Below is our formal public comment sent to the Minnesota Department of Transportation on the Rethinking I-94 Scoping Document and Environmental Assessment Worksheet (EAW).
Dear Commissioner Daubenberger:
Before the construction of I-94, neighborhoods like Cedar-Riverside in Minneapolis and Rondo in Saint Paul were home to walkable, bustling commercial districts that supported a diverse and vibrant community of Black, immigrant, and working-class residents. From the late 1950s to the early 1970s, the construction of I-94 demolished thousands of homes, businesses, schools, places of worship, and community institutions.
These were not neutral decisions. They were choices that prioritized regional mobility over community stability, and in doing so, displaced residents, severed neighborhoods, and concentrated harm in communities of color and low-income communities.
Today, these neighborhoods remain among the most diverse and vibrant in Minnesota. But I-94 continues to harm. Residents experience elevated rates of asthma and other health conditions tied to air pollution. Noise pollution impacts daily life. Transportation options and job access remain limited for those without access to a car. The people most impacted are disproportionately poor and disproportionately people of color.
Despite the scale and long-term implications of this project, many community members still have not been meaningfully engaged. Too often, engagement has been constrained, technical, and disconnected from how people actually experience this corridor. The future of I-94 must be shaped by the people who live with its impacts every day.
A Generational Opportunity at Risk
The Rethinking I-94 project represents a once-in-a-generation opportunity to address historic harm and redefine the future of this corridor. Decisions made through this process will shape land use, transportation access, public health, and economic opportunity for decades.
However, the current process risks repeating the very harms it should be addressing.
The structure of this process increasingly suggests a predetermined outcome. By narrowing alternatives early, relying on evaluation criteria aligned with existing highway paradigms, and eliminating options that would fundamentally change the system, the process risks validating a conclusion rather than exploring possibilities.
By limiting alternatives to versions of a rebuilt freeway, the project constrains the range of possible outcomes before communities have had the opportunity to fully define what they need. This is not simply a question of design. The question is whether this process is structured to allow for transformation or is predetermined to reinforce the status quo.
Positions on Proposed Alternatives for Further Study
We do not support advancing alternatives that maintain or expand the freeway in its current form.
Options that retain the freeway, even with modifications such as managed lanes or reduced lane widths, continue to perpetuate pollution and associated health impacts, maintain physical barriers between neighborhoods, limit opportunities for land use change and community development, and reinforce long-term car dependency.
Expanding or reconfiguring freeway capacity will induce additional driving over time, increasing vehicle miles traveled and reinforcing congestion rather than resolving it. This well-documented phenomenon means that investments in expanded highway infrastructure often fail to deliver long-term mobility benefits while increasing environmental and community impacts.
These alternatives do not address the root causes of harm. They maintain the underlying system that created it.
The removal of transformative alternatives, including a multi-modal boulevard, from further study is particularly concerning.
Eliminating this option at the scoping stage forecloses meaningful analysis before its impacts, benefits, and tradeoffs can be fully evaluated. A project of this scale and consequence requires a full and transparent comparison of fundamentally different approaches, not just variations of the existing system.
Community Priorities for Rethinking I-94
Any future for this corridor must be grounded in clearly defined community outcomes.
Reconnected communities
Infrastructure should restore connections between neighborhoods, allowing people to move freely, safely, and easily across the corridor. This includes restoring street grids, improving walkability, and enabling community cohesion.
Improved air quality
The corridor must reduce exposure to harmful pollutants. This requires reducing vehicle emissions, minimizing high-speed traffic, and prioritizing transportation modes that improve public health outcomes.
Reduced noise pollution
Design solutions must meaningfully reduce noise impacts that affect daily life, sleep, and long-term health for residents living near the corridor.
Increased access
Transportation systems must expand access to jobs, education, healthcare, and community resources, especially for people who do not own or cannot afford a car.
Safety
The corridor must be safe for all users, including people walking, biking, rolling, and taking transit. Safety must be defined beyond vehicle throughput and include human-centered outcomes.
Wealth-building opportunities
This project should create opportunities for community wealth building through land use changes, local development, and reinvestment in neighborhoods that have experienced displacement and disinvestment.
The corridor includes significant publicly owned land that is currently underutilized. This project presents an opportunity to return land to community use, including housing, small business development, green space, and other community-serving purposes that contribute to long-term economic stability and local wealth building. Maintaining or expanding the freeway forecloses these opportunities.
Climate action
Any alternative must align with climate goals by reducing emissions, supporting sustainable transportation, and avoiding long-term investments in infrastructure that increase car dependency.
Assumptions that reducing capacity will worsen emissions rely on simplified modeling that does not reflect long-term system behavior. Reducing highway capacity can shift trips to other modes, reduce total vehicle miles traveled, and support more sustainable land use patterns. At the same time, expanding or maintaining highway capacity locks in emissions for decades, regardless of future vehicle technology.
Concerns on Evaluation Criteria
We are deeply concerned that the evaluation criteria used in this process do not adequately reflect these community priorities. The current framework prioritizes traffic flow, system performance, and vehicle movement in ways that disadvantage alternatives that would fundamentally change the system. This creates a structural bias in the evaluation process.
The current evaluation framework relies heavily on static traffic modeling assumptions that do not reflect how transportation systems actually function over time. These models assume relatively fixed travel demand and do not adequately account for modal shift to transit, walking, and biking, changes in land use that influence travel behavior, traffic diversion and evaporation, and induced demand resulting from expanded capacity. As a result, alternatives that depend on system adaptation and long-term behavioral change are structurally disadvantaged.
Using static modeling to eliminate transformative alternatives before applying more dynamic and appropriate analytical tools creates a biased outcome. This is not simply a technical limitation. It is a methodological choice that narrows the range of outcomes before they can be fully understood. As a result, the process does not provide a fair comparison between fundamentally different approaches.
This is not simply a technical issue. It is a policy choice about what outcomes matter and how they are measured. If the goal of this project is to address historic harm, improve public health, and create more equitable outcomes, the evaluation criteria must be redesigned to reflect those goals.
Call to Pause the Rethinking I-94 Project
Given these concerns, we urge MnDOT to pause the current process.
A pause would allow for reevaluation of the project’s purpose and goals, development of evaluation criteria that reflect community-defined outcomes, reintroduction of transformative alternatives, including a multi-modal boulevard, and a more meaningful and accessible community engagement process. Moving forward without addressing these issues risks locking in another generation of harm.
Conclusion
This is a pivotal moment.
The decisions made through the Rethinking I-94 project will shape the future of the Twin Cities for decades. We have the opportunity to repair past harm, reconnect communities, and build a transportation system that works for everyone. But that will not happen if the process is constrained, the alternatives are limited, and the evaluation framework reinforces the status quo.
We urge MnDOT to reset this process, center community leadership, and fully consider alternatives that align with the outcomes communities are asking for. The future of I-94 should not be predetermined. It should be shaped by the people who live here.
Twin Cities Boulevard
The most responsible option for the future of the Rethinking I-94 project is a multi-modal boulevard that returns the surrounding land to neighborhoods and fulfills calls for reparative justice along the corridor. The Twin Cities Boulevard will create healthier air, much-needed economic opportunity, and accessible, affordable, and sustainable transportation access to places all along the corridor.