) property. No construction staging
would occur on a Section 4(f) or Section 6(f) property.
The Build Alternative would have impacts on Goal 5 resources in the API, such as wetlands, streams,
rivers, and riparian areas. Impacts would be regulated through local land use processes (as well as state
and federal processes for impacts on wetlands, streams, and rivers) and would be mitigated as required
by the jurisdiction. Therefore, no goal exception would be required as the Project would meet
jurisdictional permitting requirements which allow impacts on Goal 5 resources with mitigation. See
Section 3.13 and Section 3.14 for more information on these impacts and mitigation. The City of West
Linn has permitted impacts on Water Resource Areas and Habitat Conservation Areas from the I-205
widening associated with Phase 1A between the area just east of OR 43 to the 10th Street intersection.
Additional impacts on Water Resource Areas and Habitat Conservation Areas west of the 10th Street
intersection from the widening as well as the toll gantries and supporting infrastructure would be avoided
to the extent practicable and, if determined to be unavoidable as the Project design progresses, would be
permitted through separate land use processes.
Long-Term Effects
As shown in Figure 3-18, the Build Alternative would require the permanent conversion of 415 square feet
of land on portions of two privately owned parcels to transportation use for the replacement of the West A
Street Bridge and to facilitate the I-205 widening. Both parcels are currently zoned general commercial.
The land that would be converted to right-of-way is currently vacant. One 107-square-foot permanent
easement would also be required from a portion of a privately owned residential parcel. The toll gantries
and supporting infrastructure would be located entirely within I-205 right-of-way; therefore, no long-term
effects on land use would occur from this infrastructure.

I-205 Toll Project
Figure 3-18. Land Use Impacts
Because the conversion of land would be relatively small and there is a sufficient amount of land in the
area to absorb the reduction, no long-term effects on land use would occur under the Build Alternative. All
right-of-way acquisitions would be done in accordance with the Uniform Relocation Assistance and Real
Property Acquisition Policies Act of 1970, as amended, and Chapter 35 of the Oregon Administrative
Rules – Eminent Domain; Public Acquisition of Property.
The physical components of the Build Alternative generally are consistent with applicable state, regional,
and local transportation and land use laws, plans, and policies, as described in more detail in Appendix K,
I-205 Toll Project Land Use Technical Memorandum.
Under the Build Alternative, there would be no permanent incorporation or constructive use of a Section
4(f) property, or a conversion of a Section 6(f) property to a transportation use; therefore, no long-term
impacts on Section 4(f) and Section 6(f) properties would occur. FHWA guidance notes that a
constructive use does not occur “when noise resulting from the project does not approach or exceed the
FHWA noise abatement criteria or when it is considered a barely perceptible increase over existing levels”
(FHWA n.d.-b). As documented in the I-205 Toll Project Noise Technical Report, noise levels in 2045
would exceed ODOT noise criteria at Jon Storm Park, a Section 4(f) resource; however, existing noise
levels also exceed impact criteria, and the Project would not result in a perceptible noise increase

I-205 Toll Project
compared to existing conditions. A noise wall was evaluated to mitigate noise levels at and near Jon
Storm Park and the Section 4(f) resources on the west side of the Willamette River but did not meet
ODOT’s criteria for a feasible and reasonable noise wall. Similarly, modeled noise levels would approach
or exceed noise criteria at some areas within 250 feet of I-205 near Stafford Road and the Tualatin River.
Noise walls at these locations were also found to be infeasible due to their proximity to I-205 and lack of
other nearby noise-sensitive land uses. Modeled noise levels in 2045 at the three Section 4(f) historic
sites on the west side of the Willamette River were below impact criteria.
At the Tualatin River Water Trail crossing under I-205, removal of the existing columns for the I-205
Tualatin River Bridges would open up more space closer to the banks of the river, and the new bridge
piers would be located closer to the middle of the river. However, because the piers would occupy the
same overall amount of space as the existing bridges, there would be no permanent changes in the
amount of space in the river available for recreational uses, and the physical condition of the trail would
be similar to how it was prior to construction. Trail users would benefit from having access to a single
channel that is approximately 50 feet wider, depending on water levels, than existing conditions.
Therefore, there would be long-term physical improvements and no adverse long-term physical impacts
on the water trail.

Table 3-42 provides a comparison of anticipated land use effects by alternative.
Table 3-42. Summary of Land Use Effects by Alternative

Short-Term • None • 4,515 square feet of temporary construction easements
• De minimis impacts on the Tualatin River Water Trail
Long-Term • None • Conversion of 415 square feet of private property to right-of-way
• 107-square-foot permanent easement on private property

No short-term or long-term impacts on land use would occur under the Build Alternative; therefore, no
avoidance, minimization, and/or mitigation measures are proposed.
3.10 Geology and Soils

The geology and soils API, which extends 100 feet beyond the I-205 right-of-way, lies within the Portland
and Tualatin basins, which were formed more than 6 million years ago during the Missoula Floods
(Beeson et al. 1991). The Columbia, Willamette, and Clackamas Rivers converge within the Portland
Basin and, with their tributaries, have contributed to extensive alluvial and sedimentary rock that overlies
basalt. Within the API, I-205 is partially located in a channel scabland eroded by the Missoula Floods
(Burt et al. 2009). The exposed geologic units along the I-205 rock cuts are composed of Columbia River
Basalt Group lava flows. Mapped geologic units within the API consist of fill, fine-grained Missoula Floods
deposits, and sentinel bluffs Grande Ronde basalt.
Oregon is located within the Cascadia Subduction Zone, a fault line that is a source of substantial
earthquakes greater than magnitude 8 about every 500 years (Atwater and Hemphill-Haley 1997);
however, the last earthquake of this magnitude occurred in 1700 (Satake et al. 1996; Atwater and
Hemphill-Haley 1997). Cascadia Subduction Zone seismic hazards include ground shaking, liquefaction

I-205 Toll Project
and its associated effects, ground surface fault rupture, and tsunami that could result in damage to or
failure of the existing bridges along I-205.
Appendix L, I-205 Toll Project Geology and Soils Technical Memorandum, provides more detailed
information about the API and methodology for this analysis.

Under the No Build Alternative, without the seismic upgrades and replacements of the I-205 bridges, a
Cascadia Subduction Zone earthquake would likely result in damage to the bridges and surrounding
infrastructure, making this section of I-205 impassable and hindering regional emergency response
immediately following the earthquake. Inadequate transportation access would prolong overall recovery
from the earthquake.
Build Alternative
Short-Term Effects
During construction, excavation of soils would be required at various bridge foundations, along the
roadway, and at the tolling gantry areas. Excavated soils that are stored on site and other areas of soil
disturbance could experience erosion from wind or stormwater. Soils would be compacted by machinery
and storage of materials. An erosion and sediment control plan that would identify BMPs, such as
installing erosion controls, temporary seeding, and delineating disturbance limits, would be implemented
during construction to minimize or prevent erosion of soils.
In-water work would be required in the Tualatin River. Drilled shafts anticipated at the Tualatin River
Bridges would be constructed using fully cased excavations due to the potentially expansive clay soil
types at the river. Other areas of excavation performed within the Tualatin River would likely be contained
within a cofferdam during construction. Both activities could mobilize sediment during construction. The
placement of new piers within the Tualatin River could also modify localized scour and result in temporary
sediment migration and turbidity. BMPs such as turbidity monitoring and the use of turbidity curtains or
cofferdams would be implemented to minimize these effects.
A rock cut would be required along a portion of the existing rock cut adjacent to I-205 northbound, from
the Broadway Bridge (I-205 MP 8.69) to southwest of the Sunset Avenue Bridge (I-205 MP 8.38). Blasting
would be required to move the rock cut face 35 to 40 feet south of the existing rock face for a total length
of approximately 2,565 feet (Figure 3-19). Blasting of rock creates ground vibrations that could potentially
damage nearby structures such as houses and render a nearby cell tower temporarily inoperable if not
properly planned. A blasting plan for the rock cut would be implemented to limit the timing, sequence, and
force of each blast and minimize the possibility of damage or harm to nearby structures. Ground
vibrations would be monitored to ensure maximum vibrations are not exceeded. The construction
contractor would use rock fall barriers to control rock migration.
All excavation, pile driving, shaft installation, and other foundational work associated with construction of
the improvements would adhere to the Oregon Standard Specifications for Construction (ODOT 2021c).

I-205 Toll Project
Figure 3-19. Rock Cut Limits
Long-Term Effects
Under the Build Alternative, bridges along I-205 in the API would be reconstructed or replaced and
designed to withstand a Cascadia Subduction Zone earthquake. The expanded rock cut along I-205
northbound (on the south side of the highway) would modify the slope angles of the rock face, increasing
its stability. It would also provide a catchment area sufficient for retention of 90% of all rockfall and 99%
retention of free-falling rocks, thereby improving safety along the northbound corridor (Shannon & Wilson
2020).

I-205 Toll Project

Table 3-43 provides a comparison of anticipated effects on geology and soils by alternative.
Table 3-43. Summary of Geology and Soils Effects by Alternative

Short-Term • None  Potential soil compaction and erosion during
construction
 Disturbance of soils during excavation
• Potential sediment migration and turbidity during in-
water work
Long-Term • Potential bridge failures along I-205 • Improved bridges and foundations along I-205 that
after a Cascadia Subduction Zone would reduce the potential of bridge failure after a
earthquake Cascadia Subduction Zone earthquake
• Improved stability of rock cut; improved safety from
rock falls

Construction contractors would be required to develop and implement an erosion and sediment control
plan with BMPs to reduce the potential for soil erosion. No additional mitigation for construction is
required. There would be no long-term impacts on geology and soils under the Build Alternative, and the
Build Alternative would result in long-term benefits for seismic resilience and rock stability; therefore, no
avoidance, minimization, and/or mitigation measures are proposed.
3.11 Hazardous Materials

Hazardous materials investigations identified 46 sites of concern58 near or within the hazardous material
API, which extends 100 feet beyond the I-205 right-of-way (HDR 2018c; 2020a, 2020b; Reynolds
Engineering 2020). Of the 46 identified sites, only two are located in the API: they are near the Willamette
Falls Drive and OR 43 intersection.
The Project is an active automobile and truck travel corridor where unknown spills and releases may have
occurred. Soil sampling was completed in 2020 at the sites of concern that were identified in the
Hazardous Materials Corridor Study as having a moderate risk of contamination (HDR 2020a). Most
samples were within the DEQ clean fill criteria,59 except for several detections of total metals, including
copper, antimony, and lead, that exceeded clean fill criteria. Although above clean fill criteria, the sampled
soils were below the DEQ Excavation Work Risk Based Concentrations and could be reused in the right-
of-way away from stormwater inlets and erosional areas. Soil sampling was also completed within the
upper 18 inches of unpaved shoulder areas along I-205. The investigation identified soils that would be
considered clean fill, have levels of total metals above clean fill criteria, and exceed DEQ Risk Based
Concentrations for total arsenic, in which potential contamination is possible.
58
A site of concern is defined as a site with known or suspected hazardous materials contamination that could
potentially migrate to areas where construction activity or property acquisition could occur. Sites of concern have
sufficient possibility of contamination to warrant additional investigations.
59
"Clean fill means material consisting of soil, rock, concrete, brick, building block, tile or asphalt paving, which do
not contain contaminants which could adversely impact the waters of the State or public health” (OAR 340-093-
0030, Solid Waste General Provisions).

I-205 Toll Project
A structure survey completed in 2020 (Reynolds Engineering 2020) identified asbestos-containing

materials at the Sunset Avenue, West A Street, and Broadway Street bridges. Paint containing lead was
identified at all of the bridges; however, the concentrations detected are below the regulatory threshold for
hazardous waste.
Appendix M, I-205 Toll Project Hazardous Materials Technical Memorandum, provides more detailed

Under the No Build Alternative, no ground disturbance of existing soils nor demolition of any structures
would occur to expose unknown contaminated soils or hazardous materials. Under the No Build Alternative,
no cleanup of contamination of known hazardous materials would occur, and these materials would remain
in the API. Additionally, because of projected higher traffic congestion levels and degraded traffic operations
under the No Build Alternative, the likelihood of spills related to vehicular crashes would increase.
Build Alternative
Short-Term Effects
Under the Build Alternative, construction activities such as excavation and structure demolition could
expose contaminated soils and materials. Accidental spills of hazardous materials from construction
machinery would also be a risk during construction. In-water work at the Tualatin River Bridges could
result in contamination of waters during construction from structure demolition and potential spills.
During construction, BMPs such as proper materials and waste management, daily inspection of heavy
equipment, and preparation of hazardous waste determinations would be implemented to reduce the risk of
accidental spills, prevent pollution, and protect existing wetlands and waterbodies. Hazardous materials
such as asbestos-containing materials would be disposed of at an approved disposal site, while soils that
contain contaminants at concentrations greater than DEQ clean fill levels, but less than DEQ’s occupational
risk-based concentrations, would be disposed of in the ODOT right-of-way. The contractor would prepare
Project-specific plans such as a Contaminated Media Management Plan, Asbestos Abatement Plan, and
Pollution Control Plan prior to construction. Hazardous materials would be handled and disposed of
according to state and federal regulations, as well as the ODOT HazMat Program Manual (ODOT 2020b).
No construction activities would occur on or near the two sites of concern in the API.
Long-Term Effects
Some surface soils down to 18 inches below ground surface contain contaminants that are above DEQ’s
Clean Fill Standards but below the DEQ Excavation Worker Risk Based Concentrations (HDR 2020b).
These soils would be disposed of within ODOT-owned right-of-way or a regulated disposal site. Asbestos-
containing materials and lead paint would be removed and properly disposed of at an approved off-site
hazardous waste disposal site. This would remove hazardous materials from the API, creating a long-
term net benefit in the API. In addition, under the Build Alternative, traffic operations would improve,
which would likely reduce vehicular collisions and, therefore, reduce the potential for spills of hazardous
materials.

Table 3-44 provides a comparison of anticipated hazardous materials effects by alternative.

I-205 Toll Project
Table 3-44. Summary of Hazardous Materials Effects by Alternative

Short-Term • None • Encountering hazardous materials and risk of
accidental spills during construction
Long-Term • Potential increase in vehicular spills from • Removal and disposal of hazardous materials
worsening traffic operations on I-205 • Reduction of accidental vehicular spills due to
improved traffic operations along I-205

Construction contractors would be required to implement BMPs to minimize the potential for hazardous
materials release. No additional mitigation for construction is required. There would be no long-term
impacts related to hazardous materials under the Build Alternative, and the Build Alternative would result
in long-term benefits related to removal and reduction of hazardous materials; therefore, no avoidance,
minimization, and/or mitigation measures are proposed.
3.12 Historic and Archeological Resources

Historic resources are buildings, structures, sites, or places older than 45 years of age and significant in
history, architecture, and/or culture. Archaeological resources include the physical remains of human
activity that are 50 years of age or older and that provide important information about the past. In
accordance with Section 106 of the National Historic Preservation Act of 1966, FHWA and ODOT must
consider the effects of the Project on these resources.
The area of potential effects for historic and archaeological resources includes the areas along I-205 that
would be affected by construction activities and new structures associated with the Build Alternative.
ODOT conducted a survey in 2017 that identified 34 historic resources in the Project’s area of potential
effects, five of which are considered eligible for the National Register of Historic Places (HDR 2018d). The
five eligible resources are in West Linn.
Previous surveys documented multiple archaeological sites that lie partly within the area of potential
effects; however, these sites are no longer intact or were determined to not be significant, and no other
known archaeological sites are located in the area of potential effects (Connolly 2018).
Appendix N, I-205 Toll Project Historic and Archaeological Resources Technical Memorandum, provides
more detailed information about the API and methodology for this analysis.

Under the No Build Alternative, no historic resources would be affected. No ground-disturbing activities
would take place, avoiding any potential impacts on unidentified archaeological resources.
Build Alternative
Short-Term Effects
The Abernethy Bridge toll gantry area would be in the same vicinity of the five eligible historic resources;
however, these resources would not be affected by the construction of the Build Alternative. Construction
activities for the Abernethy Bridge toll gantries and supporting infrastructure would occur entirely within

I-205 Toll Project
ODOT right-of-way and would not result in any physical damages or alterations to any of the eligible
historic resources, or result in any temporary effects (e.g., traffic detours, noise, visual elements,
emissions, or dust) that would diminish the historic significance of the eligible historic resources.
Because no intact or significant archaeological resources were identified, no effects are anticipated as a
result of the Build Alternative. An inadvertent discovery plan would be developed prior to construction that
would describe steps to take if cultural resources are identified during construction of the Build
Alternative. If archaeological resources are encountered during construction of the Build Alternative, all
work in the vicinity of the finds would cease immediately and the Oregon SHPO, ODOT, affected tribes,
and other appropriate parties and agencies would be promptly notified, and Oregon Revised Statute
358.920 and 36 Code of Federal Regulations 800.13 would be consulted to ensure compliance with
applicable state and federal laws.
Long-Term Effects
No long-term effects on historic and archaeological resources are anticipated from the Build Alternative.
The Project used Stipulation 4C of the 2011 Section 106 Programmatic Agreement (FHWA 2011), which
allows ODOT to act on behalf of FHWA during Oregon SHPO consultation and provide documentation
and evaluation of historic resources. Upon evaluation of the Project effects on the five eligible historic
resources in the APE, ODOT issued a Finding of No Adverse Effect (36 C.F.R. 800.5[b]) on historic
resources for the Project and sent a letter to Oregon SHPO on December 22, 2022, requesting
concurrence with this finding. Oregon SHPO concurred with ODOT’s finding on December 23, 2022 (see
Appendix N, I-205 Toll Project Historic and Archaeological Resources Technical Memorandum).

Table 3-45 provides a comparison of anticipated effects on historic and archaeological resources by
alternative.
Table 3-45. Summary of Historic and Archaeological Resources Effects by Alternative

Short-Term • None • Potential discovery of previously unidentified
archaeological resources
Long-Term • None • None

Construction contractors would be required to prepare and implement an inadvertent discovery plan that
includes prescribed actions to be taken in the event that unanticipated cultural resources are discovered.
There would be no long-term impacts related to historic and archaeological resources under the Build
Alternative; therefore, no avoidance, minimization, and/or mitigation measures are proposed.

I-205 Toll Project
3.13 Vegetation and Wildlife

Existing vegetation in the vegetation and wildlife API, which extends 100 feet beyond the I-205 right-of-
way, includes maintained herbaceous vegetation in the highway median and along the shoulders, as well
as patches of deciduous forest and scrub-shrub vegetation (see Appendix O, I-205 Toll Project
Vegetation and Wildlife Technical Memorandum). Most of the API is paved or unvegetated. Many of the
plant species found throughout the API are invasive species (Oregon Department of Agriculture 2020),
including Himalayan blackberry (Rubus armeniacus), reed canary grass (Phalaris arundinacea), and
English ivy (Hedera helix).
A June 2017 plant survey identified locations of white rock larkspur (Delphinium leucophaeum), which is
listed as a species of concern by the United States Fish and Wildlife Service (USFWS). No plant species
listed as threatened or endangered under the Endangered Species Act were identified (ODOT 2017).
Some areas within the API have been designated as Habitat Conservation Areas under Metro’s Urban
Growth Functional Plan, Title 13 - Nature in Neighborhoods (Metro 2018d). Generally, Habitat
Conservation Areas include rivers, streams, wetlands, and adjacent resource areas, as well as wildlife
habitat patches and habitats of concern (City of Portland 2020). In addition, West Linn has designated
Significant Riparian Corridors, several of which occur along streams in the API. Local jurisdictions
regulate development in Habitat Conservation Areas and Significant Riparian Corridors.
Wildlife in the API includes both terrestrial and aquatic species. Although existing vegetation in the API is
limited, it provides potential habitat for small mammals and amphibians, both native and invasive,
including raccoons (Procyon lotor), western gray squirrels (Sciurus griseus), nutria (Myocastor coypus),
brown rats (Rattus norvegicus), river otters (Lutra canadensis), opossums (Didelphis virginiana),
American bullfrogs (Lithobates catebeianus), red-eared slider (Trachemys scripta elegans), and rough-
skinned newts (Taricha granulosa). ODOT has determined there is no suitable habitat for Endangered
Species Act-listed terrestrial species in the API (ODOT 2017).
Field investigations were conducted in November and December 2017 to evaluate the potential for
migratory birds and bats listed under the Endangered Species Act to occur in the API (HDR 2018e).
Several species of bats are listed as sensitive species in Oregon. No bats, roosts, or suitable habitat were
identified. Bird species protected under the Migratory Bird Treaty Act are expected to be found in the API
in habitat areas that are contiguous or adjacent to a larger habitat area. Species observed during the field
investigations included song sparrow (Melospiza melodia), scrub jay (Aphelocoma californica), spotted
towhee (Pipilo maculatus), and Steller’s jay (Cyanocitta stelleri).
Multiple anadromous species of fish listed under the Endangered Species Act are found in the API within
the Tualatin and Willamette Rivers, as well as essential salmonid habitat 60 and species on Oregon’s
sensitive species list, 61 as shown in Table 3-46.
60
Oregon’s essential salmonid habitat designation protects the waterbodies where salmonid species lay eggs and
where juvenile fish grow before traveling to the ocean (DSL n.d.).
61
To provide a proactive approach to species conservation, a “sensitive” species classification was created under
Oregon’s Sensitive Species Rule (OAR 635-100-0040) to prevent species from declining to the point of qualifying
as threatened or endangered under the Endangered Species Act (ODFW n.d.).

I-205 Toll Project
Table 3-46. Anadromous Fish Species and Habitats of Concern in the Area of Potential Impact
Species Listing
Upper Willamette River Chinook salmon Endangered Species Act
Lower Columbia River Coho salmon Endangered Species Act
Upper Willamette Steelhead Endangered Species Act
Pacific lamprey Oregon Sensitive Species List
Coastal cutthroat trout Oregon Sensitive Species List
Winter steelhead Oregon Essential Salmonid Habitat
Fall and spring Chinook salmon Oregon Essential Salmonid Habitat
Sources: Endangered Species Act species: National Oceanic and Atmospheric Administration National Marine
Fisheries Service endangered species list (NMFS 2022)
Oregon Sensitive Species list: Oregon Department of Fish and Wildlife Sensitive Species List FAQ‘s
(ODFW 2021)
Essential salmonid habitat: Oregon Department of State Lands essential salmonid habitat map (DSL
2022)
Appendix O, I-205 Toll Project Vegetation and Wildlife Technical Memorandum, provides more detailed

Under the No Build Alternative, no construction activities or in-water work would occur; therefore,
vegetation, terrestrial species, or aquatic species would not be affected.
Build Alternative
Short-Term Effects
Construction of the Build Alternative would require in-water work to replace the bridges over the Tualatin
River. Temporary piles would be required to support work bridges, causing hydroacoustic effects that can
disturb, injure, or result in direct mortality of fish. Installation of drilled shafts needed for the new bridge
supports could result in short-term increased turbidity. During construction, temporary piles in the Tualatin
River would occupy approximately 3,000 square feet, temporarily displacing potential aquatic habitat.
However, the piles would be removed after bridge construction and the area would be expected to return
to pre-construction conditions.
The Build Alternative would use the Endangered Species Act Programmatic Biological Opinion and
Magnuson-Stevens Act Essential Fish Habitat Response for the Federal-Aid Highway Program in the
State of Oregon (referred to as the FAHP Programmatic) (NMFS 2021), the design standards from the
FAHP Programmatic User Guide (ODOT and FHWA 2016), and the Oregon Standard Specifications for
Construction (ODOT 2021c) to address effects on Endangered Species Act-listed fish species and short-
term water quality effects. In accordance with these documents, BMPs such as fencing off no-work zones,
conducting turbidity monitoring, preventing untreated discharge water, and erosion control measures
would be implemented during construction to reduce effects from in-water removal and fill activities. In-
water work would adhere to the Oregon Department of Fish and Wildlife in-water work window from
June 1 to September 30 to reduce effects on species listed under the Endangered Species Act, unless
otherwise approved by the National Marine Fisheries Service and the Oregon Department of Fish and
Wildlife. During pile driving activities, bubble curtains would be used to reduce hydroacoustic effects.
Appropriate measures would be identified and implemented during permitting to minimize turbidity effects
during in-water work.

I-205 Toll Project
Approximately 60 acres of tree and vegetation removal would occur during construction, potentially
reducing nesting habitat for birds in the vegetation and wildlife API. If migratory bird nests are present,
tree removal would occur outside of the nesting window (March 1 to September 1) to minimize disruption
to migratory birds. After construction, trees would be replaced and vegetated areas that were disturbed
would be restored or replanted. New vegetation would be planted in areas of the corridor where
permanent pavement or other constructed facilities are not located. Some areas of disturbance would not
be planted if the location would be difficult to access and/or maintain by mowing after construction is
completed. In accordance with the FAHP Programmatic design standards, a no-work zone would be
established prior to construction to prevent disturbance of white rock larkspur.
Invasive plant species could spread during construction when equipment moves onto and off of each site,
importing and exporting viable seeds. Invasive species reduce available habitat for native plant species
and do not provide quality resources on which birds and wildlife depend. However, plant materials would
be cleaned from equipment and gear to prevent the spread of invasive species. The construction
contractor would be required to comply with Oregon Standard Specifications for Construction (ODOT
2021c) and the FAHP Programmatic and associated design standards to provide protection to wildlife and
habitat, including performing work within regulated work areas during in-water work windows, preventing
equipment and pollutants from entering habitat, and fencing off no-work zones.
Construction access and traffic control would have a temporary effect on approximately 38,000 square
feet (about 0.9 acre) of wetlands, temporarily reducing habitat for birds and amphibians. These areas
would be restored after construction is completed. Noise and vibration effects from construction
machinery and rock blasting activities could also disturb resident wildlife species that are present during
construction, potentially deterring them from the API. These effects would be temporary and only occur
during construction. Rock blasting is not anticipated to affect Endangered Species Act- and state-listed
species.
Stormwater facilities would be designed in compliance with the FAHP Programmatic and associated
design standards, which would create a net benefit to water quality by treating stormwater that is currently
untreated (see Section 3.14 Wetlands and Water Resources).
ODOT and FHWA are in the process of obtaining FAHP Programmatic approval from the National Marine
Fisheries Service for the Build Alternative.
Long-Term Effects
The new foundations of the Tualatin River Bridges would be constructed in different locations than the
existing foundations. New structures would occupy approximately 1,350 square feet within the river that
could otherwise be used as habitat. However, this habitat loss would be offset by the removal of the
existing foundations that support the bridges, which would create approximately 1,350 square feet of
aquatic habitat, resulting in no net change in available habitat.
Approximately 51,000 square feet (1.2 acres) of wetlands would be permanently filled to support roadway
widening, reducing available wetland habitat for birds, mammals, and amphibians. Additionally,
permanent loss of wetlands could reduce native plant diversity and result in lower water quality support
functions such as sediment retention. Wetland impacts and proposed mitigation are discussed in Section
3.14, Wetlands and Water Resources.
Approximately 863,000 square feet (about 20 acres) of vegetated areas or areas of pervious soil would
be converted to roadway under the Build Alternative. Conversion of pervious surfaces into impervious
surfaces would result in a direct loss of vegetation and available habitat for terrestrial species in the API.

I-205 Toll Project
Because much of the vegetation in the API consists of invasive species (e.g., Himalayan blackberry,
English ivy, reed canary grass), removal of invasive vegetation and the replanting of areas used
temporarily during construction with non-invasive species would improve the quality of the existing
habitat.
The Build Alternative would encroach upon areas designated as Habitat Conservation Areas and
Significant Riparian Areas. Impacts on these areas would be regulated through local land use processes
and would require mitigation based on the location and agency with jurisdiction (see Section 3.9).

Table 3-47 provides a comparison of anticipated effects on vegetation and wildlife by alternative.
Table 3-47. Summary of Vegetation and Wildlife Effects by Alternative

Short-Term • None • Approximately 3,000 square feet of temporary aquatic habitat
impacts from in-water construction piles
• Approximately 0.9 acre of temporary wetland habitat impacts
• Potential hydroacoustic impacts on fish from in-water work
• Noise and vibration disturbance from construction activities
Long-Term • None • Approximately 1.2 acres of wetland habitat filled
• Approximately 20 acres of vegetated areas or areas of pervious
soil converted to impervious surface
• Improved habitat conditions due to removal of invasive species

Construction contractors would be required to comply with mitigation commitments in the FAHP
Programmatic and meet the Oregon Standard Specifications for Construction, which include requirements
to implement BMPs during construction to reduce impacts on vegetation and wildlife. Permanent impacts
on wetlands and waters would be mitigated in accordance with federal, state, and local permits and
approvals, as discussed in Section 3.14.4.
3.14 Wetlands and Water Resources

Water resources in the API include the Tualatin River, Willamette River, McLean Creek, Abernethy Creek,
Athey Creek, Tanner Creek, Wilson Creek, wetlands, and several unnamed streams and ditches (HDR
2019). Within the API, 33 wetlands, 16 waterways, and 4 ditches were determined to be under the
jurisdiction of the USACE and/or Oregon DSL (HDR 2019). Wetlands, rivers, creeks, and streams in the
API may also include regulatory buffers to protect the functions of the water resource. Buffer widths would
vary based on the quality of the resource and surrounding conditions and would be determined during
development permitting. (See also Appendix P, I-205 Toll Project Wetlands and Water Resources
Technical Memorandum.)
Portions of the existing Tualatin River Bridges are located within the active river channel, including two
piers supporting the northbound bridge and two piers supporting the southbound bridge. Many of the
wetlands in the API receive stormwater runoff from the existing roadways. Stormwater runoff from I-205 is
collected through conveyance systems that outfall to the Willamette and Tualatin Rivers and their
tributaries. There are three existing stormwater facilities in the API that treat runoff from a total of 1.49

I-205 Toll Project
acres of impervious area. This leaves runoff from approximately 43.5 acres of impervious area in the API
that goes untreated.
Appendix P, I-205 Toll Project Wetlands and Water Resources Technical Memorandum, provides more
detailed information about the API and methodology for this analysis.

Under the No Build Alternative, the existing bridge structure within the Tualatin River would remain as is.
No short-term or long-term impacts on wetlands or water resources would occur. No water quality
facilities would be constructed to capture or treat additional stormwater runoff, and the existing
approximately 43.5 acres of impervious area would continue to be untreated.
Build Alternative
Short-Term Effects
Under the Build Alternative, in-water work would be required below the ordinary high water mark
(OHWM)62 of the Tualatin River to replace the existing bridges. Work within the actively flowing channel
would be limited. Turbidity control measures such as floating turbidity curtains may be used during
construction to address temporary increases in turbidity and potential sediment transport, thereby
minimizing effects on water quality. The total area occupied by temporary pile below the OHWM would be
approximately 700 square feet (0.02 acre), which would be removed after bridge work is completed. The
volume of temporary pile would be approximately 3,000 cubic yards below the OHWM. Widening I-205
under the Build Alternative could also encroach upon up to 7 streams and associated stream buffers that
I-205 crosses or is adjacent to in the API. Most of these streams flow under I-205 in culverts and would
not be affected by the widening. If ODOT identifies stream and stream buffer impacts as the Project
design progresses, ODOT would obtain appropriate approvals and permits with regulatory agencies.
Approximately 38,000 square feet (0.9 acre) of temporary wetland fill is anticipated during construction to
accommodate construction vehicle access and traffic control. The total volume would be approximately
1,500 cubic yards of fill. This fill could temporarily reduce functions provided by wetlands, including water
storage, sediment retention, and wildlife habitat. After construction is complete, temporarily affected
wetlands, streams, and buffers would be restored or enhanced in accordance with agency permits and
approvals (see Section 3.14.4).
Vegetation removal and soil compaction from construction machinery, excavation, and demolition could
result in temporary sediment increases in stormwater runoff. However, the following construction BMPs
would be implemented during construction to avoid these actions or minimize negative effects on water
quality in receiving waterbodies: creating no-work zones and installing protective measures around
wetlands and other waters, turbidity curtains or cofferdams, and treating construction discharge water.
62
The OHWM is the highest water level that a water body has reached and maintained long enough to leave visible
evidence on the landscape.

I-205 Toll Project
Long-Term Effects
Approximately 51,000 square feet (1.2 acres) of wetlands would be permanently filled under the Build
Alternative to allow for I-205 widening. The total impact volume would be approximately 5,000 cubic yards
of fill. Permanent loss of wetlands can result in a decrease in water quality functions such as sediment
retention and a decrease in hydrologic functions such as water storage. Other impacts from permanent
wetland loss include loss of fish and wildlife habitat and decreased function in water temperature
regulation.
The existing bridge piers occupy an area of approximately 1,350 square feet (0.03 acre), which would be
removed and replaced with new permanent structures that would occupy the same area below the
OHWM of the Tualatin River. However, the two existing piers are located closer to the banks of the river,
while the new piers would be placed between the existing pier locations, closer to the middle of the river,
which would change the location of available habitat area. The total volume of permanent effects below
the OHWM would include 2,150 cubic yards of fill and 1,900 cubic yards of removal, resulting in a net fill
of approximately 250 cubic yards. Permanent impacts on wetlands, streams, and stream buffers would be
mitigated in accordance with federal, state, and local permits and approvals (see Section 3.14.4).
The total amount of impervious area contributing to stormwater runoff under the Build Alternative would
be approximately 100 acres, leading to greater levels of stormwater runoff than the No Build Alternative.
Any new or reconstructed impervious surfaces, as well as any ODOT-controlled impervious surface areas
that drain onto the reconstructed surfaces, would require stormwater treatment. Stormwater facilities
would be constructed as part of the Build Alternative to address stormwater management requirements
for water quality and quantity in accordance with the FAHP Programmatic and associated design
standards. These design standards require stormwater facilities, including biofiltration swales and
detention ponds, that would treat stormwater runoff from approximately 80 acres of impervious areas in
the API, leaving approximately 20 acres of impervious area without stormwater treatment. Therefore, the
Build Alternative would provide a net benefit to water quality in receiving water bodies over the No Build
Alternative.

Table 3-48 provides a comparison of anticipated effects on wetlands and water resources by alternative.
Table 3-48. Summary of Wetlands and Water Resources Effects by Alternative

Short-Term • None • Potential temporary increases in turbidity and potential sediment
transport in the Tualatin River during in-water work
• 0.02 acre/3,000 cubic yards temporary fill in the Tualatin River from work
bridge piling
• 0.9 acre/1,500 cubic yards temporary wetland fill for construction access
and traffic control
•
Long-Term • Continued untreated • 0.03 acre/250 cubic yards of net fill below the Tualatin River OHWM
stormwater runoff from • 1.2 acre/5,000 cubic yards permanent wetland fill due to roadway
approximately 43.5 acres widening
of impervious area
• Untreated stormwater runoff from approximately 20 acres of impervious
area
OHWM = ordinary high water mark

I-205 Toll Project
3.14.4 Avoidance, Minimization, and or Mitigation Measures

Construction contractors would be required to meet Oregon Standard Specifications for Construction as
well as federal, state, and local permit requirements, all of which would require the implementation of
BMPs during construction to avoid and minimize impacts on wetlands and water resources. Impacts on
wetlands and waters would require permits and approvals from U.S. Army Corps of Engineers (Section
404 Permit), Oregon Department of State Lands (Removal-Fill Permit), DEQ (401 Water Quality
Certification), City of West Linn, and Clackamas County. Appropriate mitigation would be specified in
these permit and approval processes. Compensatory mitigation for permanent, unavoidable impacts
could include the purchase of mitigation bank credits,63 on-site restoration, or other methods as
determined in the permitting process.
3.15 Cumulative Impacts

Cumulative impacts are defined as the effects on the environment that result from the incremental effects
of the action when added to the effects of other past, present, and reasonably foreseeable actions
regardless of what agency (Federal or non-Federal) or person undertakes such other actions (Council on
Environmental Quality 2022). This section identifies past actions, present actions, and reasonably
foreseeable future actions (RFFAs) affecting the same resources affected by the Build Alternative;
discusses the contribution of the Build Alternative to cumulative impacts and benefits on relevant
environmental resources; and identifies measures to avoid, minimize, and/or mitigate cumulative impacts.
Because the cumulative impacts analysis is based on the incremental impacts of the Build Alternative on
individual resources, analysts used the geographic APIs identified for each resource topic, as described
in Sections 3.1 through 3.14 of this EA.
Historical Context and Past Actions

The relevant timeframe for past actions extends back to the beginning of large-scale urban development
around the Project area in the late 1970s/early 1980s with the construction of I-205. Section 5 of
Appendix Q, I-205 Toll Project Cumulative Impacts Technical Report, provides a more detailed overview
of the historical context and relevant past actions in the region and near the Project location, including the
development of I-205 and the highway system in the Portland metropolitan area starting in the mid-1900s,
as well as the enactment of regional governing bodies and growth management regulations.
Present Actions and Reasonably Foreseeable Future Actions

The present actions and RFFAs included in this analysis were developed through review of Metro’s 2018
Regional Transportation Plan (RTP) and discussions with partner agencies using the following criteria
(Metro 2018b):
• The action is of a regional scale and is listed on the financially constrained project list in Metro’s
RTP. 64
63
A wetland mitigation bank is a site where wetlands are restored, created, enhanced, or preserved for the specific
purpose of providing compensatory mitigation in advance of unavoidable impacts on wetlands from a
development project. Mitigation banks provide the option of purchasing credits to offset the unavoidable impacts
of a project (Washington State Department of Ecology n.d.).
64
The financially constrained project list includes projects that fit within the RTP financial forecast (i.e., projects for
which funding has been committed and the projects that agencies have determined are the highest priority and
can be implemented with funding assumed in the financial forecast) (Metro 2018b).

I-205 Toll Project
• The action has a primary purpose of congestion management on the I-205 or I-5 corridors and is
listed on the financially constrained project list in Metro’s RTP.
• The action is anticipated to change vehicle or multimodal travel patterns in the vicinity of the I-205 Toll
Project and is listed on the financially constrained project list in Metro’s RTP.
• The action is within one or more of the resource area APIs concerned with physical impacts, 65 would
have a physical impact on the same resource areas that are physically impacted by the Build
Alternative; and is listed on the financially constrained project list in Metro’s RTP.
Effects of anticipated future land use development is captured in the regional growth modeling and was
therefore included in Project analyses for air quality, GHG emissions and climate change, noise, and
transportation. Therefore, this future development is inherently included in the cumulative analyses for
these topic areas.
Figure 3-20 identifies 13 projects as present actions and RFFAs that, with the Build Alternative, could
contribute to cumulative environmental impacts. Table 3-49 provides a brief description of each project as
described in the RTP, and Appendix Q, I-205 Toll Project Cumulative Impacts Technical Report, provides
more detailed information about those projects.
The three actions listed below are regionally or locally important but do not meet the Project’s criteria for
an RFFA for the following reasons:
• Regional Mobility Pricing Project (RMPP): The RMPP will evaluate congestion pricing in the
Portland metropolitan region as a mechanism to manage congestion and raise revenue to help fund
construction of approved congestion-relief transportation projects. The planning process is under
way, with the formal environmental review beginning in late 2022. Because key details about the
RMPP are unknown (e.g., starting and ending points for tolling, potential toll rates), impacts cannot be
reliably qualified or quantified at this time. The RMPP is not currently included in Metro’s RTP. The
cumulative impacts analysis for the RMPP will include the Project.
• Interstate Bridge Replacement (IBR) Program: The IBR program, which is in the environmental
review phase, would replace the existing Interstate Bridge across the Columbia River between
Vancouver, Washington, and Portland, Oregon. Because the IBR program is outside of the API for the
Project, the IBR program does not meet the identified criteria for an RFFA. However, the Project Team
included the bridge replacement in the transportation model used for the Project (i.e., the model
assumes the bridge replacement will be constructed); therefore, this action is accounted for in several
technical analyses, including transportation, noise, air quality, and energy and GHGs. ODOT also
anticipates that the IBR program will be included in the cumulative impacts analysis for the RMPP.
• I-5 Rose Quarter Improvement Project: This project, which is in the supplemental environmental
review and design phase, would add auxiliary lanes and shoulders on I-5 in Portland. Because the
Rose Quarter Improvement Project is outside of the APIs for the Project, it does not meet the criteria
for an RFFA. However, as with the IBR program, the Project Team included the Rose Quarter
Improvement Project in the transportation model (i.e., the model assumes the Rose Quarter project
will be constructed); therefore, this action is accounted for in several technical analyses
(transportation, noise, air quality, and energy and GHG). ODOT also anticipates that the Rose
Quarter Improvement Project will be included in the cumulative impacts analysis for the RMPP.
65
The resource areas concerned with physical impacts from the Build Alternative include land use, geology and
soils, hazardous materials, historic and archeological resources, vegetation and wildlife, and wetlands and water
resources.

I-205 Toll Project
Figure 3-20. Present Actions and Reasonably Foreseeable Future Actions
Source: Metro 2018b

I-205 Toll Project
Table 3-49. Present Actions and Reasonably Foreseeable Future Actions

Metro
RTP Metro RTP Metro RTP
ID Project Name Metro RTP Description Time Period
10127 OR 43 Multimodal Improve roadway with widening, turn lanes, street trees, signal 2028 to 2040
Improvements – interconnections, cycle tracks, and sidewalks. This project is in the
Holly Street to Mary preliminary design phase.
S. Young State Park
10128 Willamette Falls Provide bike lanes/cycle tracks and sidewalks. These improvements will 2028 to 2040
Drive Multimodal provide a direct multimodal connection between the downtowns of West Linn
Improvements – OR and Oregon City. This project is in the preliminary design phase.
43 to 10th Street
10568 Tualatin-Sherwood Widen the road from three to five lanes with added bike lanes and sidewalks. 2018 to 2027
Road Improvements
10907, High Capacity Transit High Capacity Transit project between Portland and Tualatin via Tigard. 2018 to 2027
11587 Southwest Corridor –
Light Rail Project
11242 I-205 / 10th Street Construct a long-term interchange improvement to provide congestion relief, 2018 to 2027
Improvements address safety issues, and improve bike/ped connectivity.
11301 OR 212/224 Sunrise Phase 2 of the OR 212/224 Sunrise corridor, consisting of a four-lane 2018 to 2027
Highway Phase 2: roadway from SE 122nd Ave to SE 172nd Ave.
SE 122nd to SE
172nd
11304 I-5 South Operational Construct improvements to address recurring bottlenecks on I-5 south of 2018 to 2027
Improvements central city Portland. Specific improvements would be as identified in
operational analysis, mobility corridor analysis, and refinement planning.
11350 OR 224 Milwaukie Construct a third westbound lane on OR 224 from I-205 to Rusk Rd. The 2018 to 2027
Expressway project was identified in 2014 and funds have been committed.
Improvements
11402 I-5 Northbound: Extend existing auxiliary lanes. 2028 to 2040
Auxiliary Lane
Extension Nyberg to
Lower Boones Ferry
11969, I-205 Abernethy Widen both directions of the I-205 Abernethy Bridge and approaches to 2018 to 2027
11585 Bridge[1] address recurring bottlenecks on the bridge.
11981 I-205 Northbound Provide I-205 northbound auxiliary lane between Sunrise Expressway 2018 to 2027
Auxiliary Lane, entrance ramp and the Sunnyside Rd/Sunnybrook Blvd interchange exit
Sunrise Expressway ramp.
Entrance to
Sunnybrook
11989 I-5 Northbound – Replace the inside merge at I-205 entrance by constructing braided ramps. 2028 to 2040
Braided Ramps I-205
to Nyberg
11990 I-5 Southbound – Add an auxiliary lane on I-5 from Wilsonville Rd to the Wilsonville-Hubbard 2028 to 2040
Wilsonville Road to Highway, including improvements to the Boone Bridge.
Wilsonville-Hubbard
Highway
12089 Willamette Falls Construct new roadways to support the Willamette Falls Legacy Project and 2018 to 2027
Legacy Project Riverwalk, consisting of Main St, Water St, 4th Ave, 3rd St, and Railroad St,
Internal Roadways including sidewalks.
[1] While referred to as the I-205 Abernethy Bridge in Metro’s RTP, the official project name is I-205: Phase 1A
Project.
I- = Interstate; OR = Oregon Route; RTP = Regional Transportation Plan

I-205 Toll Project
3.15.2 Potential Cumulative Impacts by Resource

This section summarizes the results of the cumulative impacts analysis for each of the environmental
topics in Sections 3.1 through 3.14. Chapter 6 of Appendix Q, I-205 Toll Project Cumulative Impacts
Technical Report, provides further details for each topic area.
Transportation
The era of the multilane highways in the region began in the 1930s with the construction of Barbur
Boulevard and McLoughlin Boulevard, which follow the former alignment of Native American trails
through the Willamette Valley. These roads became state highways 99E and 99W (Engeman 2005). The
next era of transportation in the area began with the building of the interstate highway system. After the
completion of I-5, the plan for a secondary highway in the region emerged in the U.S. Department of
Transportation’s 1955 Freeway and Expressway System Report. The first section of I-205, from West
Linn to Oregon City, opened to traffic in 1970, while facing unsuccessful legal challenges throughout the
early 1970s. Construction of I-205 in its current configuration was officially completed in 1982.
Population growth and development have led to an increase in the number of vehicles on both the
highways and local roads in the Portland metropolitan area, with subsequent increases in the number of
hours of congestion, the severity of congestion, and the number of crashes. The I-205 corridor currently
experiences 6.75 hours of congestion per day (ODOT n.d.-b). Within the API, roadways experienced
3,540 crashes along study segments and 58 crashes at independent study intersections between 2015
and 2019.
The Build Alternative would contribute to positive cumulative effects on transportation, including improved
travel times for truck freight on I-205 and most truck freight roadway segments in the API; reduced
congestion on I-205 translating to reductions in daily hours of congestion for all travelers; improved travel
times and operating LOS for transit; and fewer crashes on I-205. Negative cumulative effects from the
Build Alternative could include increased congestion on some local streets because of vehicles rerouting
from I-205 to avoid the toll; an increase in crashes on some non-highway routes; and worse pedestrian
level of traffic stress at a few areas due to higher projected traffic volumes, as discussed in Section 3.1.2.
However, ODOT is proposing measures to reduce and mitigate these impacts, as discussed in
Section 3.1.4.
The Project’s transportation modeling assumes the construction of the projects on the present actions
and RFFA list and, therefore, the model results represent a cumulative effect. The primary objective
identified in the RTP for most of the RFFAs includes improving system efficiency and/or relieving current
congestion. Secondary objectives for various RFFAs include improving truck freight and other vehicle
access, reducing crashes, and increasing opportunities for physical activity (via pedestrian and bicycle
improvements). Three of the RFFAs—OR 43 Multimodal Improvements, Southwest Corridor Light Rail,
and Willamette Falls Drive Multimodal Improvements—list increasing access to transit as a secondary
objective. None of the RFFAs include actions that would contribute to vehicle rerouting in the long term.
When considered in combination with past and present actions and RFFAs, the Build Alternative,
including its proposed mitigation, would have positive cumulative effects on the transportation network.
Therefore, no additional mitigation for cumulative transportation impacts is warranted or proposed.
Air Quality
The current air quality conditions in the API reflect past and present regional development, with emissions
from vehicles and residential, commercial, and industrial development. Air quality in the region has
improved over the past few decades (DEQ 2021). FHWA anticipates that MSAT emissions will continue to

I-205 Toll Project
decline through 2050, despite increased vehicle use (measured as VMT) due to the implementation of
fuel and engine regulations and vehicle technology improvements (FHWA 2016). The Portland region
currently meets all NAAQS. However, according to DEQ, the Portland region has the highest risk to the
population from air toxics compared to other areas in the state due to business and population density,
with levels of air toxics that could cause adverse health effects (DEQ 2021).
The air quality modeling for the Project includes outputs from the traffic modeling, which considers future
population and employment growth, expected changes in land use, and future transportation projects,
including the assumption that the present actions and RFFAs would be built. The modeling analysis,
therefore, accounts for the cumulative effects of Build Alternative with other present actions and RFFAs.
Air quality modeling under the Build Alternative shows a net decrease in MSAT emissions compared to
existing conditions, as well as lower emissions under the Build Alternative compared with the No Build
Alternative, as described in Section 3.2.2. Several of the RFFAs identify “reduce emissions” as a project
objective, including the OR 43 Multimodal Improvements, the Southwest Corridor Light Rail Project, and
the Willamette Falls Drive Multimodal Improvements.
When considered in combination with other past and present actions and RFFAs, the Build Alternative
would not have negative cumulative effects on air quality. Therefore, no mitigation for cumulative impacts
on air quality is warranted.
Climate
GHGs from human activity are a primary cause of climate change through increased concentration of
atmospheric carbon dioxide from the burning of fossil fuels. GHG emissions in the region have increased
over the past century due to population growth, increased development and consumption of goods,
increased number of motor vehicles, and emissions from various land uses. Consistent with national
trends, transportation (including highway, rail, and air transport) is the greatest contributor to GHG
emissions in Oregon (Oregon Global Warming Commission 2020). Petroleum (e.g., gasoline, diesel fuel,
jet fuel) is the predominant source of transportation fuel consumption at approximately 98% (U.S. Energy
Information Administration 2021).
Although construction of the Build Alternative would cause a short-term increase GHG emissions to
produce materials and operate equipment, in the long term, the Build Alternative would have net lower
GHG emissions and VMT, which would contribute to ODOT’s efforts to reduce GHG emissions and meet
climate change goals, consistent with the Oregon Statewide Transportation Strategy (ODOT 2013b) and
ODOT’s Climate Action Plan (ODOT 2021c). Overall, the Build Alternative would not contribute to a
cumulative climate change impact.
Economics
Development of I-205 helped shape the region’s economic environment, including facilitating commuter
vehicle trips within, into, and out of the Portland metropolitan area and connecting truck freight traffic to
the interstate highway system. I-205 also provides access for producers located outside of the region to
trade markets within the region. Past actions in the economics API have resulted in the development of
neighborhoods, infrastructure, public facilities and services, and the business and economic environment
that exists near I-205 where the Project would be located.
The Build Alternative would contribute to positive and negative cumulative effects on the economy. The
positive effects would be related to improved travel times, truck freight reliability, and vehicle operation
cost savings, as well as additional business revenues and employment in nearby commercial areas
resulting from projected changes in traffic volumes due to vehicles rerouting off I-205. The negative

I-205 Toll Project
effects would be higher transportation costs for households and wholesale traders; however, decreased
congestion and improved on-time reliability are expected to increase demand in the warehousing and
wholesale trade sectors, benefiting businesses throughout the supply chain (see Section 3.4.2), and
impacts on low-income households would be mitigated (see Section 3.8.4).
Construction of some of the present actions and RFFAs may occur simultaneously with the Build
Alternative, such as the I-205/10th Street Improvements or I-5 South Operational Improvements, which
would lead to positive cumulative economic effects related to design and construction services, as well as
growth in overall construction-related employment in the API. Potential negative cumulative effects from
simultaneous construction of multiple projects could include temporary truck freight and consumer access
and congestion issues; however, state and local jurisdictions would be required to develop traffic
management and control plans that would address construction access issues and minimize these
impacts.
The primary and secondary objectives for many of the present actions and RFFAS include congestion
relief, increasing access to jobs, and improving truck freight access to industries; all of which would
provide benefits to the local and regional economy. Some of the RFFAs, such as the Willamette Falls
Legacy Project Internal Roadways project, would directly support larger economic development activities
that result in more jobs and services within the API. Bicycle and pedestrian RFFAs such as the Willamette
Falls Drive Multimodal Improvements project, which will provide a multimodal connection between the
downtowns of West Linn and Oregon City, would also support local economic development. Investments
in bicycle and pedestrian infrastructure in/near business districts has been shown to improve economic
conditions in those districts (National Institute for Transportation and Communities 2020).
Therefore, when considered with the other past and present actions and RFFAs, the Build Alternative is
expected to have cumulative positive economic effects, and no mitigation for cumulative economic effects
is warranted or proposed.
Noise
I-205 was completed in the early 1980s. The development of the areas adjacent to and near I-205, along
with increased traffic on I-205 and on nearby roadways, has led to an overall increase in ambient noise
levels in the API. As residential uses and traffic levels have increased, the number of residences
negatively affected by road noise in the API has increased.
Construction activities from the Build Alternative and RFFAs would generate temporary noise during the
construction period, and contractors would be required to comply with noise control measures. When
considered with the present actions and RFFAs, the Build Alternative is not expected to have negative
cumulative effects related to construction noise because the project construction areas would be mostly
geographically dispersed and, for projects that are within the same area, it is unlikely that the projects
would be constructed simultaneously.
The long-term noise analysis for the Build Alternative was based on the transportation modeling, which
assumed the present actions and RFFAs would be built. The traffic model accounts for increased demand
on the transportation system from future population, housing and land use changes, and growth.
Therefore, the noise analysis is inherently an analysis of cumulative impacts. Under the Build Alternative,
no roadways would experience a “substantial” increase in noise levels in 2045 as defined in the ODOT
Noise Manual (ODOT 2011). However, predicted traffic noise levels under the Build Alternative would
range from 44 dBA Leq to 74 dBA Leq and would exceed ODOT’s NAAC at various residences, an outdoor
pool at an apartment building, a church/preschool/daycare, a park, and a school. To mitigate these noise
exceedances under the Build Alternative, three noise walls are recommended for consideration along

I-205 Toll Project
I-205 (see Section 3.5.3). For present actions and RFFAs that are managed by ODOT, if any of the
projects result in a substantial increase in noise levels or exceed ODOT’s Noise Abatement Approach
Criteria, noise abatement would also be required, which would reduce the potential for negative
cumulative effects. For present actions and RFFAs that are managed by other jurisdictions, those projects
would be required to adhere to local noise standards and ordinances.
Therefore, when considered with past and present actions and RFFAs, the Build Alternative would not
have negative cumulative effects related to noise, and no additional mitigation for cumulative effects is
warranted or proposed.
Visual Quality
The visual resources API includes a mixture of natural elements, such as native vegetation, rock cliffs,
and waterbodies, and human-made elements from past actions. These human-made elements include I-
205 and the supporting infrastructure, as well as the residences, businesses, recreational facilities, and
utilities that are located adjacent to I-205. Construction of the Build Alternative would require the removal
of trees and vegetation and the presence of signage, construction vehicles and equipment, and staging
areas. These temporary visual elements would be present within existing I-205 right-of-way, which is
adjacent to various residential and commercial uses. However, views of the right-of-way from these uses
are mostly screened by trees, vegetation, and/or slope that would remain, which would also mostly
screen construction activities on the Build Alternative. When considered with past and present actions
and RFFAs, the Build Alternative is not expected to have negative cumulative effects on visual quality
during construction because the projects would be mostly geographically dispersed and, for projects that
are within the same area, it is unlikely that the projects would be constructed simultaneously.
The addition of a third through lane along I-205 and toll gantries under the Build Alternative would not
substantially change the long-term visual environment in the area, which currently contains the existing
highway and supporting infrastructure. Although vegetation removal to accommodate the expanded
highway would occur in the right-of-way, views of I-205 from residential and commercial uses adjacent to
I-205 that are currently screened would mostly remain screened. The visual elements associated with the
present actions and RFFAs would mostly consist of horizontal elements (e.g., roads, rail lines, sidewalks,
bicycle lanes) and would be built along existing transportation corridors through urban environments of
varying densities, and therefore would not result in substantial changes to the existing visual landscape.
Therefore, when considered with past and present actions and RFFAs, the Build Alternative is expected
to have neutral cumulative effects66 related to visual quality, and no additional mitigation for cumulative
effects is warranted or proposed.
Social Resources and Communities

Population growth in the Portland metropolitan area has led to an increase in social resources throughout
the API to serve various needs of local communities. Each city and some unincorporated areas in the API
provide a variety of social resources, including social services providers, public service providers (defined
as police and fire services, libraries, museums, and community centers), religious organizations, schools,
parks and recreational facilities, and medical facilities.
66
A neutral cumulative effect means that the anticipated positive and negative effects on a specific resource would
balance each other out such that, when considered as a whole, the effects on that resource would not be
considered positive or negative.

I-205 Toll Project
As described in Section 3.7.2, the accessibility analysis found that the Build Alternative would result in the
same or improved access to social resources for households in the API during peak and off-peak periods
as the No Build Alternative. When compared with general population households in the API, EFC
households would generally experience the same or improved access to jobs, community places, and
medical facilities, depending on the time of day and mode of travel. The travel-time analysis found that
the general population and EFCs would experience the same or shorter travel times from their homes to
representative activity locations when traveling on routes that include the tolled bridges under the Build
Alternative relative to existing conditions and the No Build Alternative. Because the Metro regional travel
demand model includes the present actions and RFFAs, these results reflect the cumulative effects of the
Build Alternative and RFFAs. Therefore, when considered with past and present actions and RFFAs, the
Build Alternative would have a positive cumulative effect on social resources and communities related to
accessibility and travel time.
In the short-term, it is possible that the construction areas for the Build Alternative, present actions, and
RFFAs could overlap, leading to detours or travel-time delays for people accessing social resources and
communities. However, it is anticipated that access to social resources and communities would be
maintained and managed through coordination of traffic control plans across projects, which would
reduce the potential for negative cumulative effects related to construction.
All communities in the API would benefit from 26% fewer crashes (representing about 144 fewer crashes)
on I-205 in the API, including crashes resulting in injuries, under the Build Alternative as compared to the
No Build Alternative. Segments of OR 99E, OR 213, and Willamette Falls Drive in the API would
experience more crashes in 2045 under the Build Alternative compared to the No Build Alternative
because of changes in traffic volumes in those areas, and mitigation is proposed to address safety
impacts (see Section 3.1.4). Therefore, the Build Alternative would generally have no adverse effects on
safety on local roadways and intersections.
Several RFFAs, such as the Tualatin-Sherwood Road Improvements Project, I-5 South Operational
Improvements, and I-205 Abernethy Bridge, include secondary objectives to “reduce fatal and severe
injury crashes.” Pedestrian and bicycle RFFAs, such as the Willamette Falls Drive Multimodal
Improvements, aim to improve safety for pedestrians and bicyclists by separating these modes from
vehicle traffic and constructing safe facilities. Therefore, when considered with past and present actions
and RFFAs, the Build Alternative is expected to have positive to neutral cumulative effects on social
resources and communities related to roadway safety.
Social and public service providers and households, including EFCs, could experience increased costs as
a percentage of their operating or household transportation budgets if they choose to use the tolled
bridges, as described in Section 3.4.2. Overall, the improved I-205 traffic performance under the Build
Alternative compared to the No Build Alternative is expected to lead to benefits such as lower vehicle
emissions, shorter travel times, vehicle operating cost savings, and fewer vehicle incidents that reduce
costs for social resource providers and community members. It is not anticipated that the other present
actions and RFFAs would increase transportation costs or employ tolling. Therefore, when considered
with past and present actions and RFFAs, the Build Alternative is expected to have neutral cumulative
effects on social resources and communities related to transportation costs.
Under the Build Alternative, some traffic would reroute to local streets in order to avoid tolls, resulting in
potential impacts on access to nearby social resources in Canby, Gladstone, Lake Oswego, Oregon City,
Tualatin, West Linn, and unincorporated Clackamas County (near Stafford Hamlet and Canby), as
detailed in Section 3.1.2. However, mitigation measures such as intersection improvements proposed in
Section 3.1.4 are expected to avoid and minimize impacts related to rerouting traffic to local streets.

I-205 Toll Project
Long-term vehicle rerouting is not expected to occur as a result of the present actions and RFFAs
because they do not include tolling or roadway pricing. In addition, most of the present actions and
RFFAs, including improvements on I-205, I-5, OR 43, OR 212, and OR 224, include congestion relief and
system efficiency as primary or secondary objectives. Therefore, when considered with past and present
actions and RFFAs, the Build Alternative is expected to have positive to neutral cumulative effects on
social resources and communities related to rerouting.
Because roadway signage would be in English, the tolling system could introduce challenges for persons
with limited English proficiency in the API. ODOT proposes to implement measures, as detailed in Section
3.7.4, that would address language barriers to understanding the toll system. Other RFFAs, such as the
expansion of light rail or actions that create new or modified routes, could increase barriers for
populations that have limited English proficiency. Common transportation barriers for people with limited
English proficiency include signage, verbal or written instructions, and communications with agency staff
(e.g., bus drivers). ODOT, Metro, and TriMet (the key transportation providers within the API) have
existing programs in place to provide language assistance to travelers. These include ODOT’s Limited
English Proficiency Plan (ODOT n.d.-c), Metro’s Limited English Proficiency Plan (Metro 2018e), and
TriMet’s Language Access Plan (TriMet 2019). Each of these three plans evaluate translation needs
specific to that agency’s services and identify how each agency will ensure its information is translated
into languages that riders may need. Therefore, when considered with past and present actions and
RFFAs, the Build Alternative is expected to have neutral cumulative effects on social resources and
communities related to technology and language barriers.
Environmental Justice
In the past, construction of I-205 and other major transportation corridors fractured and isolated
communities, often disproportionately affecting environmental justice populations (ODOT 2020c). Large-
scale urban renewal projects and land use planning further contributed to adverse effects on
environmental justice populations (City of Portland 2019). In addition, a historic lack of transportation
improvements and investments in these communities has led to increased traffic safety risks, including
greater risk of a traffic fatality and limited access to transit and active transportation networks (Oregon
Walks 2021; Cohen and Hoffman 2019). Due in part to rapid population growth, low-income
neighborhoods have also been subject to gentrification and displacement (Bates 2013). As the cost of
housing grows in response to increased demand, some households are choosing to move farther from
the more developed areas of the API. These moves may decrease housing costs but often increase the
cost of transportation because individuals and households must travel farther to reach jobs and services.
As described in Section 3.8.2, when compared with general population households in the API,
environmental justice communities would generally experience the same or improved access to jobs,
community places, and medical facilities, depending on the time of day and mode of travel. The travel-
time analysis described in the Travel-Time Scenarios subsection of Section 3.8.2 found that the general
population and environmental justice communities would experience the same or shorter travel times
from their homes to representative activity locations when traveling on routes that include the tolled
bridges under the Build Alternative relative to existing conditions and the No Build Alternative. Because
the Metro Regional Travel Demand Model includes present actions and RFFAs, these results reflect
cumulative effects of the Build Alternative and RFFAs. Therefore, when considered with past and present
actions and RFFAs, the Build Alternative would have a positive cumulative effect on environmental justice
populations related to accessibility and travel time.

I-205 Toll Project
The lower number of I-205 crashes under the Build Alternative compared to the No Build Alternative would
benefit all populations, including environmental justice populations. OR 99E, which has segments that cross
through areas in Canby and Gladstone with higher percentages of environmental justice populations than
Clackamas County as a whole, is projected to experience more crashes under the Build Alternative as
compared to the No Build Alternative. The additional crashes would affect all communities, including
environmental justice populations, living in and traveling through the area, and mitigation is proposed to
address impacts (see Section 3.1.4). Several RFFAs, such as the Tualatin-Sherwood Road Improvements
Project, I-5 South Operational Improvements, and I-205 Abernethy Bridge, include secondary objectives to
“reduce fatal and severe injury crashes.” Pedestrian and bicycle RFFAs, such as the Willamette Falls Drive
Multimodal Improvements, aim to improve safety for pedestrians and bicyclists by separating these modes
from vehicle traffic and constructing safe facilities. It is expected that these benefits would extend to
environmental justice populations who live and travel through these project areas. Therefore, when
considered with past and present actions and RFFAs, the Build Alternative is expected to have positive to
neutral cumulative effects on environmental justice populations related to roadway safety.
Under the Build Alternative, some traffic would reroute to local streets in order to avoid tolls, resulting in
potential impacts on areas with higher concentrations of environmental justice populations in Canby and
Tualatin, as well as for environmental justice populations traveling to hubs of social resources in Oregon
City. Intersection impacts related to rerouting would occur throughout the API, and most impacts would
occur outside of high concentrations of environmental justice populations. Two intersections in areas with
higher percentages of environmental justice populations than the county as a whole (I-5 southbound
ramps and Nyberg Street in Tualatin, and OR 99E and Ivy Street in Canby) would have worse operations
under the Build Alternative than the No Build Alternative in 2027. Oregon City has a concentration of
social resources that provide assistance to low-income and/or minority populations, such as the
Clackamas City Court House, City Hall, a community center, religious organizations, nursing homes, and
parks. Longer delays at these intersections under the Build Alternative would have an impact on
environmental justice populations traveling to access social resources in Oregon City. However,
mitigation measures such as intersection improvements proposed in Section 3.1.4 are expected to avoid
and minimize impacts related to rerouting traffic to local streets. All populations, including environmental
justice populations, in the API are expected to experience impacts from rerouting to the same degree.
None of the RFFAs include tolling or roadway pricing; therefore, long-term changes in vehicle traffic patterns
are not expected to occur under the RFFAs. In addition, most of the RFFAs, including improvements on I-
205, I-5, OR 43, OR 212, and OR 224, include congestion relief and system efficiency as primary or
secondary objectives. When considered with past and present actions and RFFAs, the Build Alternative is
not expected to have negative cumulative effects on environmental justice populations related to rerouting
traffic to local streets. The cost of the toll would present a potential disproportionately high and adverse
effect on households living at or below the federal poverty level. However, ODOT is committed to providing
a low-income toll program that is expected to address the disproportionate burden of the toll on low-income
populations. Potential actions such as exemptions, credits, and/or discounted rates would be implemented
under the toll program (see Section 3.8.4). It is not anticipated that the other RFFAs would increase
transportation costs or employ tolling. Therefore, when considered with past and present actions and
RFFAs, the Build Alternative with implementation of the low-income toll policy is expected to have neutral
cumulative effects on environmental justice populations related to transportation costs.
In summary, impacts on environmental justice populations from the Build Alternative would be mitigated
and, when combined with present and RFFAs, the Build Alternative would have positive or neutral
cumulative effects on environmental justice populations. No mitigation for cumulative effects is warranted
or proposed.

I-205 Toll Project
Land Use
Transportation infrastructure such as I-5 and I-205 have supported population and job growth throughout
the Portland metropolitan area, leading to a concentration of land development around these
transportation networks. Land use planning and urban growth boundaries, which direct growth toward
urban areas to contain suburban sprawl and preserve agricultural and forest lands, has also influenced
how and where land development has occurred. In Oregon City, land uses adjacent to the segment of I-
205 where the Build Alternative would be located include a mix of residential uses, light industry, parks
and recreational areas along the Willamette River, and a variety of commercial uses such as a shopping
center, restaurants, and a hotel. West Linn includes a predominance of low-density residential uses north
of the I-205 right-of-way and vegetated areas, road infrastructure, and low-density residential uses south
of it. Unincorporated areas of Clackamas County adjacent to I-205 include primarily undeveloped, low-
density residential, agriculture lands, and sparse commercial uses.
The Build Alternative would result in a minor conversion (415 square feet) of private vacant land to
transportation use in West Linn. However, there is a sufficient amount of land in the API to absorb the
small reduction, so no long-term effects on land use would occur under the Build Alternative. RFFAs that
include roadway widening or the addition of new lanes, such as Tualatin-Sherwood Road Improvements
and OR 224 Milwaukie Expressway Improvements, may also require right-of-way acquisition; however,
local jurisdictions would review these projects to ensure that there is sufficient residential, commercial,
and industrial zoned land to meet future demand, and that projects comply with local land use plans and
state land use goals. Therefore, when considered with other past and present actions and RFFAs, the
Build Alternative would have a neutral cumulative effect on land uses, and no mitigation for cumulative
effects is warranted.
Geology and Soils

Current soil and geologic conditions in the region have been influenced by past natural events, such as
flooding and earthquakes, and ground-disturbing activities from development and infrastructure projects
over time. These events and activities can increase the potential for erosion and the contribution of
sediments to waterbodies. In addition, as existing infrastructure ages, it becomes more susceptible to
damage from geologic and natural events.
Construction of the Build Alternative would include ground disturbances that could cause erosion and
increased sediment in stormwater runoff. It is unlikely that the Build Alternative, considered with present
actions and RFFAs, would represent a greater potential for erosion and contribution of sediments to rivers
in the region during construction because the projects are mostly geographically dispersed and, for
projects that are within the same area, it is unlikely that the projects would be constructed simultaneously.
Furthermore, with the implementation of appropriate erosion, sediment control, and stormwater
measures, the individual impacts of the Build Alternative and the present actions and RFFAs would be
minimized, and as a result the overall negative cumulative effects would be minimal. Therefore, no
additional mitigation for cumulative impacts related to erosion of soils is warranted.
The Build Alternative would reconstruct or replace various bridges along I-205 to withstand a Cascadia
Subduction Zone earthquake. Present actions and RFFAs that also include redevelopment of existing
infrastructure such as reconstructing roads or bridges would be required to meet current seismic design
standards. For example, ODOT is reconstructing the I-205 Abernethy Bridge to withstand a Cascadia
Subduction Zone earthquake. Therefore, the Build Alternative, when considered with the past and present
actions and RFFAs, would have a positive cumulative effect on seismic resiliency in the region, and no
additional mitigation for cumulative impacts is warranted.

I-205 Toll Project
Hazardous Materials
Hazardous materials investigations identified two sites of concern within the API (HDR 2018b; 2020a,
2020b; Reynolds Engineering 2020). In addition, I-205 is an active automobile and truck travel corridor
where unknown spills and releases of hazardous materials may have occurred. During construction of the
Build Alternative and present actions and RFFAs, spills of hazardous materials could occur; however, spill
prevention plans would be required that include BMPs to reduce the risk of accidental spills and to
account for unforeseen spills of hazardous materials. All asbestos-containing materials and lead-based
paint encountered during construction of the Build Alternative would be disposed of at an approved
disposal site, leading to an improvement in the presence of hazardous materials in the API.
The Build Alternative would include ground disturbance and grading for construction, which could expose
existing contaminated materials. Exposure to contaminated materials under the Build Alternative would
be mitigated by proper handling and disposal of these materials in accordance with DEQ and ODOT
regulations. Taken together with present actions and RFFAs in the API, there is a greater potential for
contaminated material exposure; however, all projects would be required to implement proper handling
and disposal of hazardous materials in accordance with state and local regulations, thereby reducing the
overall potential for negative cumulative effects. If contaminated materials are encountered during
construction of the Build Alternative or present actions and RFFAs, there would be an incremental
improvement in environmental quality when the contamination is removed or remediated according to
current applicable regulatory standards. This removal or remediation could prevent potential migration of
hazardous materials through soil and groundwater over time. Therefore, when considered with past and
present actions and RFFAs, the Build Alternative would have a positive cumulative effect on hazardous
materials conditions, and no additional mitigation for cumulative impacts is warranted.
Historic and Archaeological Resources

Archaeological research shows the Portland region has been inhabited for the last 11,000 years. The
earliest inhabitants were the Chinookan-speaking peoples, including the Clackamas, Kathlamet,
Multnomah, and Tualatin peoples. By the 16th century, dozens of bands of people lived in what is now
Oregon, with populations along the Columbia River, the western valleys, and the coastal regions (Oregon
Historical Society 2018). Important for its abundant natural resources and plentiful fish and game, the
region is also home to Willamette Falls, located between what is now Oregon City and West Linn.
Willamette Falls was a historically important trading center in the Pacific Northwest and played an
important role in the oral histories and stories of original peoples, including the Chinookans and
Kalapuyans (Willamette Falls Legacy Project 2014).
The Build Alternative, present actions, and RFFAs would all include some level of ground disturbance
and/or grading for construction. Construction of the Build Alternative along with the present actions and
RFFAs would result in an incremental increase in the risk of encountering or disturbing unknown
archaeological resources. However, inadvertent discovery plans would be required to be prepared prior to
the construction of the Build Alternative, present actions, and RFFAs. These plans would identify
measures to address any archaeological resources encountered during construction to minimize impacts
on these resources. Therefore, when considered with past and present actions and RFFAs, the Build
Alternative is not expected to have negative cumulative effects on archaeological resources.
Five historic resources were identified in the Project’s area of potential effects; however, these resources
would not be affected by the Build Alternative. Some RFFAs may be determined to have an effect on
historic resources and would be required to prepare a mitigation plan to resolve those effects in
compliance with Section 106 of the National Historic Preservation Act. Therefore, when considered with

I-205 Toll Project
past and present actions and RFFAs, the Build Alternative would not have negative cumulative effects on
historic resources, and no additional mitigation for cumulative effects is warranted.
Vegetation and Wildlife

As the region has developed over time, native vegetation has been reduced and altered; terrestrial
habitats have become fragmented; and aquatic habitats have been degraded by in-water activities and
structures as well as increasing pollution runoff. A large portion of the Portland metropolitan area has
been disturbed by the development of buildings, roads, infrastructure, and other impervious surfaces.
Most of the API for vegetation and wildlife is paved or unvegetated, consisting mostly of I-205 and
supporting infrastructure. Most of the RFFAs would include new or expanded infrastructure along existing
transportation corridors through urban environments with limited native vegetation and/or fragmented
terrestrial habitats.
Under the Build Alternative, roughly 20 acres of vegetated areas or areas of pervious soil would be
converted to roadway, resulting in a direct loss of vegetation and available habitat for terrestrial species.
However, as detailed in Section 3.13, much of the vegetation that would be removed under the Build
Alternative consists of invasive species. The removal of invasive species and replanting of areas with
non-invasive species would improve the quality of the existing habitat in the API. Construction of the
present actions and RFFAs may also result in the removal of invasive species, resulting in a positive
cumulative effect on the quality of existing habitat in the long-term.
Some of the impacts on vegetation under the Build Alternative would occur in locally designated habitat
conservation areas, which would be regulated through local land use processes and may also require
mitigation/offsetting of non-invasive vegetation that is removed. Cumulative negative effects on non-
invasive vegetation and habitat during construction of the present actions and RFFAs would be expected
to be minimized through adherence to local development codes that require compliance with landscape
planting standards and offsetting vegetation removal with new plantings, as well as adherence to local
regulations pertaining to habitat conservation.
The Build Alternative would require in-water construction work in the Tualatin River that could disturb, injure,
or result in the direct mortality to fish. Some of the RFFAs, such as Southwest Corridor Light Rail and I-5
Southbound – Wilsonville Road to Wilsonville Hubbard Highway would also require in-water work. However,
the potential for negative cumulative effects on fish from in-water work is unlikely because only a few of the
projects would require in-water work; projects would be geographically dispersed; and for in-water work
projects that are close to each other (such as the Build Alternative and I-205 Abernethy Bridge), it is unlikely
that they would have the same in-water work window. Furthermore, projects with in-water work would be
required to secure permits from federal, state, and/or local jurisdictions that include commitments to avoid or
minimize impacts on fish. The Build Alternative would have no effect on ESA species and therefore would
not contribute to a cumulative effect on ESA species because construction would comply with the FAHP
Programmatic (NMFS 2021), the design standards from the FAHP Programmatic User Guide (ODOT and
FHWA 2016), and the Oregon Standard Specifications for Construction (ODOT 2021c), as discussed in
Section 3.13. ODOT and FHWA are in the process of obtaining FAHP Programmatic approval from the
National Marine Fisheries Service for the Build Alternative.
The Build Alternative and most of the present actions and RFFAs would increase the amount of
impervious surface area, which could increase the quantity of stormwater runoff to nearby waterbodies
and potentially affect aquatic species. However, all projects would be subject to stormwater management
regulations that would reduce runoff-related risks to wildlife. In addition, the Build Alternative would create
a net benefit to the water quality of nearby waterbodies because it would treat more stormwater than
existing conditions (see Section 3.14). Some RFFAs, such as the I-205 Abernethy Bridge, Tualatin-

I-205 Toll Project
Sherwood Road Improvements, and OR 43 Multimodal Improvements, include stormwater upgrades that
would potentially have positive cumulative effects on water quality and aquatic species.
Therefore, when considered with the past and present actions and RFFAs, the Build Alternative would
have positive cumulative effects on vegetation and wildlife, and no mitigation for cumulative effects is
warranted.
Wetlands and Water Resources

Numerous water resources exist in the Portland region, including rivers, lakes, creeks, streams, ditches,
and wetlands. Over time, increased development on and adjacent to water resources, as well as an
increase in pollution runoff to water resources, has reduced the quality of these resources for humans
and animals. Water resources in the API include the Tualatin River, Willamette River, McLean Creek,
Abernethy Creek, Athey Creek, Tanner Creek, Wilson Creek, wetlands, and several unnamed streams
and ditches. Various wetlands in the API are isolated from (i.e., not connected to) nearby larger
waterbodies due to past development, specifically the development of I-205.
The Build Alternative would result in temporary wetland fill during construction, and it would permanently
fill approximately 1.2 acres of wetlands from widening I-205. Construction of some of the present actions
and RFFAs may also require the temporary or permanent filling of wetlands. However, because most of
the present actions and RFFAs would include new or expanded infrastructure along existing
transportation corridors through urban environments, the presence of substantial high-quality wetland
areas within the project footprints is unlikely. Ultimately, the Build Alternative and present actions and
RFFAs would be subject to federal, state, and local requirements regarding wetland impacts, including
providing compensatory mitigation on-site or by the purchase of wetland mitigation credits. Wetland
impact mitigation would provide opportunities to improve existing wetlands along I-205 that have been
affected by past development in the area, or create new wetlands in protected areas. Therefore, when
considered with present actions and RFFAs, the Build Alternative would have neutral cumulative effects
on wetlands.
The Build Alternative and present actions and RFFAs would require ground disturbance and/or grading
during construction that could increase the amount of sediment in stormwater runoff that reaches nearby
waterbodies. Increased sediment can lead to a decrease in water quality. However, construction
contractors for the Build Alternative, present actions, and RFFAs would be required to implement BMPs to
manage stormwater runoff, thereby minimizing negative cumulative effects on water quality.
The Build Alternative would require in-water construction work in the Tualatin River that could increase
turbidity and sediment transport in waterways. Some of the RFFAs, such as Southwest Corridor Light Rail
and I-5 Southbound – Wilsonville Road to Wilsonville Hubbard Highway, would also require in-water
work. However, the potential for negative cumulative effects on water quality from turbidity and sediment
transport is unlikely because only a few projects would require in-water work; projects would be
geographically dispersed; and for in-water work projects that are close to each other (such as the Build
Alternative and I-205 Abernethy Bridge), it is unlikely that they would have the same in-water work
window. Furthermore, the Build Alternative and present actions and RFFAs would be required to
implement BMPs during construction and to secure permits and approvals that include commitments to
minimizing water quality impacts, which would result in minimal negative cumulative effects on water
resources.
The Build Alternative and most of the present actions and RFFAs would add new impervious surface
area, which could increase the quantity of stormwater runoff to nearby waterbodies and potentially have

I-205 Toll Project
an impact on water quality. However, all projects would be subject to stormwater management
regulations that would reduce the potential for negative cumulative effects on water quality. In addition,
the Build Alternative would create a net benefit to the water quality of nearby waterbodies by treating a
greater volume of stormwater than existing conditions (see Section 3.14). Some RFFAs, such as I-205
Abernethy Bridge, Tualatin-Sherwood Road Improvements, and OR 43 Multimodal Improvements,
include stormwater upgrades, potentially resulting in a cumulative benefit to water quality. Therefore,
when considered with past and present actions and RFFAs, the Build Alternative would result in positive
cumulative effects on water resources, and no mitigation for cumulative effects is warranted.

I-205 Toll Project
4 Public Involvement, Agency Coordination,

and Tribal Consultation
ODOT and FHWA have engaged in extensive public involvement, agency coordination, and tribal
consultation to gather input throughout development of the I-205 Toll Project. Input provided to date has
informed key elements of this I-205 Toll Project EA, including the purpose and need for the Project,
alternatives considered, potential impacts, and possible mitigation measures.
4.1 Equity-Focused Engagement

As part of the Oregon Toll Program, ODOT created the Equity Framework to describe its commitment to
minimizing burdens and maximizing benefits to historically and currently excluded and underserved
communities (ODOT 2020c). Equity acknowledges that not all people, or all communities, are starting
from the same place due to historical and current systems of oppression. Equity is the effort to provide
different levels of support based on an individual’s or group’s need to achieve fairness in outcomes.
Equity actionably empowers communities most affected by systemic oppression and requires the
redistribution of resources, power, and opportunity to those communities (State of Oregon 2020b). The
Equity Framework is consistent with Title VI of the Civil Rights Act of 1964, which prohibits discrimination
on the basis of race, color, and national origin in programs and activities receiving federal financial
assistance, as well as with ODOT’s Title VI Implementation Plan (ODOT 2022e).
4.1.1 Equity and Mobility Advisory Committee

ODOT convened an Equity and Mobility Advisory Committee composed of individuals with professional or
lived experience in equity and mobility. This committee advises the Oregon Transportation Commission
and ODOT on how tolls, in combination with other demand-management strategies, can include benefits
for communities that have been historically and are currently excluded and underserved by transportation
projects.
The Equity and Mobility Advisory Committee has provided valuable input and insights on many topics,
including:
• The Equity Framework for the Oregon Toll Program
• Public involvement approaches that actively and successfully encourage the meaningful participation
of individuals and groups from historically excluded and underserved communities
• Project impacts on historically excluded and underserved communities
• Recommendations to the Oregon Transportation Commission on toll policies and strategies to
address the availability of transit and other transportation options, potential impacts on neighborhood
health and safety as a result of rerouting, and affordability
4.1.2 Historically and Currently Excluded and Underserved Communities

Impacts on historically and currently excluded and underserved communities were considered during the
environmental review process. Based on the Equity Framework, people from historically and currently
excluded and underserved communities include, but are not limited to, the following:
• People experiencing low-income or economic disadvantage (individuals and communities with
substantially less wealth and financial resources and whose economic health and wellbeing has been
impaired due to systemic barriers)
• Black, Indigenous, and People of Color communities

I-205 Toll Project
• Older adults and children

• People who speak languages other than English, especially those with limited English proficiency
• People experiencing a disability
ODOT worked with community engagement liaisons to connect with multilingual audiences that
historically have not been engaged in planning activities for transportation projects. For example, during
the summer-fall 2020 engagement, fact sheets and surveys about the Project translated into Spanish,
Russian, Vietnamese, Simplified Chinese, and Traditional Chinese were provided to the liaisons who then
provided the information to their communities. The liaisons also interacted with service providers, freight
haulers, I-205 commuters, schools, and online Facebook groups. In November 2021, the community
engagement liaisons recruited and facilitated six virtual discussion groups for in-depth engagement to
understand current perceptions of traffic and transportation problems and to invite public conversations
about congestion pricing on I-205 and I-5 (as part of the larger Regional Mobility Pricing Project). Through
the discussion groups, members of the Vietnamese, Latin American, Chinese, Native American, Slavic,
and Black/African American communities shared current experiences with using I-205, concerns
surrounding the effects of congestion pricing, and support for potential mitigation measures.
ODOT translated the entire open house for the summer-fall 2020 engagement into Spanish and
advertised the Spanish open house site through in-language print and digital ads in Spanish language
publications (digital, print, and radio). ODOT also translated a flyer with Project information and an online
survey into Spanish, Russian, Vietnamese, Simplified Chinese, and Traditional Chinese.
In an effort to reach community members who may not use ODOT’s existing communication platforms,
ODOT coordinated with community-based organizations and agencies to share notifications about the
summer-fall 2020 engagement comment period. These outreach strategies included the following:
• Meeting with and presenting to various committees that represent historically and currently excluded
and underserved communities, such as the Welcome Home Coalition, Community Alliance of
Tenants, and Community in Motion
• Emailing an outreach toolkit with fact sheet, flyer, sample news article, and sample social media posts
to more than 100 community groups and neighborhood organizations
• Making telephone calls to about 20 community organizations that support historically and currently
excluded and underserved populations to alert them to the comment period, the toolkit, and
informational resources in non-English languages
• Distributing flyers containing information about the Project and the comment period in English and
Spanish to the Borland Road Free Clinic and Tualatin School House Food Pantry along I-205
Attachment 7 of Appendix J, I-205 Toll Project Environmental Justice Technical Report, provides
comprehensive summary of engagement with historically and currently excluded and underserved
communities.
4.2 Public Outreach

ODOT has conducted extensive public engagement and communications efforts throughout Project
development and environmental review. ODOT sought public input to help refine the draft purpose and
need, the toll alternatives to be studied, and key issues for analysis in the EA. During a focused
engagement period between August 3 and October 16, 2020, ODOT received approximately 4,600
survey responses, letters, emails, and voicemails, as well as comments at meetings and briefings. A
majority of respondents across all demographic groups and comment methods expressed strong

I-205 Toll Project
opposition to tolling in general or to the specifics of the I-205 Toll Project. Comments included concerns
about financial hardship, lack of fairness, and potential rerouting onto local roadways to avoid a toll.
ODOT has participated in more than 100 briefings and presentations to local officials, committees, and
councils; numerous tabling events at community gathering places such as farmers markets; and multiple
online and in-person open houses to provide information about the Project. Public notification of the
engagement opportunities has occurred through news releases, email newsletters (“e-News”) and a
dedicated Project email list, social media posts, paid advertising, and media and blog coverage. ODOT
has primarily collected public input through the open houses and tabling events; coordination with
community engagement liaisons, community-based organizations and agencies; and advisory committee
meetings. ODOT has also interviewed a variety of interested parties, including neighborhood
associations, business groups, social service groups, freight advocates, and representatives from local
jurisdictions. Comments received by ODOT have generally indicated support for the Project’s overall
objectives but have expressed concerns about noise, tolling as a revenue source, neighborhood traffic
impacts, and whether the Project would reduce congestion.
More recent examples of this outreach include:

• In September 2021, ODOT started a monthly online video series to share information on the Oregon
Toll Program and the I-205 Toll Project in a way that is more widely accessible.
• In early 2022, ODOT hosted webinars to present the preliminary results of the traffic analysis
conducted for the Environmental Assessment and allow members of the public and agencies to ask
questions to project staff. ODOT also hosted virtual workshops with elected officials, business and
community leaders, and local and regional agency staff to explore congestion pricing in the Portland
metropolitan area.
• In spring 2022, ODOT launched an online survey to gather broader input on congestion pricing on I-5
and I-205 in the region and potential mitigation measures for low-income populations. The online
survey received more than 12,000 responses.
• In summer 2022, ODOT shared the draft Low-Income Toll Report, which considers different options
to address the impacts of tolls on people experiencing low incomes, and the draft tolling policy update
to the Oregon Highway Plan for public review and comment.
ODOT will continue to conduct extensive public outreach during the environmental review process and
during construction of the Build Alternative through a variety of methods, such as ongoing briefings to
local community groups, engagement with committees and councils, online and in-person open houses,
and tabling events at community gathering places. ODOT will continue to share information about the
Project through email newsletters and the dedicated Project email list, social media posts, news releases,
paid advertising, and media and blog coverage.

I-205 Toll Project
4.3 Agency Coordination

4.3.1 Lead Agencies
FHWA and ODOT are the lead agencies for this EA. FHWA serves as the lead federal agency because
federal approval is needed, and federal funding is being used to study the impacts of tolling. Also, FHWA
funds have been used for other I-205 projects, including its original construction. ODOT is the joint lead
agency as the direct recipient of the Project’s federal funds.
4.3.2 Cooperating Agencies

The U.S. Army Corps of Engineers (USACE) is designated as a cooperating agency for this
Environmental Assessment per the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A
Legacy for Users. The USACE regulates activities and/or discharges into the waters of the United States
and will review the Project under Section 404 of the Clean Water Act and Section 10 of the Rivers and
Harbors Act of 1899. The level of the USACE participation as a cooperating agency and the authorization
that may be required will depend on the final design of the Project.
4.3.3 Participating Agencies

Participating agencies are any federal, tribal, state, regional, and local agencies that have an interest in
the Project. Participating agencies are responsible for the following:
• Providing comments on the purpose and need and range of alternatives
• Reviewing methodologies to address technical topics consistent with special expertise or jurisdiction
of the agency
• Reviewing this Environmental Assessment for sufficiency and providing comments
• Identifying any issues of concern regarding potential project impacts
• Providing timely input on unresolved issues
Participating agencies for this Environmental Assessment include the following:

• Oregon Department of Environmental • Washington County
Quality • City of Gladstone
• Oregon State Historic Preservation Office • City of Gresham
• Washington State Department of • City of Happy Valley
Transportation • City of Lake Oswego
• C-Tran • City of Milwaukie
• Metro • City of Oregon City
• Port of Portland • City of Portland
• Port of Vancouver • City of Rivergrove
• Southwest Washington Regional • City of Tualatin
Transportation Council • City of Vancouver
• TriMet • City of West Linn
• Clackamas County • City of Wilsonville
• Clark County, WA
• Multnomah County

I-205 Toll Project
ODOT held a virtual scoping meeting for participating agencies on August 12, 2020, that provided an
overview of the Project, equity considerations and the Equity and Mobility Advisory Committee, and
alternatives, and offered opportunities for agency representatives to ask questions. Since the summer-fall
2020 engagement effort and scoping period, ODOT has continued to provided briefings and
presentations to share information about the Oregon Toll Program with elected officials, advisory
committees, and city and county councils
4.3.4 Project Working Groups and Agency Briefings

In addition to the formal invitations to serve as participating agencies, ODOT convened the following three
working groups for development of the I-205 Toll Project:
• Regional Partner Agency Staff: This group is composed of agency staff representing the R1ACT, 67
Metro Joint Policy Advisory Committee on Transportation, and Southwest Washington Regional
Transportation Commission. This group met in advance of R1ACT meetings to hear Project updates
and to provide input on information that the R1ACT requested.
• Regional Modeling Group: This group is composed of agency staff members who have a technical
understanding of transportation modeling to provide input on the modeling approach for the Project.
• Transit and Multimodal Working Group: This group is composed of agency staff members with
knowledge of the local transit, pedestrian, and bicycle systems to provide input on how these
elements could be affected by or incorporated into the Project.
ODOT met regularly with each of these working groups during the development of this Environmental
Assessment to provide Project updates, answer questions, and encourage agencies to submit comments
during the public comment period.
4.3.5 Mitigation Workshops with Local Jurisdictions

ODOT and FHWA convened a series of workshops and meetings with local jurisdictions in August and
September 2022 to discuss proposed mitigation measures related to the effects of the Build Alternative.
Participants included representatives from the Cities of Canby, Gladstone, Lake Oswego, Oregon City,
Rivergrove, Tualatin, and West Linn; Clackamas and Washington Counties; Canby Area Transit; South
Metro Area Regional Transit; and TriMet. At the workshops, the Project Team presented preliminary
proposed mitigation measures for identified roadway, transit, and active transportation impacts under the
Build Alternative (as described in Section 3.1.2) and received input from the jurisdictions about how to
refine and modify these measures.
Key themes of the workshops included a desire to better understand the safety impacts of the Build
Alternative and consideration of safety mitigations, a desire to consider multimodal mitigation options that
do not increase vehicle capacity, input on local plans and projects that should be considered in the
analysis, ideas for transit service and access improvements that could improve overall mobility in the
Project area, and questions about how the API was selected and why certain intersections were not
included in the analysis. The input received during the workshops was incorporated into mitigation
measures included in this Environmental Assessment. Appendix C1, I-205 Toll Project Mitigation
Workshop Summaries, provides a summary of each workshop.
67
R1ACT is an advisory body composed of 31 voting members, including private industry, transit agencies,
stakeholders, and elected officials, who collaborate on transportation issues affecting ODOT Region 1 (serving all
of Clackamas, Multnomah, and Hood River Counties and eastern Washington County).

I-205 Toll Project
Follow up meetings were held with local jurisdictions in November and December 2022 to review
proposed mitigation measures. ODOT incorporated some input received during the meetings into the
mitigation measures included in this Environmental Assessment. Appendix C1, I-205 Toll Project
Mitigation Workshop Summaries, provides a summary of each follow up meeting. ODOT will continue to
work with local jurisdictions to address additional comments on the mitigation measures, and the Revised
Environmental Assessment will provide final mitigation commitments.
4.4 Tribal Consultation

ODOT and FHWA initiated formal government-to-government consultation with the following Native
American Tribes:
• Confederated Tribes of the Grand Ronde Community of Oregon
• Confederated Tribes of the Siletz Indians
• Confederated Tribes of the Umatilla Indian Reservation
• Confederated Tribes of Warm Springs Reservation of Oregon
• Confederated Tribes and Bands of the Yakama Nation
• Cowlitz Indian Tribe
• Nez Perce Tribe
These tribes were also invited to serve as participating agencies; however, none accepted the invitation.
ODOT and FHWA offered to meet with tribes at their request. The Confederated Tribes of the Grand
Ronde Community of Oregon requested meetings and ODOT and FHWA met with them in summer 2021
and early 2022 to discuss the I-205 Toll Project. Tribal representatives posed questions about how toll
rates would be set, what projects tolling would fund and how potential impacts on low-income populations
would be mitigated. They voiced concerns about the use of tolling in general, potential congestion and
business impacts related to diversion to local streets (particularly in Oregon City and near Willamette
Falls), and effects from diesel emissions. ODOT and FHWA also met with the Cowlitz Indian Tribe in
summer 2021 and heard concerns about the use of tolling as a congestion-management tool. ODOT and
FHWA met with the Cowlitz Indian Tribe again in summer 2022 to give an update on all Oregon toll
projects and answer questions related to the toll program and policies. ODOT sent letters on
September 6, 2022, to all of the consulting tribes detailing the updated scope of the Environmental
Assessment to include the planned I-205 improvements and recommendations for the Project’s
Section 106 Finding of Effect. ODOT has not received any responses from the tribes on this follow-up
letter and recommendations for the Section 106 Finding of Effect to date.
Government-to-government consultation for the Project and other proposed projects with tolling is
ongoing. In November 2022, ODOT and FHWA met with the Cowlitz Indian Tribe, Confederated Tribes of
the Grand Ronde Community of Oregon, Confederated Tribes of the Siletz Indians, and the Nez Perce
Tribe for the first quarterly inter-tribal tolling meeting. The second quarterly inter-tribal tolling meeting was
held in February 2023. The meetings provide updates on all proposed tolling projects in Oregon, including
the I-205 Toll Project, and offer opportunities for questions and discussion about tolling policy. In January
2023, the OTC adopted an amendment to the Oregon Highway Plan regarding tolling which, among other
policies and actions, would require ensuring that rate-setting structures and fees are consistent with
existing sovereignty or treaty rights and that ODOT undertakes government-to-government consultation
with affected tribes for all tolling projects (ODOT 2022f).

I-205 Toll Project
4.5 Summary of Input Considered in this Environmental

Assessment
Input from agencies and the public has shaped the scope, methodology, and analysis for this
Environmental Assessment. Appendix R, I-205 Toll Project Engagement Summary, describes ODOT’s
engagement with agencies, community groups, corridor travelers, and the public August through October
2020, when it was seeking input on the Project purpose and need, goals and objectives, alternatives, and
environmental impacts. ODOT had continued outreach to agencies, Tribes, and the public during the
development of this Environmental Assessment, as noted in Sections 4.1 through 4.4. In July 2022,
ODOT notified agencies, Tribes, and the public of the changes to the Project, i.e., adding widening and
seismic improvements to the I-205 Toll Project. Examples of steps ODOT took to incorporate comments
into this Environmental Assessment include:
• Updating the I-205 Toll Project goals and objectives, listed in Section 1.5 of this Environmental
Assessment, to include equity and acknowledge quality of life impacts on nearby and adjacent
communities, based on comments received from the public, agencies, the Equity and Mobility
Advisory Committee, and specific outreach to historically and currently excluded and underserved
communities.
• Adding performance measures to account for equity impacts on disadvantaged groups, such as
health, safety, and accessibility.
• Increasing the number of intersections studied for potential traffic rerouting effects from 34 to 50
based on continuing coordination with local cities and counties.
• Evaluating potential environmental effects from the implementation of tolling and the resulting
changes in traffic patterns across a range of topic areas beyond transportation, including
environmental justice, social resources and communities, and noise.
• Proposing mitigation measures to offset projected effects on local roadways in close coordination with
affected cities and counties, as described in Section 3.1.4 and Section 4.3.5.
• Expanding the number of engagement opportunities and outreach events to provide information
about the I-205 Toll Project and environmental review process, including flyers distributed at local
clinics and briefings.

I-205 Toll Project

I-205 Toll Project
5 Preparers
Individuals involved in preparing this Environmental Assessment are identified in Table 5-1.
Table 5-1. List of Preparers

Name Role
AGENCY STAFF
FHWA
Brent Allen EA Reviewer
Melissa Parker EA Reviewer
Thomas Parker EA Reviewer
Nathaniel Price EA Reviewer
Shaneka Owens EA Reviewer
ODOT
Andrew Bastasch Transportation Reviewer
Becky Knudson Economics Reviewer
Ben White Vegetation and Wildlife Reviewer
Carol Snead Environmental Project Manager
Daniel Burgin Noise Reviewer
Devin Simmons Wetlands and Water Resources Reviewer, FAHP Compliance
Hannah Williams Stakeholder Engagement
Magnus Bernhardt Visual Quality Reviewer
Mandy Putney Project Lead
Melanie Ware NEPA Compliance
Michael Holthoff Cumulative Impacts Reviewer
Natalie Liljenwall Air Quality and Climate Change Reviewer
Robert Hadlow Historic Resources and Section 4(f) Reviewer
Robert Schiavone Noise Reviewer
Susan White Social Resources and Communities and Environmental Justice Reviewer
Tobin Bottman Historic and Archaeological Resources Reviewer, Section 106 Compliance, Tribal
Coordination
CONSULTING TEAM
WSP USA
Abby Caringula Transportation Technical Report Author
Adela Mu Performance Measures Support; Social Resources and Environmental Justice
Technical Reports Support
Anne Pressentin Communications and Public Involvement Task Lead
Anne Broache, AICP EA and Technical Report Reviewer; EA Author
Alec Egurolla SAC Compliance
Brennah McVey GIS Analyst
Brent Baker Traffic & Revenue/Financial Planning Lead
Chris Wellander Transportation Analysis Lead, Transportation Technical Report Author, Reviewer
Chris Wilhelm Economics Analysis Lead; Economics Technical Report Author
Edith Lopez Transportation Technical Report Author
Emily Benoit Social Resources and Communities Technical Report Lead and Author;
Environmental Justice Technical Report Author
Emma Johnson, AICP, Cumulative Technical Lead and Author
LEED Green Associate
Ethan Spoo, AICP SAC Compliance
Gabriella Yanez-Uribe Noise Technical Report QC
Ginette Lalonde Air Quality and Energy and Greenhouse Gases Technical Report QC

I-205 Toll Project
Name Role
Heather Wills Project Manager
Jennifer Rabby, AICP NEPA Scoping Lead
Jessie Jones Graphic Designer
Jeff Crisafulli Technical Editor
Keely Lucientes GIS Analyst
Ken Zatarain Transit and Multimodal Planning Analysis
Kevin Keller Noise Modeling
Mat Dolata, PE, PTOE Regional Modeling Technical Lead; Analysis Framework and Coordination
Matthew Hall Cumulative Impacts Technical Report Author
Mingyang Li, AICP Traffic Modelling Support
Michael Babin Editor/Document Specialist
Michael Lieu Noise Modeling
Nicki Hurley, GISP GIS Analyst
Nicole McDermott, AICP NEPA Task Lead; EA Author
Patrick Romero, INCE, Noise Technical Report Lead
ENV SP
Rachel Haukkala, AICP Transportation Technical Report Author, Bicycle and Pedestrian Planning
Analysis
Rebecca Frohning Air Quality and Energy and Greenhouse Gases Technical Report Lead
Rebecca Steiner Environmental Justice Technical Report Lead and Author; Social Resources and
Communities Technical Report Author; EA Author
Ryan Weston, PLA, ASLA Abbreviated Visual Impact Assessment Lead and Author
Sam Roberts, AICP NEPA Deputy Task Lead; Cumulative Impacts Technical Report Author;
Abbreviated Visual Impact Assessment Author; EA Author
Sine Madden, AICP Deputy Project Manager
Stephanie Sprague, PMP, Environmental Justice Senior Advisor and Reviewer
AICP
Timothy Thornton Economic Analysis Manager
Zahra Sadegh Environmental Justice Technical Report Author; Social Resources and
Communities Technical Report Author; EA Author
HDR, Inc.
Rachel Barksdale EA and Technical Memorandum Author

I-205 Toll Project
6 References
Atwater, B.F., and E. Hemphill-Haley. 1997. Recurrence intervals for great earthquakes of the past 3500
years at Northeastern Willapa Bay, Washington: U.S. Geological Survey Professional Paper
1576.
Bates, Lisa K., PhD. 2013. Gentrification and Displacement Study: implementing an equitable inclusive
development strategy in the context of gentrification. Commissioned by City of Portland Bureau of
Planning and Sustainability.
Beeson, M.H., T.L. Tolan, and I.P. Madin (Beeson et al.). 1991. Geologic Map of the Portland
Quadrangle, Multnomah and Washington Counties, Oregon, and Clark County, Washington:
Oregon Department of Geology and Mineral Industries, Geological Map Series GMS-75, scale
1:24,000.
Burt, W., T. Conlon, T.L. Tolan, R.E. Wells, and J. Melady (Burt et al.). 2009. “Hydrogeology of the
Columbia River Basalt Group in the Northern Willamette Valley, Oregon: Volcanoes to vineyards:
geologic field trips through the dynamic landscape of the Pacific Northwest.” O’Connor, J.E.,
Dorsey, R.J., and Madin, I.P., (eds.), Geological Society of America Field Guide 15, p. 697-736.
Census Reporter. 2018. Portland-Vancouver-Hillsboro, OR-WA Metro Area.
https://censusreporter.org/profiles/31000US38900-portland-vancouver-hillsboro-or-wa-metro-
area/. Accessed February 4, 2020.
City of Canby. 2019. Zoning Map.
https://www.canbyoregon.gov/sites/default/files/fileattachments/development_services/page/6591
/zoningmapsept2019.pdf. Accessed April 6, 2022.
City of Gladstone. 2014. Zoning Map.
https://www.ci.gladstone.or.us/sites/default/files/fileattachments/planning_commission/page/1251/
zoning_small.pdf. Accessed April 6, 2022.
City of Lake Oswego. 2019. Zoning Map. https://www.ci.oswego.or.us/maps/lake-oswego-zoning-map.
Accessed April 6, 2022.
City of Oregon City. 2013. Oregon City Transportation System Plan. Volume 1.
https://www.orcity.org/sites/default/files/fileattachments/public_works/page/4283/volume_1_versio
n_4.pdf. Accessed June 1, 2022.
City of Oregon City. 2020. Zoning Map. https://www.orcity.org/maps/zoning-map. Accessed April 6, 2022.
City of Oregon City. 2022. Oregon City 2040 Comprehensive Plan.
https://www.orcity.org/system/temporary/filefield_paths/final_oc2040_comp_plan_document_12.2
1.22_0.pdf. Accessed January 17, 2023.
City of Portland. 2019. Historical Context of Racist Planning: A History of How Planning Segregated
Portland. https://www.portland.gov/sites/default/files/2019-
12/portlandracistplanninghistoryreport.pdf. Accessed January 10, 2022.
City of Portland. 2020. Title 13 – Nature in Neighborhoods, Request for Metro Determination of
Substantial Compliance. https://www.portland.gov/sites/default/files/2020-
02/2012_metrotitle13_compliancereport.pdf. Accessed September 9, 2022.
City of Tualatin. 2020. Tualatin River Water Trail. https://www.tualatinoregon.gov/recreation/tualatin-river-
water-trail. Accessed November 17, 2022.
City of Tualatin. 2022. Zoning Map Interactive Viewer. https://www.tualatinoregon.gov/planning/zoning-
map-interactive-viewer. Accessed April 6, 2022.

I-205 Toll Project
City of West Linn. 2014. Water Resource Area Map.

https://westlinnoregon.gov/sites/default/files/fileattachments/maps_gis/page/9641/sigripa
rian_wetlands_20140606v6_final_added_special_disclaimer_201503.pdf. Accessed
January 13, 2022.
City of West Linn. 2015. West Linn City Map. https://westlinnoregon.gov/maps/city-map. Accessed April 6,
2022.
City of West Linn. 2016a. City of West Linn Comprehensive Plan.
https://westlinnoregon.gov/sites/default/files/fileattachments/planning/page/6526/west_linn_comp
_plan_-_updated_07-31-2017.pdf. Accessed June 1, 2022.
City of West Linn. 2016b. City of West Linn Transportation System Plan.
https://westlinnoregon.gov/sites/default/files/fileattachments/planning/page/5828/west_linn_tsp_-
_adopted_2016_updated_2021.pdf. Accessed June 1, 2022.
Clackamas County. 2000. Title 6 Public Protection – Chapter 6.05 Noise Control.
https://dochub.clackamas.us/documents/drupal/5e976f74-eea5-4935-bfa8-
99ecf0cbd228. Accessed January 13, 2022.
Clackamas County. 2020. Clackamas County Comprehensive Plan – Map 5-1 Scenic Roads.
https://www.clackamas.us/planning/maptoc.html. Accessed September 8, 2022.
Clackamas County. 2022a. Comprehensive Plan Map 4-07a: Non-Urban Area Land Use Plan.
https://www.clackamas.us/planning/maptoc.html. Accessed April 6, 2022.
Clackamas County. 2022b. Clackamas County Transportation System Plan.
https://dochub.clackamas.us/documents/drupal/4f347d01-968b-47c4-ae92-7eaac0776a0f.
Accessed June 2, 2022.
Congressional Budget Office. 2020. Reauthorizing Federal Highway Programs: Issues and Options.
https://www.cbo.gov/system/files/2020-05/56346-CBO-Highway-Reauthorization.pdf. Accessed
August 31, 2022.
Connolly, Thomas J. 2018. Exploratory Cultural Resource Survey of Locality 5 on the I-205L Stafford
Road – OR99E Section, Clackamas County (ODOT Key No. 19786; Museum Report 2018-010).
Prepared by the Oregon State Museum of Anthropology for the Oregon Department of
Transportation, Salem.
Council on Environmental Quality. 1997. Considering Cumulative Effects Under the National
Environmental Policy Act. https://ceq.doe.gov/publications/cumulative_effects.html.
Council on Environmental Quality. 2022. National Environmental Policy Act Implementing Regulations –
40 CFR Parts 1500-1508. https://ceq.doe.gov/docs/laws-regulations/NEPA-Implementing-
Regulations-Desk-Reference-2022.pdf. Accessed September 14, 2022.
Engeman, Richard. 2005. “Roads to Freeways: Building and Land Preservation.”
ESRI. 2018. GIS data for county, city, urban area boundaries, locations of religious organizations.
Federal Deposit Insurance Corporation. 2019. How America Banks: Household Use of Banking and
Financial Services. https://www.fdic.gov/analysis/household-survey/2019report.pdf. Accessed
October 27, 2021.
Federal Highway Administration (FHWA). No date-a (n.d.-a). Federal Tolling Programs: Section 129
General Tolling Program.
https://www.fhwa.dot.gov/ipd/tolling_and_pricing/tolling_pricing/section_129.aspx. Accessed
January 19, 2023.
Federal Highway Administration (FHWA). No date-a (n.d.-b). Section 4(f) Tutorial.
https://www.environment.fhwa.dot.gov/env_topics/4f_tutorial/overview.aspx?h=e. Accessed
October 24, 2022.

I-205 Toll Project
Federal Highway Administration (FHWA). No date-b (n.d.-c).

https://www.environment.fhwa.dot.gov/env_topics/4f_tutorial/properties_other.aspx#7. Accessed
November 17, 2022.
Federal Highway Administration (FHWA). No date-b (n.d.-d). Section 4(f) Properties
https://www.environment.fhwa.dot.gov/env_topics/4f_tutorial/properties_other.aspx#7. Accessed
November 17, 2022.
Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook and
Roadway Construction Noise Model (version 1.0).
Federal Highway Administration (FHWA). 2011. A Programmatic Agreement among the Federal Highway
Administration, the Advisory Council on Historic Preservation, the Oregon State Historic
Preservation Office and the Oregon Department of Transportation Regarding Implementing
Section 106 of the National Historic Preservation Act for the Federal-Aid Highway Program in
Oregon. https://www.oregon.gov/ODOT/GeoEnvironmental/Docs_CulturalResource/Arch_00-
02_ODOT-FHWA-Programmatic-Agree_2011.pdf. Accessed June 29, 2022.
Federal Highway Administration (FHWA). 2015. Guidelines for the Visual Impact Assessment of Highway
Projects. Washington D.C.
https://www.environment.fhwa.dot.gov/env_topics/other_topics/VIA_Guidelines_for_Highway_Pro
jects.pdf.
Federal Highway Administration (FHWA). 2016. Frequently Asked Questions (FAQ) Conducting
Quantitative MSAT Analysis for FHWA NEPA Documents. FHWA HEP-15-0156.
https://www.fhwa.dot.gov/environment/air_quality/air_toxics/policy_and_guidance/moves_msat_f
aq.pdf
Federal Highway Administration (FHWA). 2022. Infrastructure Carbon Estimator.
https://www.fhwa.dot.gov/environment/sustainability/energy/tools/carbon_estimator/
Garcia-López, Miquel-Àngel, Ilias Pasidis and Elisabet Viladecans-Marsal (Garcia-López et al). 2020.
"Congestion in highways when tolls and railroads matter: Evidence from European cities,"
Working Papers wpdea2011, Department of Applied Economics at Universitat Autonoma of
Barcelona.
Guerrero, Sebastian, Robert B. Noland, Stan Hsieh, Ira Hirschman, Abhishek Bhargava (Guerrero et al.).
2019. Value of Reliability: the Most Important Variable for Trucking Yet the Least Understood.
Transportation Research Board.
HDR 2017. Proof of Concept Report.
HDR 2018a. Cost-to-Complete Report for the Combined Interstate 205 Abernethy Bridge and Widening
Projects.
HDR. 2018b. Final Design Acceptance Package (DAP).
https://i205corridor.org/files/Contractor%20Meeting%20Documents/Technical%20Documents/fina
l-design-acceptance-package-narrative.pdf.
HDR. 2018c. Level 1 Hazardous Material Corridor Study and Hazardous Building Materials Paper Survey
for the I-205 Improvements Project.
HDR. 2018d. Historic Resources Technical Report. I-205: Stafford Road to OR 213 Corridor Widening &
Abernethy Bridge Seismic Retrofit / Widening.
HDR. 2018e. Migratory Bird and Bat Technical Memorandum. I-205 Stafford Road to OR 213 Corridor
Road Widening and Retrofit of the Abernethy Bridge Project.
HDR. 2019. WD # 2018-0209 Wetland Delineation Report for K19786 I-205 Corridor Widening;
Clackamas County; T2S R1W Sec. 25; T2S R1E Sec. 27, 28, 29, 30, 34, 35, and 36; T2S R2E
Sec. 16, 20, 29, 30, and 31, in ROW and Many Tax Lots.
HDR. 2020a. Level 2 Preliminary Site Investigation for the I-205 Improvements Project. October 2020.

I-205 Toll Project
HDR. 2020b. Shoulder Material Investigation Report for the I-205 Improvements Project. November 2020.
May C., C. Luce, J. Casola, M. Chang, J. Cuhaciyan, M. Dalton, S. Lowe, G. Morishima, P. Mote, A.
Petersen, G. Roesch-McNally, and E. York (May et al.). 2018. Northwest. In Impacts, Risks, and
Adaptation in the United States: Fourth National Climate Assessment, Volume II [Reidmiller, D.R.,
C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)].
U.S. Global Change Research Program, Washington, DC, USA, pp. 1036–1100. doi:
10.7930/NCA4.2018.CH24.
Metro. 2016. Population Forecast to 2060. https://www.oregonmetro.gov/2060-growth-forecast. Accessed
February 4, 2020.
Metro. 2018a. Regional Freight Strategy.
https://www.oregonmetro.gov/sites/default/files/2019/09/20/Regional-Freight-Strategy-FINAL-
091919.pdf. Accessed February 3, 2020.
Metro. 2018b. Regional Transportation Plan.
https://www.oregonmetro.gov/sites/default/files/2020/07/29/Adopted-2018-RTP-all-chapters.pdf
Metro. 2018c. 2018 Regional Transportation Plan, Appendix E: Transportation Equity Evaluation: An
Evaluation of Equity, Environmental Justice and Title VI outcomes.
https://www.oregonmetro.gov/sites/default/files/2019/03/13/Transportation-Equity-Evaluation-
Final-3.12.19.pdf. Accessed July 8, 2020.
Metro. 2018d. Urban Growth Management Functional Plan.
https://www.oregonmetro.gov/sites/default/files/2018/04/16/urban-growth-management-
functional-plan-04162018.pdf. Accessed June 28, 2022.
Metro. 2018e. Limited English Proficiency Plan.
https://www.oregonmetro.gov/sites/default/files/2016/06/21/2015_limited_english_proficiency_pla
n.pdf. Accessed February 1, 2022.
Metro. 2020. 2018 Kate v2.0 Trip-Based Travel Demand Model Methodology Report.
https://www.oregonmetro.gov/sites/default/files/2020/05/13/trip-based-travel-demand-model-
methodology-report-May-2020.pdf. Accessed July 20, 2022.
Metro. 2022. Regional Land Information System. https://rlisdiscovery.oregonmetro.gov/.
National Institute for Transportation and Communities. 2020. Understanding Economic and Business
Impacts of Street Improvements for Bicycle and Pedestrian Mobility: A Multi-City, Multi-Approach
Exploration. https://ppms.trec.pdx.edu/media/project_files/NITC-RR-1031-
1161_Understanding_Economic_and_Business_Impacts_of_Street_Improvements_for_Bicycle_a
nd_Pedestrian_Mobility.pdf. Accessed January 27, 2022.
National Oceanic and Atmospheric Administration National Marine Fisheries Service (NMFS). 2021.
Reinitiation of the Endangered Species Act Programmatic Biological Opinion and Magnuson-
Stevens Act Essential Fish Habitat Response for the Federal-Aid Highway Program in the State
of Oregon (FAHP). https://www.oregon.gov/odot/GeoEnvironmental/Documents/FAHP_NMFS-
Bio-Opinion.pdf. Accessed October 12, 2022.
National Oceanic and Atmospheric Administration National Marine Fisheries Service (NMFS). 2022.
Endangered Species Conservation. https://www.fisheries.noaa.gov/topic/endangered-species-
conservation. Accessed October 10, 2022.
National Park Service. 2020. National Water Trails. https://www.nps.gov/subjects/rivers/national-water-
trails-system.htm. Accessed November 17, 2022.
Oregon Department of Agriculture. 2020. Noxious Weed Policy and Classification System. 2020.
https://www.oregon.gov/oda/shared/Documents/Publications/Weeds/NoxiousWeedPolicyClassific
ation.pdf. Accessed June 20, 2022.
Oregon Department of Environmental Quality (DEQ). 2021. Oregon Air Quality Monitoring Annual Report:
2020. December 2021. https://www.oregon.gov/deq/aq/Documents/2020AQMonitoringReport.pdf

I-205 Toll Project
Oregon Department of Fish and Wildlife (ODFW). No date (n.d.). Sensitive Species.
https://www.dfw.state.or.us/wildlife/diversity/species/sensitive_species.asp. Accessed October,
10 2022.
Oregon Department of Fish and Wildlife (ODFW). 2021. Sensitive Species List – Frequently Asked
Questions. https://www.dfw.state.or.us/wildlife/diversity/species/docs/Sensitive_Species_List.pdf.
Accessed October 10, 2022.
Oregon Department of Land Conservation and Development (DLCD). 1997. Oregon’s Statewide Planning
Goals and Guidelines. https://www.oregon.gov/lcd/OP/Documents/goal5.pdf. Originally adopted
January 1975. Accessed January 18, 2023.
Oregon Department of State Lands (DSL). No date (n.d.). Essential Salmonid Habitat and Removal-Fill
Permitting. https://www.oregon.gov/dsl/WW/Pages/ESH-permits.aspx. Accessed October 10,
2022
Oregon Department of State Lands (DSL). 2022. 2022 Essential Salmonid Habitat Map.
https://maps.dsl.state.or.us/esh/. Accessed October 10, 2022.
Oregon Department of Transportation (ODOT). No date-a (n.d.-a). TDS Crash Reports: State Highway
Crash Reports. https://tvc.odot.state.or.us/tvc/.
Oregon Department of Transportation (ODOT). No date (n.d.)-b. I-205 Improvements – Stafford Road to
OR 213 – Needs and Benefits. https://i205corridor.org/needs-and-benefits. Accessed November
30, 2021.
Oregon Department of Transportation (ODOT). No date-c. (n.d.-c) Limited English Proficiency Plan.
https://www.oregon.gov/ODOT/Business/OCR/Documents/FINAL_VI_LEP_PLAN.pdf. Accessed
February 1, 2022.
Oregon Department of Transportation (ODOT). 1999. 1999 Oregon Highway Plan Including amendments
November 1999 through May 2015. https://www.oregon.gov/odot/Planning/Documents/OHP.pdf.
Accessed November 5, 2021
Oregon Department of Transportation (ODOT). 2006. Oregon Transportation Plan.
https://www.oregon.gov/odot/planning/pages/plans.aspx. Accessed November 14, 2022.
Oregon Department of Transportation (ODOT). 2011. Noise Manual.
https://www.oregon.gov/odot/GeoEnvironmental/Docs_Environmental/Noise-Manual1.pdf.
Accessed November 22, 2021.
Oregon Department of Transportation (ODOT). 2012. Oregon department of transportation Highway
Design Manual. https://www.oregon.gov/odot/Engineering/Pages/Hwy-Design-Manual.aspx.
Accessed April 2022.
Oregon Department of Transportation (ODOT). 2013a. Corridor Bottleneck Operations Study – ODOT
Region 1.
Oregon Department of Transportation (ODOT). 2013b. Oregon Statewide Transportation Strategy. A
2050 Vision for Greenhouse Gas Emissions Reduction.
Oregon Department of Transportation (ODOT). 2014. Oregon Highways Seismic Plus Report.
https://www.oregon.gov/ODOT/Bridge/Docs_Seismic/Seismic-Plus-Report_2014.pdf. Accessed
August 31, 2022.
Oregon Department of Transportation (ODOT). 2017. Personal communication with Benjamin White,
ODOT Biologist, regarding species in the area of potential effect, on September 14, 2017.
Oregon Department of Transportation (ODOT). 2018a. Oregon Application to FHWA: Value Pricing
Feasibility Analysis and Proposed Implementation.
https://www.oregon.gov/odot/tolling/ResourcesHistory/VP%20Final_FHWAApplication_Draft.pdf.
Oregon Department of Transportation (ODOT). 2018b. Portland Region 2018 Traffic Performance Report.

I-205 Toll Project
Oregon Department of Transportation (ODOT). 2019. 2018 Transportation Volume Tables.

https://www.oregon.gov/ODOT/Data/Documents/TVT_complete_2018.pdf. Accessed February 3,
2020.
Oregon Department of Transportation (ODOT). 2020a. Active 2021-2024 Statewide Transportation
Improvement Program. https://www.oregon.gov/odot/STIP/Documents/OnlineSTIP_Public.pdf.
Oregon Department of Transportation (ODOT). 2020b. HazMat Program Manual.
https://www.oregon.gov/odot/GeoEnvironmental/Docs_GeologyGeotech/HazMat_Program_Manu
al.pdf. Accessed June 9, 2022.
Oregon Department of Transportation (ODOT). 2020c. I-5 and I-205 Toll Projects Draft Toll Projects’
Equity Framework.
Oregon Department of Transportation (ODOT). 2020d. Transportation Planning and Analysis Unit
Analysis Procedures Manual. https://www.oregon.gov/odot/Planning/Documents/APMv2.pdf
Oregon Department of Transportation (ODOT). 2021a. Observed Statewide Traffic Volume Patterns
Related to COVID-19 Monitoring.
https://www.oregon.gov/odot/Data/Documents/ODOT_TrafficReport_July_9_2021.pdf. Accessed
August 31, 2022.
Oregon Department of Transportation (ODOT). 2021b. 2020 Traffic Performance Report.
Oregon Department of Transportation (ODOT). 2021c. Oregon Standard Specifications for Construction.
https://www.oregon.gov/odot/Business/Specs/2021_STANDARD_SPECIFICATIONS.pdf.
Accessed August 12, 2022.
Oregon Department of Transportation (ODOT). 2021d. Climate Action Plan 2021-2026. July 2021.
Oregon Department of Transportation (ODOT). 2022a. Re-Evaluation of the Categorical Exclusion for the
I-205: Stafford Road to OR 213 Improvements Project.
https://www.oregon.gov/odot/tolling/I205%20Files/I-
205%20Improvements%20Project%20CE_Reevaluation_050422_signed.pdf. Accessed August
31, 2022.
Oregon Department of Transportation (ODOT). 2022b. I-205 Toll Project: Level 2 Toll Traffic and
Revenue Study Report. August 2022.
Oregon Department of Transportation (ODOT). 2022c. Low-Income Toll Report: Options to Develop a
Low-Income Toll Program and Best Practices for Implementation.
Oregon Department of Transportation (ODOT). 2022d. Highway Safety Improvements Program
Countermeasures and Crash Reductions Factor.
Oregon Department of Transportation (ODOT). 2022e. Title VI Implementation Plan FFY 2022.
https://www.oregon.gov/odot/Business/OCR/SiteAssets/Lists/Non_Dis_Main_List/EditForm/ODO
T_Title_VI_Implementation_Plan_2022_FINAL.pdf. Accessed January 18, 2023.
Oregon Department of Transportation (ODOT). 2022f. Oregon Highway Plan Policy Amendment – Goal 6
Tolling and Congestion Pricing.
https://www.oregon.gov/odot/Planning/Documents/OHP_Goal_6_Policy.pdf. Accessed January
25, 2023.
Oregon Department of Transportation (ODOT) and Federal Highway Administration (FHWA). 2016. FAHP
Programmatic User’s Guide. https://www.oregon.gov/odot/GeoEnvironmental/Documents/FAHP-
Users-Guide-Update.pdf. Accessed October 18, 2022.
Oregon Global Warming Commission. 2018. 2018 Biennial Report to the Legislature for the 2019
Legislative Session. https://www.keeporegoncool.org/reports/. Accessed May 14, 2020.

I-205 Toll Project
Oregon Global Warming Commission. 2020. 2020 Biennial Report to the Legislature.
https://static1.squarespace.com/static/59c554e0f09ca40655ea6eb0/t/5fe137fac70e3835b6e8f58e
/1608595458463/2020-OGWC-Biennial-Report-Legislature.pdf.
Oregon Historical Society. 2018. The Oregon History Project.
https://www.oregonhistoryproject.org/narratives/wooden-beams-and-railroad-ties-the-history-of-
oregons-built-environment/international-northwest-and-cryptic-styles/roads-to-freeways-building-
and-land-preservation/#.YPhkLD2Sk2y. Accessed July 20, 2021.
Oregon Legislative Revenue Office. 2022. 2022 Oregon Public Finance: Basic Facts: Research Report
#1-22. https://www.oregonlegislature.gov/lro/Documents/Final%20Basic%20Facts%202022.pdf.
Oregon Walks. 2021. Fatal Pedestrian Crash Report. https://oregonwalks.org/fatal-pedestrian-crash-
report/. Accessed January 4, 2022.
Reynolds Engineering. 2020. Structure Survey. I-205: Stafford Road to OR99E Project. October 2020.
Satake, K., K. Shimazaki, Y. Tsuji, and K. Ueda (Satake et al.). 1996. “Time and size of a giant
earthquake in Cascadia inferred from Japanese tsunami records of January 1700.” Nature, 379,
p. 246-249.
Shannon & Wilson. 2020. Geotechnical Report, I-205: Stafford Road to OR 99E Widening. Rock Cut. May
2020.
Stafford Hamlet. 2020. Community Vision Plan. https://staffordhamlet.com/community-vision-plan/.
Accessed November 14, 2022.
State of Oregon. 2020a. Directing State Agencies to Take Actions to Reduce and Regulate Greenhouse
Gas Emissions. March 10, 2020.
https://www.oregon.gov/gov/Documents/executive_orders/eo_20-04.pdf. Accessed January 4,
2021.
State of Oregon. 2020b. State of Oregon Equity Framework in COVID-19 Response and Recovery.
https://www.oregon.gov/gov/policy/Documents/EquityFrameworkCovid19_2020.pdf. Accessed
September 16, 2021.
Tax Policy Center. 2020. Briefing Book: Key Elements of the U.S. Tax System – What is the Highway
Trust Fund and how is it financed? https://www.taxpolicycenter.org/briefing-book/what-highway-
trust-fund-and-how-it-financed#:~:text=Budget%20and%20Economy-
,What%20is%20the%20Highway%20Trust%20Fund%2C%20and%20how%20is%20it,on%20gas
oline%20and%20diesel%20fuel. Accessed September 8, 2022.
Transportation Vision Panel. 2016. One Oregon – A Vision for Oregon’s Transportation System.
https://visionpanel.files.wordpress.com/2016/05/one-oregon-final-report-web-version2.pdf.
Tri-County Metropolitan Transportation District (TriMet). 2019. Draft Language Access Plan.
https://trimet.org/equity/pdf/2019-draft-lap.pdf. Accessed February 1, 2022.
U.S. Bureau of Labor Statistics. 2021. Current Employment Statistics. https://www.bls.gov/ces/. Accessed
July 19, 2022.
U.S. Census Bureau. No Date-a (n.d.-a). American Community Survey: Households and Families, 2010-
2018 [Data set]. Retrieved July 31, 2021, from http://data.census.gov.
U.S. Census Bureau. No Date (n.d.-b). American Community Survey: Median Household Income, 2010-
2018 [Data set]. Retrieved July 31, 2021, from http://data.census.gov.
U.S. Census Bureau. 2021. American Community Survey 2015-2019 Estimates.
https://www.census.gov/acs/www/data/data-tables-and-tools/data-profiles/2019/. Accessed June
13, 2022.

I-205 Toll Project
U.S. Census Bureau. 2022. U.S. Census Bureau QuickFacts.

https://www.census.gov/quickfacts/fact/table/US/PST045221. Accessed June 13, 2022.
U.S. Department of Energy. 2015. Idling Reduction for Personal Vehicles.
https://afdc.energy.gov/files/u/publication/idling_personal_vehicles.pdf. Accessed June 30, 2022.
U.S. Department of Health and Human Services. 2020. 2020 Poverty Guidelines.
https://aspe.hhs.gov/topics/poverty-economic-mobility/poverty-guidelines/prior-hhs-poverty-
guidelines-federal-register-references/2020-poverty-guidelines.
U.S. Department of the Interior. 2007. “Deputy Secretary of the Interior Lynn Scarlett to Participate in
Ribbon Cuttings at Two New National Trails in Oregon.”
https://www.doi.gov/sites/default/files/archive/news/archive/07_News_Releases/070604.html.
Accessed December 8, 2022.
U.S. Department of Transportation. 2012. Department of Transportation Updated Environmental Justice
Order 5610.2a. May 2, 2012.
U.S. Energy Information Administration. 2021. State Energy Data System (SEDS): 1960-2019 (complete).
https://www.eia.gov/state/seds/seds-data-complete.php?sid=US.
U.S. Environmental Protection Agency. 2016. Promising Practices for EJ Methodologies in NEPA
Reviews: Report of the Federal Interagency Working Group on Environmental Justice & NEPA
Committee. https://www.epa.gov/sites/production/files/2016-
08/documents/nepa_promising_practices_document_2016.pdf. Accessed June 9, 2020.
Washington State Department of Ecology. No date (n.d.). Wetland Mitigation Banking.
https://ecology.wa.gov/Water-Shorelines/Wetlands/Mitigation/Wetland-mitigation-banking.
Accessed October 7, 2022.
Willamette Falls Legacy Project. 2014. A Vision for the Willamette Falls Legacy Project.
https://www.willamettefallslegacy.org/wp-
content/uploads/2015/06/vision_report_revised_for_web.pdf. Accessed July 19, 2021.

I-205 Toll Project
7 Glossary
Term Definition
A-weighted decibel scale A scale used to measure loudness of sound that is adjusted to the frequency response of
(dBA) the human ear.
AM peak period The two morning hours with the highest travel volumes (7 a.m. to 9 a.m.)
Area of potential impact The geographic area within which the project may result in direct or indirect impacts.
(API) Different resource areas (e.g., land use, fish and wildlife, etc.) may have different API
boundaries based on potential impacts.
Build Alternative The Build Alternative includes tolls at the Abernethy Bridge and Tualatin River Bridges and
toll-funded I-205 improvements. Future conditions under the Build Alternative would include
three through lanes in each direction of I-205 between the Stafford Road interchange and
the OR 213 interchange, as well as replacement of or seismic upgrades to eight bridges
along I-205.
Congestion Congestion occurs when the demand is greater than the transportation system’s capacity.
For highways, congestion occurs when the average speed along a section of highway or on
a particular facility falls below a specified speed, generally below 30 miles per hour (mph).
Recurrent congestion is caused by constant excess volume compared to capacity.
Nonrecurring congestion is caused by actions such as special events and/or traffic
incidents.
Congestion pricing Congestion pricing, sometimes known as value pricing or variable rate tolling, is a strategy
that charges higher fees to use roads or bridges during “rush hour” in an effort to shift trips
to less congested times of day.
Corridor A portion of a roadway, typically an arterial street or highway, studied in this EA.
Construction staging A designated area where vehicles, supplies, and construction equipment are positioned for
access and use to a construction site.
Criteria pollutants This is a group of six common air pollutants for which the EPA has set National Ambient Air
Quality Standards (NAAQS): ozone (O3), particulate matter (PM10 and PM2.5), carbon
monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), and lead.
Cumulative effect The effect on the environment, which results from the incremental impact of the action
(cumulative impact) when added to other past, present, and reasonably foreseeable future actions, regardless
of what agency or person undertakes such other actions. Cumulative effects result from
individually minor but collectively significant actions taking place over a period of time.
Decibels A unit for relative sound intensity. For highway traffic noise, an adjustment, or weighting, of
the high and low-pitched sounds is made to approximate the way that an average person
hears sounds. The adjusted sounds are called “A-weighted levels” (dBA).
Disabled A person having a long-lasting condition, such as severe vision or hearing impairments, or
a condition that substantially limits basic physical activities. It may also include people with
conditions that make other activities such as learning, getting around inside the home,
working at a job, or going places outside the home difficult.
Environmental justice The fair treatment and meaningful involvement of all people regardless of race, color,
national origin, or income, with respect to the development, implementation, and
enforcement of environmental laws, regulations, and policies. Fair treatment means no
group of people should bear a disproportionate share of the negative environmental
consequences resulting from industrial, governmental and commercial operations or
policies. Meaningful involvement means: people have an opportunity to participate in
decisions about activities that may affect their environment and/or health; the public's
contribution can influence the regulatory agency's decision; community concerns will be
considered in the decision-making process; and decision makers will seek out and facilitate
the involvement of those potentially affected.
Hispanic/Latino A self-designated classification for people whose origins are from Spain, the Spanish-
speaking countries of Central or South America, the Caribbean, or those identifying
themselves generally as Spanish, Spanish-American, etc. Origin is viewed as ancestry,
nationality, or country of birth of the person or person’s parents or ancestors. Hispanic/
Latino persons may be of any race, White and non-White.
Hours of Congestion The hours of congestion for a corridor is the total number of hours that the corridor has at
least one congestion location.

I-205 Toll Project
Term Definition
Indirect effects Effects are caused by the proposed action or alternative and are later in time or farther
removed in distance, but still reasonably foreseeable. Indirect effects may include growth-
inducing effects and other effects related to induced changes in the pattern of land use,
population density or growth rate, and related effects on air and water and other natural
systems.
Job years Job-years is a metric in economics analyses that refers to the equivalent of an employee
working for 2,080 hours in a year. For example, a full-time employee working for three
years would be equal to three job-years, while three part-time employees working a total of
2,080 hours in a year would be equivalent to one job-year.
Level of service (LOS) A qualitative measure of the effectiveness of one or more elements of transportation
infrastructure. LOS is most commonly used to describe roadway performance, but can also
be applied to transit, intersections, or other infrastructure elements. The AASHTO defines
the following levels-of-service: A= Free flow; B=Reasonably free flow; C=Stable flow;
D=Approaching unstable flow; E=Unstable flow; and F=Forced or breakdown flow.
Level of Traffic Stress LTS is an analysis method used to quantify multimodal conditions by estimating the
(LTS) perceived safety of bicycle and pedestrian infrastructure. The LTS analysis provides scores
of 1 through 4 for each mode, with level 1 representing little or no traffic stress and level 4
representing high stress.
Limited English Individuals who do not speak English as their primary language and who have a limited
Proficiency (LEP) ability to read, speak, write, or understand English.
Low-income As defined in the USDOT Updated Order on Environmental Justice, “low-income” means a
person whose median household income is at or below the U.S. Department of Health and
Human Services poverty guidelines (USDOT 2012). To be more inclusive and account for
variability in the cost of living, the I-205 Toll Project Team adopted the definition of the low-
income as 200% of the federal poverty level to be consistent with data available through
the U.S. Census Bureau, to be aligned with regional and stakeholder definitions of low-
income, and to be more inclusive of the costs of living.
Minority A person who is: Black (a person having origins in any of the black racial groups of Africa);
Hispanic (a person of Mexican, Puerto Rican, Cuban, Central or South American, or the
Spanish culture or origin, regardless of race); Asian/Pacific Islander (a person having
origins in any of the original peoples of the Far East, Southeast Asia, the Indian
subcontinent, or the Pacific Islands); or American Indian or Alaskan Native (a person
having origins in any of the original peoples of North America, and who maintains cultural
identification through tribal affiliation or community recognition).
Mitigation A measure that could be taken to lessen the negative effects predicted for each resource.
These measures may include reducing or minimizing a specific negative effect, avoiding it
completely, or rectifying or compensating for the negative effect.
Mobile Source Air Toxics The Clean Air Act identifies 188 air toxics, of which MSATs are the subset emitted by
(MSATs) mobile sources. Although MSATs pose potential public health concerns, there are no
established regulatory limits for relevant MSAT pollutants.
National Ambient Air The maximum allowable level, averaged over a specific time period, for a certain air
Quality Standards pollutant in the outdoor air.
(NAAQS)
National Environmental The federal policy that requires agencies to incorporate environmental considerations into
Policy Act (NEPA) decision making by preparing an environmental assessment or environmental impact
statement that consider the effects of proposed actions.
No Build Alternative The No Build Alternative provides a baseline for comparing the potential impacts of the
Build Alternative. The No Build Alternative consists of existing conditions and any planned
actions with committed funding in the I-205 Toll Project study area.
Noise abatement criteria If future noise levels with a project are predicted to approach or exceed the FHWA noise
(NAC) criteria at a sensitive receptor, abatement is evaluated at the receptor. For residences, the
criterion is 67 dBA.
Mainline The through travel lines of a highway.

I-205 Toll Project
Term Definition
Participating agency Under 23 U.S.C. 139, a “participating agency” is any federal or nonfederal agency (federal,
state, tribal, regional, or local government agency) that may have an interest in the project.
This provides a method for agencies that do not have permitting or approval authority over
any portion of the project to have a more formal role in the environmental review and
comment process. Nongovernmental organizations and private entities cannot serve as
participating agencies.
Particulate matter (PM10 Naturally-occurring and man-made particles with a diameter less than 10 microns (PM10) or
or PM2.5) 2.5 (PM2.5) microns. Sources of particulate matter include sea salt, pollen, road dust,
agricultural dust.
PM peak period The two afternoon hours with the highest travel volumes (4 p.m. to 6 p.m.)
Purpose and Need A formal statement of the objective(s) of the proposed project (Purpose) and the problem(s)
that the project is intended to solve (Need). The Purpose and Need Statement is developed
early in the project planning stage and serves as a guideline for future project efforts. For
example, in evaluating alternatives, any alternative that does not meet the project’s
purpose and need will be dropped from consideration.
Section 129 A federal program under 23 U.S. Code that regulates authorization of toll roads, bridges,
tunnels, and ferries.
Toll Gantry Vertical columns on the outside of travel lanes that support a horizontal structure spanning
the travel lanes in which electronic tolling equipment is attached to.
Unbanked populations People who do not have access to conventional financial services.
Value Pricing Pilot A federal program established by the U.S. Congress in 1991 that has supported projects
Program nationwide. The intent of the projects is to demonstrate whether and to what extent
roadway congestion may be reduced through congestion pricing strategies, and the
magnitude of the impact of such strategies on driver behavior, traffic volumes, transit
ridership, air quality and availability of funds for transportation programs.
Variable-rate tolls Fees to use a road or bridge that vary based on time of day. It can be a strategy to shift
demand to less congested times of day and is sometimes known as congestion pricing or
value pricing.
Vehicle hours of delay The number of hours that a vehicle must wait, particularly at intersections. This metric is
typically measured in seconds, with hours used to show broader delay experienced over
longer periods of time (e.g., annually). The amount of delay can then be used to gauge
overall congestion levels based on predefined ranges and thresholds (known as Level of
Service).
Vehicle miles traveled The total number of miles that vehicles are driven in a specified period of time for a given
(VMT) area or transportation facility.
Viewshed The portion of the landscape that can be seen from within the project area and that has
views of the project area. The boundaries of a viewshed are determined by the surrounding
topography, vegetation, and built environment.
Visual quality Character of the landscape, which generally gives visual value to a setting.
Volume-to-capacity ratio Volume-to-capacity ratios measure the level of congestion on a roadway by dividing the
volume of traffic by the capacity of the roadway.

I-205 Toll Project

I-205 Toll Project Environmental Assessment - 508

Uploaded by

Copyright:

Available Formats

I-205 Toll Project Environmental Assessment - 508

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

I-205 Toll Project Environmental Assessment - 508

Uploaded by

Copyright:

Available Formats

I-205 Toll Project

This page intentionally left blank.

This page intentionally left blank.

I-205 Toll Project

February 14, 2023

Mandy Putney Thomas Parker

This page intentionally left blank.

Notice of Document Availability

Oregon City Public Library Tualatin Public Library

West Linn Public Library Canby Public Library

How to Submit Comments

3.8 Environmental Justice ...................................................................................................... 3-86

www.OregonTolling.org Page iii

Table 3-42. Summary of Land Use Effects by Alternative............................................................... 3-106

Acronyms and Abbreviations

www.OregonTolling.org Page vii

www.OregonTolling.org Page viii

Figure 1-1. I-205 Toll Project Area

www.OregonTolling.org Page 1-1

1.2 Background and Context

www.OregonTolling.org Page 1-2

www.OregonTolling.org Page 1-3

1.4.2 Traffic Congestion Results in Unreliable Travel

www.OregonTolling.org Page 1-4

1.4.3 Traffic Congestion Affects Freight Movement

1.4.4 Traffic Congestion Affects Safety

1.4.5 Traffic Congestion Contributes to Climate Change

www.OregonTolling.org Page 1-5

1.4.6 Oregon’s Highway System is Not Seismically Resilient

1.5 Goals and Objectives

www.OregonTolling.org Page 1-6

1.6 Next Steps

www.OregonTolling.org Page 1-7

www.OregonTolling.org Page 1-8

2.1.1 No Build Alternative

2.1.2 Build Alternative

www.OregonTolling.org Page 2-1

Figure 2-1. Schematic Diagrams of No Build and Build Alternatives

www.OregonTolling.org Page 2-2

www.OregonTolling.org Page 2-3

Bridge Tolls – Abernethy and Tualatin River Bridges

The I-205 toll system would be designed to be

www.OregonTolling.org Page 2-4

Toll Rate Assumptions

www.OregonTolling.org Page 2-5

Bridge Reconstructions and Replacements

www.OregonTolling.org Page 2-6

Traveler Information Signs (Active Traffic Management Improvements)

Anticipated Permits and Approvals

www.OregonTolling.org Page 2-7

Table 2-1. List of Anticipated Environmental Permits and Approvals

2.2 Alternatives Considered but Not Advanced

Appendix A provides a more detailed analysis of tolling alternatives.

www.OregonTolling.org Page 2-8

2.2.1 Alternative 1: Abernethy Bridge Toll

Figure 2-4. Alternative 1: Abernethy Bridge Toll

www.OregonTolling.org Page 2-9

2.2.2 Alternative 2: Abernethy Bridge Toll with Off-Bridge Gantries

Figure 2-5. Alternative 2: Abernethy Bridge Toll with Off-Bridge Gantries