The Defenders Comments on the 2040 Plan, submitted to CMAP
August 6, 2010
From: Environmental Defenders of McHenry County, 124 Cass St. Ste 3,
Woodstock IL 60098
RE: Comments on Go To 2040 Plan
The Environmental Defenders of McHenry County support CMAP commitment to
“plan more effectively for the livability of communities” (defined by
the residents of our region as healthy, safe, walkable— with
transportation choices and a ‘sense of place’) in the Go To 2040 Plan.
Because our organization’s mission is ‘Citizens Working for a Healthy
Environment’, we have concentrated our review on plan recommendations
which most directly have environmental consequences.
We support the conservation of energy and water as a top priority. We
support retrofitting buildings for increased energy efficiency and
maximizing the energy efficiency of new buildings as well as integrating
water conservation goals with land use planning, preserving open space
in aquifer recharge areas and using green infrastructure to manage
We wholeheartedly agree that “Access to parks and open space is part of
what makes up quality of life, and open space also has a crucial role in
flood protection, public health, drinking water supply and quality, and
adaptation to climate change.” Specifically, we support the call for a
green infrastructure network that follows waterway corridors, expands
existing preserves, and creates new preserves in the region with a
target of an additional 150,000 acres of land to be preserved across the
region over the next 30 years.
We support the concept of building a sustainable local food-shed, which
would help in preservation of our region’s remaining farmland, among the
best in the world, as well as reducing the energy costs associated with
bringing in food from distant places and providing people in our region
with fresh, healthy food.
On Regional Mobility, we agree with calls for investment in the existing
system and a focus on improving the public transit system.
However, as we read the details of the plan, we have specific concerns
which we raise below. Excerpts from the plan are followed by our
Challenges and Opportunities Section
Page 26 Energy and water are not being used efficiently and the region
suffers from the degradation of air and water quality.
Page 42 The region should conserve energy and water resources by
reducing its consumption in our residential and commercial buildings.
Critical concerns about the quality of the region’s air and water
described in the first excerpt are not addressed by the focus on
conservation in the second excerpt which was taken from the Conclusion
of this section. Specifically, we need to address the quality of our
region’s water resources not just the quality of water supplies.
Livable Communities Section
Page 51 By incorporating open space, carefully designing buildings and
landscapes, and using small-scale green infrastructure features, the
localized negative impacts of density can be avoided.
This is an important, necessary point if we are to sustain and improve
the quality of the water resources of our region.
Page 59 Technical assistance activities will often take the form of
creating model ordinances or codes for municipal consideration, often on
topics like water conservation that may be outside of usual
comprehensive planning practice.
The plan should note the important leadership which NIPC/CMAP has
provided the region in developing model ordinances addressing water
quality issues, consistent with its responsibility for the Regional
Water Quality Management Plan. These have been important tools for
communities which CMAP needs to continuously update and promote to
Page 72 Integrate land use policies and site planning with water
resources. Land use policies that promote compact development will
reduce residential water use and reduce both capital and operating costs
for water utilities. Green infrastructure, like rain gardens and
permeable pavement, should be integrated more fully into site planning.
Using green infrastructure to manage stormwater has many benefits and
can be more cost effective when compared with gray infrastructure.
The plan should directly state the groundwater recharge, improved
surface water quality and reduced flooding benefits of using green
infrastructure to infiltrate stormwater.
Page 72 Communities that are dependent on groundwater should consider
accessing water from the Fox and Kankakee Rivers.
Communities that are dependent on groundwater should be encouraged to
vigorously pursue a water management strategy which puts water taken
from the ground back on the ground in order to recharge their aquifers.
The concerns about the effects of both direct surface water withdrawals
and lowering of the water table due to shallow groundwater pumping on
the aquatic life in the Fox and Kankakee Rivers cannot be ignored.
Page 80 According to the Illinois State Water Survey (ISWS), flow in the
Fox River will continue to increase as a result of population growth and
the associated wastewater discharge. As a result, the Fox River has the
potential to supply significant new water demands.
That population growth will lead to new wastewater discharges and new
water available in the Fox River for human needs should not be assumed.
As communities seek to sustain their groundwater supplies, it is likely
that they will opt to land apply their wastewater in order to recharge
the water to the aquifer from which it was taken. This is especially
likely in McHenry County where the bulk of available groundwater is
found in the shallow aquifer. Thus, population growth in McHenry County
is not likely lead to the assumed increased flows in the Fox River.
Page 81 Furthermore, federally-imposed standards on water providers to
control emerging contaminants, such as pharmaceuticals and personal care
products, demand costly and energy intensive treatment processes. It is
important that the energy implications of such standards are closely
studied and mitigated before enforcement.
This statement is disturbing as it does not weigh the serious concerns
which are emerging about the adverse impacts which pharmaceuticals and
personal care products have on aquatic life which live in streams
receiving wastewater dischargers and on the people who take their
drinking water supplies from the waters. Cost and energy should not be
the predominant considerations.
Page 94 Ideally a watershed plan will consider multi-objective projects
that address several problems simultaneously.
Defenders strongly support planning on a watershed scale to
simultaneously address water quality, water supply and green
Regional Mobility Section
Our comments on the specifics in this section are summed up by the
following quote from the book Suburban Nation. A longer excerpt is found
in the endnote to these comments.[i]
“If, as is now clear beyond any reasonable doubt, people maintain an
equilibrium of just-bearable traffic, then the traffic engineers are
wasting their time--and our money--on a whole new set of stopgap
measures that produce temporary results as best. These measures, which
include HOV (high-occupancy vehicle) lanes, congestion pricing, timed
traffic lights, and "smart streets," serve only to increase highway
capacity, which causes more people to drive until the equilibrium
condition of crowding returns. While certainly less wasteful than new
construction, these measures also do nothing to address the real cause
of traffic congestion, which is that people choose to put up with it.” -
An excerpt from Suburban Nation: The Rise of Sprawl and the Decline of
the American Dream
From: "If you don't want an automobile, you don't have to have one." -
Secretary of Transportation Ray LaHood’s definition of Livability
Page 67 "require supportive land use planning before new transit
investment is made."
Some land use patterns cannot support transit oriented developments/
investments. Roads must be evaluated in the same context. Land use
planning needs to take place before expanded road investments are made.
(i.e., Alden Road, Fleming Road project in McHenry County)
Page 166 “While finding new revenues is important, the region needs to
get more serious about setting priorities for how existing funds are
spent, on both the operating and capital side. The region’s
transportation decision makers should stress the use of
performance-driven criteria, rather than arbitrary formulas, when making
investment decisions. CMAP strongly recommends a focus on maintaining
the existing system first, and using most of our remaining resources to
modernize the system. While some expansions are necessary, and these
will be recommended in the plan’s list of major capital projects, very
few of these projects require building brand new facilities from
scratch. Instead, the emphasis is on making the existing system operate
more efficiently given the amount of funding we can reasonably expect to
- Once you start listing priority projects, everyone forgets what you
just said – all they hear is “this project is a priority”.
- Widening and extending roads does not decrease congestion over time.
Focus should be on public transportation systems.
- Good to maintain the existing system – but we also need to consider
difference construction standards for roads – if build properly, roads
can require much less maintenance and can last longer. Use road
construction best practices (e.g. many of Canada’s roadways) to reduce
deterioration and maintenance (planned obsolescence).
- Modernizing the system should be focused on the public transportation
infrastructure – the only way to truly reduce road congestion is to get
people out of cars and into busses, trains, etc. Subsidizing the cost of
public transportation coupled with elimination of national subsidies for
gasoline can assist here.
Page 167 “Making our system “world class” does not simply require
raising taxes or fees for more revenue, nor does it require expanding
the system much beyond what is here today. Instead, the primary goal
should be to prioritize spending on maintenance and modernization
efforts. “Modernization” comprises a range of enhancements, including
more comfortable and attractive trains, buses and stations, traveler
information systems, state of the art pavement materials with longer
life spans, signal timing improvements, bus stop improvements, corridor
upgrades, and a variety of other strategies that can improve mobility,
access, and the reliability of our transportation network.
- This is excellent (minus the corridor upgrades), but you have to mean
- One thing is said here, but then the plan steps in the opposite
direction with the priority projects list.
Page 171 “Long-term lease agreements (like the leasing of the Chicago
Skyway) involve a publicly- financed transportation facility that is
leased to a private-sector entity for a prescribed period of time during
which the private entity has the right to collect revenue from the
operation of the facility. In exchange, the private entity must operate
and maintain the facility, and in some cases make improvements to it.”
- We are highly skeptical of this approach.
- This creates a “lowest-common-denominator” quality of project.
- This also creates a system where the project most likely to make money
for a private interest is what gets built, over the project that is high
quality but less profitable.
Page 185 “Both auto and transit trips increase, and transit’s mode share
grows slightly. The high-priority projects support GO TO 2040’s focus on
reinvestment in existing communities, and they have limited impact on
sensitive natural areas. On the other hand, the projects do have
negative impacts on most air quality outcomes. This occurs mostly
because the region is expected to be larger (in terms of households and
jobs) than it would have been without the projects, and also because the
projects improve mobility within the region and hence lead to additional
travel. The negative impacts on air quality are minor, and are more than
compensated for by the positive impacts of the strategies within GO TO
2040. They are also well within expected air quality conformity limits.”
- The plan needs to promote steps to improve regional air quality, not
make it even worse by proposing a suite of projects which will make the
New Projects or Extensions
Central Lake County Corridor: IL 53 North and IL 120 Limited Access
Elgin O'Hare Expressway Improvements (includes Western O'Hare Bypass,
Extension, and EOE Add Lanes)
-Better to use the money spent on these projects to improve mass transit
- IL 53 North corridor runs contrary to stated intent of the plan
CTA Red Line Extension (South)
West Loop Transportation Center
Expressway Additions and Improvements
I-190 Access Improvements
I-80 Add Lanes (US 30 to US 45)
I-88 Add Lanes
I-94 Add Lanes North
I-294/I-57 Interchange Addition
- Better to use the money spent on these projects to improve mass
transit. Increasing the load capacity on these areas is ultimately short
sighted (See quote from Suburban Nation and endnote.)
Managed Lanes and Multimodal Corridors
I-55 Managed Lanes
I-90 Managed Lanes
I-290 Multimodal Corridor
- Better to use the money spent on these projects to improve mass
transit. Increasing the load capacity on these areas is ultimately short
sighted (See quote from Suburban Nation and endnote.)
CTA North Red/Purple Line Improvements
Metra Rock Island Improvements
Metra Southwest Service Improvements.
Metra UP North Improvements
Metra UP Northwest Improvements/Extension
Metra UP West Improvements
- Need to ensure that these improvements are not built in far out places
that do not and should not have the population capacity needed to
sustain or justify their construction and maintenance. Mass
transportation is self defeating if it ends up actually encouraging
sprawl development by pacing itself ahead of perceived demands.
[i] Why building new roads doesn't ease congestion
An excerpt from Suburban Nation: The Rise of Sprawl and the Decline of
the American Dream
by Andres Duany, Elizabeth Plater-Zyberk, and Jeff Speck
North Point Press, 2000, pp. 88-94.
There is, however, a much deeper problem than the way highways are
placed and managed. It raises the question of why we are still building
highways at all. The simple truth is that building more highways and
widening existing roads, almost always motivated by concern over
traffic, does nothing to reduce traffic. In the long run, in fact, it
increases traffic. This revelation is so counterintuitive that it bears
repeating: adding lanes makes traffic worse. This paradox was suspected
as early as 1942 by Robert Moses, who noticed that the highways he had
built around New York City in 1939 were somehow generating greater
traffic problems than had existed previously. Since then, the phenomenon
has been well documented, most notably in 1989, when the Southern
California Association of Governments concluded that traffic-assistance
measures, be they adding lanes, or even double-decking the roadways,
would have no more than a cosmetic effect on Los Angeles' traffic
problems. The best it could offer was to tell people to work closer to
home, which is precisely what highway building mitigates against.
Across the Atlantic, the British government reached a similar
conclusion. Its studies showed that increased traffic capacity causes
people to drive more--a lot more--such that half of any driving-time
savings generated by new roadways are lost in the short run. In the long
run, potentially all savings are expected to be lost. In the words of
the Transport Minister, "The fact of the matter is that we cannot tackle
our traffic problems by building more roads."2 While the British have
responded to this discovery by drastically cutting their road-building
budgets, no such thing can be said about Americans.
There is no shortage of hard data. A recent University of California at
Berkeley study covering thirty California counties between 1973 and 1990
found that, for every 10 percent increase in roadway capacity, traffic
increased 9 percent within four years' time.3 For anecdotal evidence,
one need only look at commuting patterns in those cities with expensive
new highway systems. USA Today published the following report on
Atlanta: "For years, Atlanta tried to ward off traffic problems by
building more miles of highways per capita than any other urban area
except Kansas City…As a result of the area's sprawl, Atlantans now drive
an average of 35 miles a day, more than residents of any other city."·
This phenomenon, which is now well known to those members of the
transportation industry who wish to acknowledge it, has come to be
called induced traffic.
The mechanism at work behind induced traffic is elegantly explained by
an aphorism gaining popularity among traffic engineers: "Trying to cure
traffic congestion by adding more capacity is like trying to cure
obesity by loosening your belt." Increased traffic capacity makes longer
commutes less burdensome, and as a result, people are willing to live
farther and farther from their workplace. As increasing numbers of
people make similar decisions, the long-distance commute grows as
crowded as the inner city, commuters clamor for additional lanes, and
the cycle repeats itself. This problem is compounded by the hierarchical
organization of the new roadways, which concentrate through traffic on
as few streets as possible.
The phenomenon of induced traffic works in reverse as well. When New
York's West Side Highway collapsed in 1973, an NYDOT study showed that
93 percent of the car trips lost did not reappear elsewhere; people
simply stopped driving. A similar result accompanied the destruction of
San Francisco's Embarcadero Freeway in the 1989 earthquake. Citizens
voted to remove the freeway entirely despite the apocalyptic warnings of
traffic engineers. Surprisingly, a recent British study found that
downtown road removals tend to boost local economies, while new roads
lead to higher urban unemployment. So much for road-building as a way to
spur the economy.
If traffic is to be discussed responsibly, it must first be made clear
that the level of traffic which drivers experience daily, and which they
bemoan so vehemently, is only as high as they are willing to
countenance. If it were not, they would adjust their behavior and move,
carpool, take transit, or just stay at home, as some choose to do. How
crowded a roadway is at any given moment represents a condition of
equilibrium between people's desire to drive and their reluctance to
fight traffic. Because people are willing to suffer inordinately in
traffic before seeking alternatives--other than clamoring for more
highways--the state of equilibrium of all busy roads is to have
stop-and-go traffic. The question is not how many lanes must be built to
ease congestion but how many lanes of congestion would you want? Do you
favor four lanes of bumper-to-bumper traffic at rush hour, or sixteen?
This condition is best explained by what specialists call latent demand.
Since the real constraint on driving is traffic, not cost, people are
always ready to make more trips when the traffic goes away. The number
of latent trips is huge--perhaps 30 percent of existing traffic. Because
of latent demand, adding lanes is futile, since drivers are already
poised to use them up.4
While the befuddling fact of induced traffic is well understood by
sophisticated traffic engineers, it might as well be a secret, so poorly
has it been disseminated. The computer models that transportation
consultants use do not even consider it, and most local public works
directors have never heard of it at all. As a result, from Maine to
Hawaii, city, county, and even state engineering departments continue to
build more roadways in anticipation of increased traffic, and, in doing,
create that traffic. The most irksome aspect of this situation is that
these road-builders are never proved wrong; in fact, they are always
proved 'right': "You see," they say, "I told you that traffic was
The ramifications are quite unsettling. Almost all of the billions of
dollars spent on road-building over the past decades have accomplished
only one thing, which is to increase the amount of time that we must
spend in our cars each day. Americans now drive twice as many miles per
year as they did just twenty years ago. Since 1969, the number of miles
cars travel has grown at four times the population rate.· And we're just
getting started: federal highway officials predict that over the next
twenty years congestion will quadruple. Still, every congressman, it
seems, wants a new highway to his credit.·
Thankfully, alternatives to road-building are being offered, but they
are equally misguided. If, as is now clear beyond any reasonable doubt,
people maintain an equilibrium of just-bearable traffic, then the
traffic engineers are wasting their time--and our money--on a whole new
set of stopgap measures that produce temporary results as best. These
measures, which include HOV (high-occupancy vehicle) lanes, congestion
pricing, timed traffic lights, and "smart streets," serve only to
increase highway capacity, which causes more people to drive until the
equilibrium condition of crowding returns. While certainly less wasteful
than new construction, these measures also do nothing to address the
real cause of traffic congestion, which is that people choose to put up
We must admit that, in an ideal world, we would be able to build our way
out of traffic congestion. The new construction of 50 percent of more
highways nationwide would most likely overcome all of the latent demand.
However, to provide more than temporary relief, this huge investment
would have to be undertaken hand in hand with a moratorium on suburban
growth. Otherwise, the new subdivisions, shopping malls, and office
parks made possible by the new roadways would eventually choke them as
well. In the real world, such moratoriums are rarely possible, which is
why road-building is typically a folly.
Those who are skeptical of the need for a fundamental reconsideration of
transportation planning should take note of something we experienced a
few years ago. In a large working session on the design of Playa Vista,
an urban infill project in Los Angeles, the traffic engineer was
presenting a report of current and projected congestion around the
development. From our seat by the window, we had an unobstructed
rush-hour view of a street he had diagnosed as highly congested and in
need of widening. Why, then, was traffic flowing smoothly, with hardly
any stacking at the traffic light? When we asked, the traffic engineer
offered an answer that should be recorded permanently in the annals of
the profession: "The computer model that we use does not necessarily
bear any relationship to reality."
But the real question is why so many drivers choose to sit for hours in
bumper-to-bumper traffic without seeking alternatives. Is it a
manifestation of some deep-seated self-loathing, or are people just
stupid? The answer is that people are actually quite smart, and their
decision to submit themselves to the misery of suburban commuting is a
sophisticated response to a set of circumstances that are as troubling
as their result. Automobile use is the intelligent choice for most
Americans because it is what economists refer to as a "free good": the
consumer pays only a fraction of its true cost. The authors Stanley Hart
and Alvin Spivak have explained that:
We learn in first-year economics what happens when products or services
become "free" goods. The market functions chaotically; demand goes
through the roof. In most American cities, parking spaces, roads and
freeways are free goods. Local government services to the motorist and
to the trucking industry--traffic engineering, traffic control, traffic
lights, police and fire protection, street repair and maintenance--are
all free goods.·
This article is an excerpt from Andres Duany, Elizabeth Plater-Zyberk,
and Jeff Speck. Suburban Nation: The Rise of Sprawl and the Decline of
the American Dream, North Point Press, 2000, 88-94.
Donald D.T. Chen. "If You Build It, They Will Come…Why We Can't Build
Ourselves Our of Congestion." Surface Transportation Policy Project
Progress VII.2 (March 1998): I, 4.
Carol Jouzatis. "39 Million People Work, Live Outside City Centers." USA
Today, November 4, 1997: 1A-2A. As a result of its massive highway
construction, the Atlanta area is "one of the nation's worst violators
of Federal standards for ground-level ozone, with most of the problem
caused by motor-vehicle emissions" (Kevin Sack. "Governor Proposes
Remedy for Atlanta Sprawl." The New York Times, January 26, 1999: A14).
Jill Kruse. "Remove It and They Will Disappear: Why Building New Roads
Isn't Always the Answer." Surface Transportation Policy Project Progress
VII:2 (March 1998): 5, 7. This study, in analyzing sixty road closures
worldwide, found that 20 percent to 60 percent of driving trips
disappeared rather than materializing elsewhere.
Stanley Hart and Alvin Spivak. The Elephant in the Bedroom: Automobile
Dependence and Denial; Impacts on the Economy and Environment. Pasadena,
Calif.: New Paradigm Books, 1993, 122.
Jane Holtz Kay. Asphalt Nation: How the Automobile Took Over America,
and How We Can Take It Back. New York: Crown, 1997, 15; and Peter
Calthorpe. The Next American Metropolis: Ecology, Community, and the
American Dream. New York: Princeton Architectural Press, 1993, 27. Since
1983, the number of miles cars travel has grown at eight time s the
population rate (Urban Land Institute traffic study). The greatest
increases in automobile use correspond to the greatest concentrations of
sprawl. Annual gasoline consumption per person in Phoenix and Houston is
over 50 percent higher than in Chicago or Washington, D.C., and over 500
percent higher than in London or Tokyo (Peter Newman and Jeff Kenworthy.
Winning Back the Cities. Sydney: Photo Press, 1996, 9). Currently,
almost 70 percent of urban freeways are clogged during rush hour (Jason
Vest, Warren Cohen, and Mike Tharp. "Road Rage." U.S. News & World
Report, June 2, 1997: 24-30). In Los Angeles, congestion has already
reduced average freeway speeds to less than 31 mph; by the year 2010,
they are projected to fall to 11 mph (James MacKenzie, Roger Dower, and
Donald Chen. The Going Rate: What It Really Costs to Drive. Report by
the World Resources Institute, 1992, 17).
Almost any situation seems acceptable to justify more highway spending,
even the recent road rage epidemic. Representative Bud Schuster, the
chairman of the U.S. Congressional Committee on Transportation and
Infrastructure, made this recommendation: "The construction of
additional lanes, the widening of roads and the straightening of curves
would decrease congestion and reduce the impatience and unsafe habits of
some motorists" (Thomas Palmer. "Pacifying Road Warriors." The Boston
Globe, July 25, 1997: A1, B5).
Stanley Hard and Alvin Spivak, The Elephant in the Bedroom: Automobile
Dependence and Denial, 2. Much of the information here on the science
and economics of traffic congestion comes from this book, which should
be required reading for every professional planner, traffic engineer,
and amateur highway activist.
The logic behind the desire to make use of free goods is suggested by an
argument overheard at a recent planning conference: "Of course there's
never enough parking! If you gave everyone free pizza, would there be
GO TO 2040 "Invent the Future"
Workshops - 2009
Do you feel like your community and region are being shaped and growing
without concern for things that are important to you, like conserving
open space and natural habitats? If so, you have a critical role to play
as the voice of conservation. The time is now - literally!
Illinois, where they are sharing ideas for shaping our region as it grows over
the next 30 years. At these meetings, participants are asked to weigh in
on four scenarios CMAP developed that address quality of life issues
such as transportation, housing, jobs, air and water quality, and open
The Chicago Metropolitan Agency for Planning (CMAP) continues its
series of "Invent the Future" workshops throughout northeast
This is an important opportunity for your opinion to be heard loud
and clear in the planning process and by other engaged citizens. The
conversation about biodiversity starts with us. Please do not
assume someone else will be there to support a future of healthy green
communities. Your voice at these meetings can help ensure that as our
region and communities grow, they do so in a way that utilizes the many
principles of natural resource conservation that we know are good
practice, such as:
-Preservation and protection of open space
-Using public transportation to relieve congestion and reduce global
-Minimizing the development of natural areas and farmland
-Planning buffers between sensitive natural areas and intensive use
-Protecting and restoring water bodies and wetlands to prevent
flooding and preserve groundwater resources
to find workshops, or to use the online model!
-paraphrased from Chicago Wilderness