Maine DOT letter to Gorrill-Palmer Associates    August 11, 2004


This letter was written by Asst. State Traffic Engineer Steven Landry, after the Portland Peninsula Traffic Study was issued .

Mr. Landry had some problems with a number of the “findings” and proposals in the study.

Note:  That in the first paragraph Mr. Landry says: “….many of the items mentioned in the comments are issues I have mentioned at many of our meetings.”

I infer from this that Mr. Landry has discussed the problems that the Oaks Plan has a number of times  with the study committee, but they nonetheless have forged ahead with what they want to do, essentially ignoring him.

The answer to this letter is here:PDF The July 21, 2005 answer from Thomas Gorrill , of Gorrill -Palmer.


Ralph Norwood                                                                                                          August 11, 2004
Gorrill-Palmer Consulting Engineers
P.O. Box 1237
15 Shaker Road
Gray, Me 04039

RE: Portland Peninsula Traffic Study

Dear Ralph:

            I am writing to document some concerns raised by the Department’s Bureau of Planning regarding the Portland Peninsula Traffic Study Final Draft.  I  know these comments are coming late in the process, but many of the items mentioned in the comments are issues I have mentioned at many of our meetings.  This letter will serve as documentation of those comments.  The items highlighted in blue below are questions or comments the Department would like responses to.  Below please find the comments:

1.      Page i-paragraph 4 Objective 1 “First, that this plan, as an outgrowth of a traffic study, is not a comprehensive transportation plan for the Peninsula”.  This report outlines a plan and recommendations for roadways and vehicle movement and should not be considered separately from broader transportation documents serving the City of Portland and the region”.  Page 3-1 “This plan is intended to be consistent with Destination Tomorrow”.  How does this compare to Destination Tomorrow Objectives?

2.      Same paragraph above – Who at MDOT is working on this Alternative Transportation Study?

3.      Objective 2 page i – paragraph 5 “ This committee hopes that this study and report will provide a basis for looking at alternatives to “level of service” criteria at both the local regulation level and at the regional funding level”.  Why would you want to change national Engineering Principles and Standards?

4.      Guiding Principles and Objectives page v

·        Change the City Ordinance so that LOS criteria are not necessarily the driving force behind roadway improvement   “Traffic management techniques should be employed to AVOID CONGESTION AND MINIMIZE THE PHYSICAL AFFECTS OF INCREASED ROADWAY INFRASTRUCTURE and the loss of valuable land”.  The S2 Plan and the two-way system for State and High Street increases congestion.

5.      Page v “Maintain efficient traffic flow, acceptable LOS, and minimize air pollution”.  Plan S-2 violates this objective.

6.      Page v “Reduce the presence of HIGHWAY CORRIDOR THROUGH DEERING OAKS AND RESTORE STATE STREET AS A PARK ENTRANCE from Park Avenue”.  The MDOT has invested hundreds of thousands of dollars into building and maintaining Route 77; how can Portland downgrade such a facility?

7.      Page ix, “It is important to realize that these changes to State and High Streets result in the loss of some on-street parking as well as operational efficiency at certain locations.  However, the potential benefits in terms of vehicular speed and accessibility improvements offset these losses”.  Loss of on-street parking is a loss of accessibility.  How does loss of operational efficiency translate into vehicular speed improvements?

8.      Page x, “All vehicles routed from I-295 south (with Destinations to Bayside west of Preble Street) will be signed to the Forest Ave Interchange.  Vehicles would be directed to either Marginal Way or the proposed Somerset Street Extension”.    This would introduce a similar situation at Franklin and Marginal (east) where vehicles block the mainline in order to turn left.  Why would you want to introduce this?  What would prevent vehicles destined further east of this area to use this way?

9.      Page 1-2 “ The committee further recommends that two-way traffic be restored to both State and High Streets, for the critical purpose of reducing high-speed and cut-through traffic, renewing and preserving the residential and commercial areas currently isolated by these streets, and broadening the alternative routes available to drivers whose destination is Portland itself”.  How will this improve access for drivers destined for Portland itself?

10.  Page 2-2 Land Use Policy – “Adopt appropriate land use changes on streets chosen as high-volume preferred routes”.  What are these routes?  Is that why Mercy Hospital has access to the new I-295 Connector?

11.  Page 3-3 Parking Policy- “Periodic assessments of the urban density and parking supply should be undertaken to determine whether the evolving densities are sufficient to support a shift in investment strategy from parking and roadways to transit and alternative modes”.  Where is the City in taking an inventory of existing parking facilities, parking impact fees, and new parking facilities?

12.  Page 4-1 How was the Origin-Destination survey conducted?  How did you hand out the survey and how long did it take to receive them?  What is the percentage return on the survey?  Where is Appendix B that contains this information?

13.  Page 4-5 Table 4.2  Vehicles that Pass Through the Peninsula: 1,013 or 6%.  “Roughly half of the trips that pass through the Peninsula have one end of their trip located within the remainder of Portland (e.g. a trip between Woodfords Corner and South Portland).  Therefore, the proportion of vehicles crossing the Portland Peninsula cordon that do not stop in Portland (e.g. trips between Yarmouth and South Portland) is roughly three percent.  What is the Benefit / Cost ratio of redesigning Route 77 (S2) for roughly 500 vehicles?  

14.   On page 4-6 “This through-traffic link to Forest Avenue represents 65 percent of all through-trips on Casco Bay Bridge ( 1,225 of the 1893 total through-trips on Casco Bay Bridge”.  Why the doubling effect for through traffic and then adding AM and PM volumes together in Figure 4.2?  This makes it sound a lot worst than the 3% of through-traffic not destined in Portland.

15.  Chapter 5 is Traffic Forecasts- Why isn’t there traffic volumes in the report?  Chapter 5 should have figures.  Why doesn’t the report have maps of existing and future volumes as well as the Existing and Future LOS with the different options like Table 8.1 and Table 8.2?

16.  Where is the technical backup for the recommendations for Eastern Waterfront and Ocean Gateway?

17.  Figure 7.2 Concern with 3 outbound lanes past Marginal.  Will the Interstate have capacity issues with this configuration and no improvements to outbound ramps and 2 through lanes on I-295?

18.  Figure 7.2 Is the queue storage requirements for left turns into Fox adequate?  They seem short in comparison to left turns into Marginal.

19.  Page 7-6 “in order to preserve the left hand turn from Forest Ave on to Marginal Way, the Kennebec Street traffic would need to be re-directed….This recommendation is due in part to the need to make the proposed rail corridor work with the Forest Ave interchange and Marginal Way”.  The only vehicles that have access to Marginal Way from Forest Ave are those that are already on Forest Ave, those on the northbound off-ramp are not allowed to turn left onto Marginal.  Opening up that option in the future would have the same effect as Franklin Arterial is today.  Also, I don’t recall that the relocation is needed to make the rail corridor to work for Marginal Way Interchange.

20.  Page 7-7 “All vehicles routed from I-295 south (with destinations to Bayside west of Preble Street) will be signed to the Forest Ave Interchange.  Vehicles would be signed to either Marginal Way or the proposed Somerset Street Extension”.  This will be complicated to sign.

21.  Page 8-4 “Prohibiting left-turn movements on westbound Park Ave at High St”.  Figure S-2 shows lefts from Park Ave to High St.

22.  Page 8-4 “Prohibiting left-turn movements on northbound High St at Park St”.  Figure S-2 shows lefts from State to Park Ave.  Alternative S-2 doesn’t state that it will be closing off Forest Ave in front of Post Office.

23.  How can having 5 travel lanes on High Street help pedestrian crossings?  Crosswalks would be lengthened.  Sidewalks would be encroached upon.  Two-way traffic means more pedestrian/vehicle conflict points.

24.  Why would you want to take a highly efficient one-way street and convert to two-way system?

25.  Page 8-5  Add reduced pedestrian accessibility on High Street to all four alternatives.

26.  Page 8-5 “ It is recommended that the S-2 alternative be considered for implementation because it meets many of the previously evaluated criteria.  However, it should be noted that while S-2 is superior from an overall criteria perspective, poor traffic flow is still identified as a concern.  Why is this still being considered if it goes against a major objective?

27.  Page 8-5 unable to find Figures 5 through 8 illustrating the alternatives for State and High Street.

28.  Page 8-6 “Restricting movements from Forest Ave at Park Ave to right turns” for Options 3 and 4.  If this is the case, would left-turn movements be allowed at Forest and Marginal?

29.  Confusion on how to read Table 8.1.  “….a No-Build option (no roadway changes), and for existing volume conditions assuming Alternative S-2 is implemented”.  The table is for future volumes (2025), why mention existing volumes.  Why does the last column mention S-3?  The four alternatives didn’t mention S-3.

30.  The No-Build is better than all four alternatives with no construction cost, no removal of parking, no widening, no confusion of when parking is allowed, no additional air pollution, no geometric constraints and better pedestrian crossings (2 lanes instead of five and vehicles only travel from one direction).  In Table 8.1 the only better LOS that occurred is at State and York, this is because those options include providing two approach travel lanes on westbound lanes at State Street.

31.  Again in Table 8.2 the No-Build is better in all six intersections except at High and Congress.  The reason it is better is because Option 3 and Option 4 prohibit left turns from High Street onto Congress Street.

32.  Not only is State and High Street LOS going to be worse by converting to two-way but what about the streets adjacent to them? 

33.  Page 8-9. “High street is approximately 40 feet wide(between Danforth and York Street).  With the need to provide four travel lanes near York Street…”  What are the existing widths of roadways and how much widening of the roadways will be required to convert to two-way?  What would the travel lane width be?  Would sidewalks be sacrificed?

34.  Page 8-11.  “When that project is complete (I-295 connector), a viable alternative to the State/High Street one-way pair will be in place. As indicated in Table 4 of Chapter 4, there is a pool of 924 AM and 969 PM peak hour trips that could potentially divert to the new connector”. Did the future volumes from the PACTS Model for State and High Street include the new I-295 connector?  From the PACTS Model what is the diversion of traffic because of the new Connector?  What will be the travel time difference between the two routes?

35.  Page 8-11.  An interim step if volumes have not dropped after the traffic patterns stabilize would be to consider disrupting the progression along State and High to discourage their use by through traffic, thereby maximizing diversion to the I-295 connector”.  The Department of Transportation would not encourage such a strategy for it violates our policy on provide efficient and safe highways.

36.  The report never gives a recommendation to which of the four alternatives they would recommend

37.  Page 8-11.  The majority of the alternatives failed after evaluation except for alternatives S-2 and S-3.  These alternatives are FEASIBLE but compromise mobility to a certain extent in favor of other policy objectives which raises a number of policy issues which need to be considered by the City in determining a course of action:”.  Has a Feasibility Study been done?

38.  The report ask several questions:

·        What is level of delay to motorists is appropriate to this area?  Traditionally the City has required a LOS no less that a “D” at signalized intersections.

·        Is the City willing to implement these improvements if they will reduce the level of service?

·        Would the project be eligible for PACTS and or the Maine DOT cost sharing if the level of service is not enhanced?

·        Would the Maine DOT allow alternatives S-2 or S-3 even if they were not funding the project?  There approval would be required since State and High are designated as STATE ROUTE 77.

Is the City going to answer these questions or take a stand on these issues?

39.  A total cost for all improvements for immediate, short term and long terms is $415,000, $13,499,000 and $37,000,000 respectively.  What is the implementation plan?

40.  The diversity of traffic initiatives addressed by this study lends themselves to a similar diversity of levels of NEPA studies and/or documents, many of them being Categorical Exclusions.  A potential option of this traffic study, combined with appropriate environmental and planning data, would be to pursue a “checklist” Environmental Assessment or Categorical Exclusion form of documentation that would address the cumulative and secondary impacts of these proposed traffic improvement strategies and serve as a comprehensive, efficient mechanism for NEPA compliance.

55.  It is important to note that the context of this report is a traffic study, therefore, only a portion of a larger overall feasibility/planning process that is subject to numerous State and Federal laws, such as the National Environmental Policy Act (NEPA).  The reader needs to be mindful that this study does not address the broader “umbrella” of NEPA-related environmental issues, such as the Air Quality Conformity analysis requirements of the Clean Air Act, the cultural resource protections of Section 4(f), and the results of a community impact assessment, to name a few.


            I realize that the quantity of comments is substantial, but it was felt that documentation of the Department’s concerns and subsequent committee response would be prudent.   I look forward to finalizing this report and developing future strategies to rectify existing problems throughout the peninsula.



If you have any further questions, please feel free to contact me at  624-3632.




                                                                        Stephen Landry

                                                                        Assistant State Traffic Engineer



cc         Bill Needelman, City of Portland Planning

            Tom Gorrill, Gorrill-Palmer Consulting Engineers

            Dennis Emidy, MEDOT Bureau of Planning