Executive Summary: Evaluation Flaws and Why They Matter
The flaws in the Minnesota Department of Transportation’s (MnDOT) criteria for evaluating alternatives on the Rethinking I-94 project created systematic issues that prevent a meaningful evaluation of, and comparison between, fundamentally different approaches to the corridor’s future.
As identified here through information obtained from a Freedom of Information Act (FOIA) request, including MnDOT’s technical communications with local and state agencies and the draft scoping decision document and evaluation matrix, these flaws become clearer and reinforce concern held about MnDOT’s process and the ability to deliver a good project to communities in the Twin Cities.
These methodological problems, which are the result of deliberate choices by the MnDOT project team and hired consultants at WSB, have concrete consequences for decision-making.
The community members, elected officials, and local governments are being asked to make billion-dollar infrastructure decisions based on metrics that provide limited differentiation between alternatives, models with acknowledged accuracy limitations, and criteria that do not capture the full range of relevant impacts, benefits, or costs will lead to worse project outcomes.
A more comprehensive approach would quantify air quality differences between alternatives, accurately assess traffic safety based on realistic traffic modeling, measure comfort and desirability for people walking and biking, calculate the economic value of land potentially available for redevelopment, and address other critical community needs.
Instead, the current metrics deemphasize these important public priorities and focus heavily on highway performance measures reminiscent of harmful highway construction in the 1960s—favoring mainline speed and vehicle throughput—while providing limited assessment of multimodal mobility, access to destinations by all modes, public health outcomes, economic development potential, and community connectivity that different alternatives might offer.
To ensure a fair, just, and holistic evaluation process and outcomes that improve the lives of Minnesotans along the corridor, MnDOT must fix this broken process and conduct an unbiased analysis of the Rethinking I-94 project alternatives. Doing so is critical to restoring communities, repairing past and ongoing harms, and repairing public trust in public processes.
About this Document
This document synthesizes a large data request and technical documentation on the Rethinking I-94 Project at MnDOT. These documents include:
- MnDOT FOIA Request; received by Our Streets in Fall 2024, containing various documents, including communications between the City of Minneapolis and MnDOT on the Rethinking I-94 Project regarding the draft scoping decision document, MnDOT Technical Advisory Committee meeting notes and agendas, and technical comments from Hennepin County, the City of Minneapolis, the City of St. Paul, the Metropolitan Council, and other stakeholders.
- MnDOT Draft Evaluation Criteria Matrix; received via FOIA Request by Our Streets in Fall 2024.
- Rethinking I-94 Project Website
- Rethinking I-94 Story Map, which outlines the scoping criteria at a higher level.
This analysis is intended for community members, elected officials, advocates, and other stakeholders seeking to understand the methodological limitations of MnDOT’s evaluation process. It serves as a technical resource for those reviewing the Draft Scoping Decision Document and participating in public comment periods.
The document is organized by evaluation category, with each section:
- Identifying specific flaws in MnDOT’s criteria or methodology.
- Providing agency staff comments and technical documentation identifying the flaw or shortcoming.
- Explaining why these flaws matter for decision-making.
Note: All agency comments referenced in this document are cited with the commenter’s name, affiliation, and a page ID number for verification. To verify the quote and receive additional details, open the MnDOT FOIA Request and search for the page ID number (using “command F”) to find the comment.
MnDOT’s responses to these comments are also included where relevant to show how (or whether) concerns were addressed. Some MnDOT responses were not included in the FOIA request and are not accessible here.
Purpose and Need Statement
Overview
To comply with federal regulations, MnDOT must develop a Purpose and Need Statement that guides project development, alternative design, evaluation criteria, and the scoping process for selecting a preferred alternative.
As MnDOT explains in their Rethinking I-94 Draft Purpose and Need document: “The purpose and need statement explains why an agency is undertaking a project and what its objectives are. The ‘need’ identifies transportation problems or deficiencies. The ‘purpose’ is a broad statement of the intended transportation results and other related objectives to be achieved. The purpose and need statement provides the basis for developing evaluation criteria, identifying a range of alternatives, and selecting the preferred alternative.”
Critically, this statement determines which alternatives are considered viable: “Alternatives that do not meet the project purpose and need should not be further studied, as they are not considered viable. Additionally, assuming all other concerns are equal, if one alternative meets the project purpose and need better than another, then that alternative may be identified as the preferred alternative.”
Rethinking I-94’s Stated Purpose and Need
MnDOT identified four transportation needs the project should address:
- Infrastructure condition – state of repair
- Mobility for people in motorized vehicles – cars, freight, and transit
- Walkability and bikeability – comfort, mobility, and risks for people walking, bicycling, and rolling
- Safety for people in motorized vehicles – cars, freight, and transit
At face value, these goals appear balanced. However, a truly transformative project requires broader priorities and evaluation criteria capable of meaningfully assessing how each alternative serves regional travel needs—neither of which were adequately established.
How the Purpose and Need Creates Structural Bias
The statement prioritizes cars and trucks by defining transportation deficiencies almost entirely through motorized vehicle metrics, while failing to establish concrete performance targets for transit and active transportation.
Infrastructure Condition: While everyone agrees that infrastructure must be improved, this criterion doesn’t differentiate between alternatives since all would improve the infrastructure condition. Adding specific multimodal infrastructure targets would have strengthened this measure and broadened the range of viable alternatives.
Mobility for Motorized Vehicles: How mobility is defined determines what investments get prioritized. By framing mobility around “congestion, poor level of service, and travel time reliability,” the statement inherently favors highway rebuilds—the problem becomes moving as many cars as possible rather than improving accessibility via all modes. Additionally, grouping transit with motorized vehicle mobility ties transit performance to traffic flow, allowing MnDOT to justify vehicle throughput as transit improvement.
Walkability and Bikeability: While the statement acknowledges that facilities are “not consistently designed and are considered substandard,” it frames the problem vaguely without requiring MnDOT to reorient the corridor to prioritize active transportation. Generic statements lack the concrete commitments needed to ensure substantive improvements.
Safety for Motorized Vehicles: Safety is critical, but vague problem definitions give MnDOT flexibility to pursue highway-oriented safety approaches rather than holistic designs that prioritize safety for all users and modes equally.
The Consequence: Unequal Evaluation Standards
The imbalance is clear: motorized vehicle needs have explicit performance metrics (level of service, congestion hours, travel time reliability), while walkability and bikeability needs lack concrete objectives. This makes it easier for alternatives to be deemed acceptable even if they don’t substantially improve, or potentially worsen, conditions for pedestrians, cyclists, and transit users.
An at-grade boulevard must demonstrate it can meet specific vehicle mobility objectives to be considered viable, but there are no equivalent performance thresholds it must meet for transit ridership, bike/ped connectivity, or active transportation comfort. This structural bias means alternatives are ultimately evaluated on how well they move cars, not how effectively they serve people traveling by all modes throughout the region.
It Doesn’t Have to Be That Way
Not all state DOTs are stuck in the ’60s like MnDOT. For example, New York State DOT (NYDOT) proceeded through the same federal environmental review process with a very similar set of project goals in their purpose and need statement and decided that removing the highway was the best way to meet them.
In the I-81 removal project in Saracyse, New York, their community grid boulevard option met all of the purpose and need criteria based on their evaluation metrics. The stretch of highway is the most similar example of highway removal in the U.S. to Rethinking I-94, described in the scoping document: “the I-81 and I-690 corridors accommodate heavy traffic volumes, with up to nearly 100,000 vehicles per day in some Downtown sections near the I-81/I-690 interchange” (Page 16).
The agency’s Purpose and Need categories are found in section 2 of this scoping report (pages 14-32) and are similar to MnDOT’s, including:
- 2-2-1 The Need to Improve Traffic Flow and Safety
- 2-2-2 The Need to Correct Non-Standard and Non-Conforming Design Features
- 2-2-3 The Need to Improve Highway Bridge Infrastructure
- 2-2-4 The Need for Transportation Infrastructure to Support Long-Range Planning Efforts
- 2-2-5 The Need to Improve Pedestrian and Bicycle Infrastructure
Their alternatives evaluation process was more robust than MnDOT’s and led to a better outcome, despite a similar set of project goals. Ultimately, the Federal Highway Administration (FHWA) accepted this process outcome and allocated over $2 billion in federal funding for the project.
MnDOT had the project team at NYDOT give a presentation on the benefits of removing the highway and further discussed the purpose and need there, but has failed to carry these lessons into their own process.
Flaws by Evaluation Criteria, and what other Agencies said About Them
Even more important than the purpose and need criteria themselves is how MnDOT measures which alternatives meet those needs. MnDOT is required to select project designs that meet the transportation needs and the purpose of the project, but provides significant flexibility for how these criteria are evaluated based on performance criteria.
This document assesses flaws with the criteria used to just that, exposing issues with the metrics that decide whether each alternative meets the needs outlined by the project and how this process was created to bias alternatives that maintain the status quo.
Below are analyses of the Purpose and Need Evaluation Criteria, the Social, Environmental, and Economic Impacts Criteria, and the Livability Goals Evaluation Criteria on the Rethinking I-94 Project.
Safety for People in Motorized Vehicles
Safety for people across all modes of transportation is critical to any major investment too—whether it be a highway project or one that invests in transit and active transportation. MnDOT’s Safety Analysis concludes that the at-grade alternatives do not meet the purpose and need concerning the “safety for people in motorized vehicle metrics.”
There are several key flaws in how safety for people in motorized vehicles is measured. Let’s break them down.
1. MnDOT’s metrics ignore the reality that traffic moving at lower speeds reduces the number of fatal crashes.
MnDOT’s metrics state that there would be a net increase in fatal and serious injury crashes per day on the mainline route in an at-grade alternative were constructed. While the total number of crashes is assumed to increase, based on Federal Guidance, the number of fatal or severe crashes is likely to decrease due to lower speeds.
The City of Minneapolis commented on this flaw, stating:
Fatal and serious injuries typically decrease at lower speeds. For example, this table from the Federal Motor Carrier Safety Administration demonstrates the increase of fatal crash rates of large trucks as speeds increases. Please clarify how fatal and serious injury crashes will increase at lower speeds.
City of Minneapolis staff (11003416) 5.3.24
MnDOT’s response sidesteps this entirely. Instead of addressing the speed-safety paradox, they simply restate their methodology: they’re using statewide average crash rates by facility type (4-lane divided roadway vs. freeway). While that explains how they calculated the numbers, it doesn’t explain why those numbers contradict the speed-safety relationship the City referenced.
This means the projected increase in crashes reflects typical outcomes for similar roadways, but it isn’t inevitable—it could be avoided if the boulevard design prioritized safety over speed. More importantly, designing for lower speeds would reduce crash severity, addressing the gap in MnDOT’s analysis, which fails to account for how speed reductions mitigate injury outcomes.
2. MnDOT’s safety conclusions about parallel roads lack the modeling certainty required to support them.
MnDOT’s evaluation of the at-grade alternatives states that fatal and serious injury crashes would increase on routes within one mile of the corridor if an at-grade boulevard is constructed.
However, because the traffic modeling results from the agency are flawed and inconclusive at this level of analysis, there is significant uncertainty on how many cars would be diverted to local streets parallel to the corridor and which corridors they would be displaced to. As such, it is premature to determine that these crashes will increase without more conclusive data and study in the next stage of the process.
Metropolitan Council staff identified this flaw, stating:
In addition, because the safety results are closely related to the issue of the level of traffic diversion and volume increases on parallel corridors, we recommend that the safety measures be considered with a similar level of uncertainty as the travel forecasts.
Metropolitan Council staff (11003424)
3. MnDOT’s measures are opaque and don’t have clear criteria that separate red, yellow, and green scores.
If the public, elected officials, project stakeholders, and technical staff cannot verify how safety ratings were determined or why specific thresholds distinguish between green, yellow, and red designations, there’s no way to challenge potentially biased or arbitrary conclusions—and no obligation for MnDOT to justify them. This opacity is especially problematic when safety findings are driving major infrastructure decisions that affect communities.
Metropolitan Council staff identified this flaw, stating:
The safety-related crash measures and analysis methods are very specialized and it is difficult for a non-safety expert to determine where and how safety measures represent significant findings and concerns and how the matrix breakpoints between a green, yellow or red safety rating were established.
Metropolitan Council staff (11003424)
Without published, detailed documentation of how those thresholds were established and why they represent significant findings, the methodology remains a “black box” regardless of which experts were consulted. Transparency requires not just that experts agree on a method, but that the method itself can be understood and scrutinized by those affected by its conclusions.
Infrastructure Condition
One of MnDOT’s priorities identified in the Purpose and Need Statement included infrastructure condition. Any project on the corridor would improve the condition of the infrastructure, as 1960s era roadway, bridges, retaining walls, and other infrastructures are deteriorating.
However, their measurement for this criterion was a simple (Yes/ No) metric for the condition of pavement and bridges along the corridor. The at-grade alternatives do not receive additional points for increasing the quality and number of transit and active transportation infrastructures along the corridor in addition to addressing the condition of the infrastructures that are currently there.
Important to note that MnDOT’s criteria for this section does not differentiate between the alternatives, making it an unuseful metric for selecting criteria across the different alternatives.
Metropolitan Council staff identified this flaw, stating:
The technical analysis has provided a significant amount of valuable data on the current condition of assets within the I94 corridor. However, because the build alternatives all will provide for replacement and improvement of these aging assets, it does not appear to be an analysis that can be used to significantly differentiate among the alternatives.
Metropolitan Council staff (11003425)
Walkability and Bikeability: Comfort, Mobility, and Risks for People biking, walking, and rolling
Improving safety for those who bike, walk, and roll is critically important for the Rethinking I-94 project to address. The highway currently bisects neighborhoods from Rondo to Cedar-Riverside and is home to 100,000 people who travel around their communities by all modes of transportation.
Road users are the most vulnerable and their safety needs to be prioritized. MnDOT’s process fails to do so.
1. MnDOT’s evaluation assumes there is no change to the existing bike and pedestrian network, even if an at-grade boulevard is constructed with significant bike and pedestrian improvements.
MnDOT’s evaluation assumes no changes to the existing bike and pedestrian network, despite at-grade alternatives including separated, safe facilities—a structural flaw that systematically underrates alternatives designed to improve biking and walking along and across the corridor.
City of Minneapolis staff identified this flaw. In response to MnDOT’s scoping documents claiming: ‘New nonmotorized conflict points would be created at locations where at-grade crossings replace grade-separated crossings,” Minneapolis staff stated:
It does not seem consistent to state new conflict points would be created but that there would be no change to the pedestrian and bicycle network as commented upon above, and
If new crossing locations are anticipated by returning to at-grade, then why is there an assumption that there is no change to the structure of the walking and biking network?
City of Minneapolis staff (11003415) 5.3.24
MnDOT’s response explored the depth of the flawed analysis, stating:
There is potential for new crossing locations as part of the at-grade, Local/Regional, and Freeway alternatives, as noted in the respective sections. However the locations of these opportunities are not known at this time. To provide an “apples to apples” comparison, the walkability/bikeability analysis in Scoping assumed no new crossing locations for any alternative.
MnDOT and WSB staff 7.15.24 (11003415)
This functionally means that the “at-grade” options were discounted for “increasing conflict points” but did not receive higher scores for having “the potential for new crossing locations.” In the analysis, the increased connectivity for all modes of transportation is achieved in a connected street grid, though excluded from analysis in MnDOT’s process.
It’s impossible to accurately conceptualize or evaluate non-motorized connectivity and performance if you assume there are no changes to the network across any of the alternatives.
2. MnDOT does not actually understand or evaluate what comfort means for those who bike, walk, and roll.
MnDOT’s criteria focus narrowly on non-motorized connectivity and performance, ignoring comfort—a key factor that determines whether people actually choose to bike, walk, and roll.
Comfort encompasses factors like noise, emissions, and the overall desirability of the walking and biking experience, particularly in relation to the freeway and getting across or along it. By omitting comfort from the evaluation criteria, despite explicitly identifying it as a purpose and need of the project, MnDOT fails to assess whether alternatives actually improve the conditions that make active transportation appealing and sustainable for residents.
City of Minneapolis, City of St. Paul, and Hennepin County all identified this flaw:
Comfort and mobility is identified for this criteria in purpose and need. There seems to be a focus on safety with limited discussion on comfort and mobility, particularly as it relates to the addition of new crossings at grade.
City of Minneapolis staff (11003415) 5.3.24
Walkability/bikeability as concepts should include “comfort” of walking and biking. For example expanded freeway would make walking and biking less comfortable by adding noise and emissions. This needs to considered along with other metrics in determining whether or not walkability/bikeability is being improved.
City of St. Paul staff (11003409)
Consider adding a level of comfort criteria as well. This is different from safety or mobility criteria as it is more focused on how comfortable, desirable, enjoyable it is to walk or bike. When considering a freeway barrier this is a legitimate consideration to peoples’ travel choice.
Hennepin County staff (11003423) 5.3.24
Mobility for People in Motorized Vehicles: Cars, Freights, and Transit
The mobility evaluation criteria for motorized vehicles are fundamentally flawed because they prioritize metrics that inherently favor highway expansion over realistic urban transportation needs. Additionally, MnDOT also significantly weighted the priority for these criteria by including more of them in the evaluation criteria than any of the other purpose and need criteria:
- Walkability and Bikeability – comfort, mobility and risks for people walking, bicycling, and rolling (2 Evaluation Criteria)
- Safety for People in Motorized Vehicles – cars, freight, and transit (2 Evaluation Criteria)
- Infrastructure Condition – state of repair (2 Evaluation Criteria)
- Mobility for People in Motorized Vehicles – cars, freight, and transit (14 Evaluation Criteria)
MnDOT measures corridor mobility using “mainline speed”—assuming that high-speed highway travel is the desired outcome—when the majority of trips on I-94 are short, local trips that don’t require freeway speeds and could be accommodated more efficiently on the urban street network. Additionally, the criteria focus on corridor throughput rather than systemwide mobility, which artificially inflates the value of maintaining highway capacity. Better measures would focus on consistency with vehicle miles traveled (VMT) instead of vehicle hours traveled (VHT), which tends to bias solutions that move cars faster over meeting state goals to reduce the amount we drive.
Finally, metrics for transit mobility and reliability are lumped into this section, and while they perform well relative to the other alternatives, this improvement is not accounted for in MnDOT’s scoring because the criteria is heavily weighted by outdated vehicle mobility metrics.
Traffic Modeling and Assumptions
Most critically, the travel demand model underlying these metrics uses outdated static traffic assignment algorithms from the 1970s that systematically overestimate highway expansion benefits, while failing to accurately match existing peak-period speeds and traffic volumes. Because the model cannot properly account for bottlenecks or realistic driver behavior in the post-pandemic era, it produces speeds and delay metrics that are demonstrably wrong. This makes any evaluation based on these numbers unreliable for informing major infrastructure decisions.
MnDOT has continued to downplay the flaws in its traffic models and resist the use of more advanced and accurate dynamic traffic assignment models, which are more expensive but more accurate. Considering that MnDOT has spent over $20 million on the Rethinking I-94 Project to date, and many critical project decisions are made based on traffic data, it’s deeply troubling to see the agency move forward with a limited understanding of the mobility implications of their decisions.
Met Council staff at MTS called out this flaw several times in their comments on MnDOT’s scoping process, stating:
Within the traffic memo, there is an appropriate discussion of the limitations of regional travel models, however, there is no discussion of levels of uncertainty in the modeling results, which is a limitation of any future-year analysis. A discussion and disclosure of sources of uncertainty in modeling and forecasting would be helpful in understanding a range of uncertainty in the modeling results.
Metropolitan Council staff (11003425)
Deputy Director Vennewitz expanded on this concern by adding:
Static traffic assignments are notoriously unreliable at estimating volumes on low-volume, low-functional class roads, in part because characteristics of their capacity (intersection queueing, frequent access and turning) are poorly represented in static regional assignment models. This is reflected in the industry guidance (FHWA TMIP Travel Model Validation and Reasonableness Checking Manual) which suggests 25% as being acceptable aggregate error in base-year calibration for roads of 20,000 AADT.
The analysis should note that while the travel forecasting runs demonstrate significant traffic diversion in the at-grade alternatives, the precise magnitude of diversion on any particular road is hard to measure with static assignment models. This was acknowledged in the January 24, 2019 project memo on “Proposed Modeling Approaches” for the study, which acknowledged that a weakness of using static traffic assignment models is that the models “have limited accuracy in handling traffic diversions.
Metropolitan Council staff (11003425)
Together, these suggest what Deputy Director Vennewitz concluded in her comments, that:
In the absence of these sensitivity tests or calculating diversion with a mesoscopic traffic assignment tool, the results currently lack sufficient confidence in specific traffic diversion forecasts to be used for decision-making at this stage.
Metropolitan Council staff (11003425)
Other Criteria
Economic Vitality Measures
When the interstate was built in the 1960s, thousands of homes, businesses, and other local assets were destroyed, and land was ceded to construct the highways. As a result, the local tax bases in Minneapolis, St. Paul, Hennepin, and Ramsey County were devastated, a loss that has never recovered.
Economic vitality is critically important to consider in the process of “Rethinking I-94.” The current measures only consider opportunities for job and business accessibility, overlooking the transformative potential of freeing up right-of-way for redevelopment and excluding it from analysis.
Based on their existing measures, which center on “employment opportunities (jobs) accessible within 30-minute travel time,” the at-grade alternatives show a slight decrease in the number of jobs accessible by car along the corridor (~4-6.8% decrease), but jobs accessible for transit users increase significantly (7.1%). However, this metric assumes no redevelopment along the corridor in the “at-grade” alternatives, meaning that new jobs would be available along the corridor and would increase the number of jobs accessible there by all modes of transportation.
Both the City of Minneapolis and the City of St. Paul staff called out the issues with evaluating economic vitality in this way.
The City of St. Paul commented:
Understand why these results are shown as is, however using this as the only measure for economic vitality doesn’t seem appropriate.
City of St. Paul staff (1103412) 4.29.24
MnDOT’s response to City of St. Paul:
While the access to jobs measure only reflects one aspect of economic vitality, it is something that can feasibly be measured in Scoping and shows differentiation between the alternatives that are being evaluated. Additional measures may be feasible during later project phases.
The City of Minneapolis comment echoed these concerns:
As the evaluation of this project is finalized, the City of Minneapolis will be looking to seize opportunities presented by the reconstruction of aging infrastructure that was designed and constructed in a past era and under much different engineering guidance than is currently used. Infrastructure reconstruction is the best opportunity to reconfigure and realign roadways to use less space and move more people in more efficient and sustainable ways.
This is also a great time to look for new opportunities related to redeveloping properties along the corridor as infrastructure is improved but also to create new space for development in the form of emerging concepts such as land bridges. We also recommend that MnDOT consider the innovative use of rights of way under existing bridges, flyovers and other structures to better connect areas of the city divided by the freeway system; and look for opportunities to engage in reparative investments in neighborhoods most impacted by the freeway system.
City of Minneapolis staff (11003422) 5.3.24
MnDOT’s response to City of Minneapolis:
Comment noted. MnDOT intends to explore land bridges, innovative uses of right of way, and other opportunities as part of future project phases.
Equity Measures
Equity was a purported goal of the Rethinking I-94 Project that did not meaningfully translate into evaluation criteria used to narrow down alternatives.
For Equity: MnDOT utilized a qualitative measure to evaluate equity, choosing a metric that was intentionally vague enough to score each of the alternatives the same. Specifically, their measure was: “Qualitative Assessment – Does the alternative have the potential to enhance transportation choices for individuals? (Yes/No)”.
With the exception for General Maintenance A and the no-build alternative, all alternatives, including highway expansion options, scored highly in this section.
MnDOT describes the at-grade options as meeting the criteria for equity, stating: “Potential for excess ROW to be used for new features/amenities in select locations. Potential for additional amenities that would not be compatible with freeway alternatives.” (See ‘Goals and livability- Mainline’ tab in MnDOT’s evaluation spreadsheet).
However, due to the vagueness of their criteria, they described the expanded freeway options, which would cause demonstrable harm to adjacent communities, as also meeting equity criteria, stating: “Potential for excess ROW to be used for new features/amenities in select locations; potential for aesthetic improvements to bridges and structures. Larger roadway footprint will reduce space available for potential features/amenities. Potential BRT stations would decrease excess ROW.” (See ‘Goals and livability- Mainline’ tab in MnDOT’s evaluation spreadsheet).
Environmental Justice: Air Pollution Measures
MnDOT’s evaluation criteria claimed that the “Major change in vertical alignment has potential to increase size of areas within EJ communities impacted by traffic noise.” This assessment ignores the fact that noise travels beyond the freeway trench even if the highway remains as it is today, continuing to harm communities.
More troubling is that their analysis does not acknowledge the impacts of the change to traffic volume that an at-grade road would result in less traffic through the neighborhood and thus more noise and pollution.
The City of Minneapolis pointed out this flaw, stating:
There is no acknowledgement of the decrease in impervious surface in at-grade A and B alternatives. Continue to question the expectation of increased noise pollution, given the decrease in speeds, number of freight, and traffic volume; all noted by AASHTO and referencing FHWA guidance.
City of Minneapolis staff (11003419) 5.3.24
MnDOT’s Response:
The likely decrease in impervious surface was discussed, however on balance it was determined that the potential noise impacts were more substantive. Notes added to working spreadsheet.
MnDOT and WSB staff (11003419) 7.15.25
The selected measures were chosen because they are key determining factors in identifying whether a project is considered a Type 1 project and requires a noise analysis based on FHWA rules. A more in-depth noise analysis that accounts for more factors will be conducted as part of the Tier 1 EIS.
MnDOT and WSB staff (11003416) 7.15.25
Further, when Minneapolis staff questioned whether urban heat island effects should be included in the environmental justice assessment, MnDOT dismissed the concern as infeasible to measure, despite heat island impacts being well-documented environmental justice issues in urban communities:
City of Minneapolis’ Comment:
Does the decrease in vegetation impact the urban heat island effect? Do the increased number of vehicles also impact the urban heat island effect? Should urban heat island impacts be included as part of the EJ assessment for all alternatives?”
City of Minneapolis staff (11003418) 5.3.24
MnDOT’s Response:
Changes in impervious surface in the corridor may have a variety of secondary effects. However, it is not feasible to measure the differing impacts of each potential alternative on these effects. For this reason, the selected measure is focused on quantifiable changes in impervious surface between the alternatives.
MnDOT and WSB staff (11003418) 7.15.25
Public Health and the Environment
MnDOT’s evaluation criteria for public health and environment is an overly simplistic measure that asks a yes/no question about “potential to impact green space or land uses.” This completely ignores the direction and magnitude of impact—destroying green space and creating green space both qualify as “impact,” and are purely qualitative (“potential to impact”) rather than quantifying actual environmental outcomes.
Every alternative, including the highway expansion options, which would have a demonstrable impact on public health, receives a “Yes” answer, making it meaningless for comparison and failing to encompass the true impacts—both positive and negative—of each alternative.
By conflating “potential” with outcomes, stating “potential for excess right of way to be used to expand green space” doesn’t mean green space will actually be created. The Expanded Freeway options acknowledge they’ll have less excess ROW but still get marked “Yes.” This Self-Contradictory Logic, where larger roadway footprints (more pavement, more traffic, more emissions) receive the same “Yes” rating as smaller footprints, demonstrates the flaw of this criterion.
Public health and environmental impacts are far broader than just green space, and highways have been demonstrated to cause a variety of public health impacts. MnDOT’s criteria deliberately ignore other measurable criteria, including air quality, noise pollution, and climate/greenhouse gas emissions, all of which are not accurately accounted for in this and other criteria throughout the analysis.
The City of Minneapolis called out this concern, responding to the flawed green space assumptions by stating:
Not all green/gathering spaces are created equal. Depending on how they are sited and designed, places located immediately adjacent to a highway may not be comfortable to use due to noise and pollution.
City of Minneapolis staff (11003420) 5.3.24
Sense of Place
MnDOT’s sense of place criteria are fundamentally flawed in their vague, superficial approach to measuring community character and cohesion, scoring all alternatives as having the potential to increase sense of place despite wildly different outcomes—from highway expansion to an at-grade boulevard.
By focusing solely on the “potential” to add features like art or gathering spaces in leftover right-of-way, the criteria ignore what matters most: the existing sense of place that was destroyed or disrupted by highway construction and the inherent incompatibility between freeways and vibrant community spaces.
There’s no assessment of impacts to current or historic districts, cultural landmarks, or neighborhood gathering places, nor any consideration of how highway barriers fragment communities and diminish the sense of place once held there. The criteria lump together disparate elements—gathering spaces, cultural representation, art, and green spaces—without defining what constitutes a meaningful sense of place or whether proposed features align with what communities actually want.
Most critically, all alternatives (except for the no-build alternative) received a “Yes” rating simply because excess right-of-way could theoretically be used for amenities, rendering the criterion useless for distinguishing between options with vastly different impacts on neighborhood character and opportunity for reconnection.
The measure treats freeway expansion as equally capable of enhancing the sense of place as an at-grade boulevard, despite the obvious reality that wider highways create larger barriers and fragment communities more severely, and returning land for community development would significantly increase the sense of place. Without actual community input, cultural context, or acknowledgment that leftover land from highway construction is fundamentally different from opening up land for development and the restoration of community spaces, these criteria reduce sense of place to a checkbox exercise rather than a meaningful evaluation of how infrastructure shapes the lived experience of neighborhoods.
Transit
Transit mobility and reliability scored similarly to highway options when it came to transit mobility and reliability. However, by grouping transit within the “Mobility for People in Motorized Vehicles” category alongside cars and freight—rather than establishing it as a separate purpose with its own performance metrics—MnDOT fundamentally links transit success to vehicle throughput and highway performance. This framing allows the agency to justify highway expansion or rebuild as a transit improvement while avoiding concrete commitments to transit-specific outcomes like ridership growth, service frequency, or dedicated right-of-way.
The result is that transit becomes subordinate to automobile mobility. Alternatives are evaluated on whether they maintain vehicle speeds and reduce congestion rather than if they actually improve transit service quality or prioritize bus and rail travel. This structural choice means MnDOT can claim to be addressing transit needs while primarily optimizing the corridor for private vehicle flow, obscuring the fundamental tension between maximizing car throughput and creating truly competitive transit service.
Consistency with Adopted Regional Plans
Consistency with adopted regional plans was included as a criterion to guide the creation of alternatives. While it is important for all designs to be compliant with regional and state plans, the reason this was likely is because the 2040 Transportation Policy Plan (TPP) included a managed High Occupancy Vehicle (HOV) lane to the project corridor, a move that would have justified expanding the highway and add additional capacity in MnDOT’s image.
In the 2050 TPP Highway Investment Plan, the document was updated to read:
While identified as a strong candidate for a future managed high-occupancy toll lane in the MnPASS System Study 3 (2017), this system study focused primarily on regional mobility needs and did not address the other needs within the corridor, which are now being considered as part of the Rethinking I-94 process. No specific corridor projects are identified in this plan as these will be identified as an outcome to Rethinking I-94.
Once Rethinking I-94 has a selected alternative, an amendment to this plan will be required to specifically identify the selected corridor alternative, projects, and sources of funding to complete the projects.
Met Council staff further emphasized this reality, stating that:
There are no alternatives under study that are inherently inconsistent with the current 2040 Transportation Policy Plan (TPP).
Metropolitan Council staff (11003425)
The Met Council extensively discusses the harms of highways and the desire to do better on future projects in the 2050 Transportation Policy Plan in their Imagine 2050 plan. Given this, and then MnDOT commissioner Charlie Zelle’s apology to the Rondo community, it’s time to see if agencies are willing to stand up for these value statements when they really matter, on the state’s most consequential highway mega project.
Conclusion
MnDOT’s evaluation framework for Rethinking I-94 contains systemic flaws that prevent fair comparison of alternatives. This limits the study of options in line with the broader potential benefit of investing differently along the corridor and the costs of failing to do so and doubling down on the status quo.
From a Purpose and Need Statement prioritizing vehicle metrics over multimodal outcomes; to criteria so vague that highway expansion scores identically to community reconnection on equity and livability; to traffic models the Metropolitan Council says, “lack sufficient confidence for decision-making,”; the process excludes or inadequately measures critical factors like air quality, pedestrian comfort, redevelopment potential, and transit service quality. Communities devastated by 1960s freeway construction deserve an evaluation that accurately assesses how alternatives serve all residents—not one that repeats the same car-centric priorities that caused that harm in the first place.
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