July 23, 2010

To: Doral Hoff, Idaho Transportation Department

cc: Jim Carpenter, ITD District 2

Alan Frew, ITD

Governor C. L. “Butch” Otter

From: Linwood Laughy and Borg Hendrickson, Kooskia, Idaho

**ITD Alert 5 — 7/23/2010 ConocoPhillips and the 15-Minute Rule**

Idaho statutes state the following regarding non-reducible overlegal loads:

“Overlegal permits will not normally be issued for movements which cannot allow for the passage of traffic as provided in Chapter 11, except under special circumstances when an interruption of low volume traffic may be permitted **(not to exceed ten (10) minutes)** or when adequate detours are available.” (emphasis added) Even if the Idaho Transportation Department believes the ConocoPhillips transports involve as yet unidentified *special circumstances*, the interruption of traffic is legally limited to 10 minutes. At the June 29, 2010, community gathering in Kooskia, ITD’s Jim Carpenter stated publicly he was not aware of any 10-minute traffic delay rule. According to Carpenter, ITD “just uses 15 minutes,” which could be a violation of Idaho law.

Nevertheless, ITD has publicly, repeatedly and consistently stated the ConocoPhillips shipments must meet ITD’s maximum 15-minute traffic delay rule. Our examination of the Emmert International Transportation Plan (ConocoPhillips), along with an examination of road conditions and measurement of turnouts along the route, makes clear ConocoPhillips cannot meet even ITD’s 15-minute requirement on numerous stretches of U.S. 12, much less 10 minutes.

**Time Factors—A Model**

Consider the following projected time factors involved in transporting a 500,000+ lb. mass that is 29 feet wide along a narrow, two-lane highway posted by ITD as “Winding Road Next 99 Miles” in traveling from Turnout X to Turnout Y.

a. 1.5 minutes — overcome load inertia, move module fully onto highway from a turnout, and accelerate load to full average speed over an estimated ¼ mile at an

averagespeed of 10 mph to a full speed of 20 mph;b. Calculated time to travel the distance between Turnout X and Turnout Y minus time and distance for acceleration and deceleration;

c. 1.5 minutes — decelerate over ¼ mile at average speed of 10 mph and pull partially or fully off the highway;

d. 1.0 minutes — clear oncoming traffic past a 500-foot-long convoy at night.

We suggest times (a), (c), and (d) above represent *minimum* estimates. Further, safely achieving an average speed of 20 mph on much of U.S. 12 may be unrealistic but will serve here as a projected speed. As further background, please note Emmert International/ConocoPhillips states in their original transportation plan:

“If areas arise along the route that have 0 inches of clearance during a typical standard steer, then the load will be backed up and crab steered through and/or away from the obstacle to achieve enough clearance.” No amount of estimated time is provided for such a maneuver, but 10 minutes would seem an absolute minimum for hand crabbing around a rock face.

**Four Examples Applying the Above Model**

We are confident ConocoPhillips will be unable to meet ITD’s 15-minute requirement on numerous stretches of Highway 12 in Idaho. Below are four examples.

**1. Mile 77.4 to 83.1 —a distance of 5.7 miles. **

According to the EI/CP transportation plan, the crossing of Maggie Creek Bridge at Milepost 76.8 requires the installation of an extra dolly beneath the load. This addition, according to CP, has a significant, negative impact on speed and turning ability. If the transport crew is able to remove this extra dolly at MP 77.4 without blocking traffic for more than 15 minutes, the transporter should be back to normal operation. Assuming an average travel speed of 20 mph, travel from 77.4 to 83.1 would require the following times:

- 1.5 minutes to return to the roadway and accelerate over a distance of .25 mile;
- 16 minutes to travel to point of deceleration
- 1.5 minutes to decelerate and enter a turnout.
- 1 minute to clear traffic.

Thus if the transporter were able to achieve an *average* speed of 20 mph, which would require speeds at times in the 20-25 mph range, traffic delay time would be 20 minutes. At an *average* speed of 15 mph once full speed is achieved, the traffic delay time would be 25 minutes.

**However**, at MP 81, two steel cables cross U.S. 12 at approximately 20 feet in height. These cables are over one inch in diameter and 6 feet apart. We are advised that arrangements have been made with a local contractor to raise these cables with a boom truck to 30 feet for each individual shipment. Thus passing beneath these cables will require an additional acceleration and deceleration time (3 minutes) plus whatever time is required to creep beneath both cables inches above the top of the load. If the latter time is 2 minutes, the predicted time for covering this stretch of highway at an average speed of 20 mph becomes 24.5 minutes. If the transporter were able only to achieve an average speed of 15 mph, total elapsed time would be 30 minutes.

Thus under ideal conditions, the traffic delay at mile 83.1 will predictably be a minimum of 24 - 30 minutes. If the pullout beside the river at 77.4 provides insufficient space to remove the extra dolly installed to cross the Maggie Creek Bridge and the size of the large turnout at 83.1 is required, resulting in travel which is “very slow with restricted turning ability,” the traffic delay will be significantly longer.

**2. Mile 116.0 – 120.3 — a distance of 4.3 miles**

In order to cross the Fish Creek Bridge, the Emmert International transportation plan again calls for temporarily adding an extra dolly under the load, which extends axle width to 21 feet. EI further states, “travel with these helper dollies installed will be very slow and the turning ability of the transporter would be very restricted…” A rock wall at 116.6 on an inside curve, according to EI, will require the load to “swing wide.” An extensive rock face close to the fog line adds a similar requirement at Mile 117.0. A tight turn radius appears at 119, with a similar curve nearby. The load must then go through deceleration as it approaches the bridge at Mile 120, cross the bridge at a maximum of 5 mph, and proceed the .3 miles remaining to the turnout, presumably at that same speed. The likely speeds for this stretch look like this:

• 1.5 minutes acceleration to 10 mph over .25 miles

• 21 minutes traversing 3.5 miles at an average speed of 10 mph

• 1.5 minutes deceleration

• 6 minutes crossing bridge at 5 mph and traveling to turnout

• 1 minute to clear traffic or maneuver completely off the highway at Milepost 120.3

At an average speed of 10 mph, projected traffic delay time totals 31 minutes. Because of the frequent partial deceleration and acceleration caused by 4 sharp curves, frequent rock faces and narrow roadbed, achieving an average speed of 10 mph on this stretch is highly optimistic. At an average speed of 7.5 mph, traffic delay time would be 38 minutes. Further, the EI transportation plan notes the rock face at MP 117.0 has no turnout on the corner, so this location could easily be one that requires “hand crabbing.” If so, a realistic prediction for this stretch is likely 48 minutes plus.

**3. Mile 55.0- 58.7 — a distance of 3.7 miles **

This segment is characterized by a narrow roadbed hugging the river, 10 rock faces next to the inner fog line, and sharp curves. In addition, at various locations the shoulder beside the river is sloughing off into the Clearwater River, questioning the roadbed’s ability to support the axle weights involved in these shipments. For example, at Mile 56, according to the EI transportation plan, “rock wall lines road at fog line.” The plan lists the roadbed at 24 feet in width with a 5-foot wide gravel shoulder. We measure 22 feet 9 inches. Gaping holes appear beneath the concrete barriers on the shoulder opposite the rock face at MP 56, and the barriers themselves lean toward the river for lack of sufficient support for even their limited weight.

This stretch of highway clearly qualifies as containing those locations where the load “might have zero inches of clearance” calling for the transporter to be backed up and “hand crabbed” around the rock faces. Averaging 10 miles per hour through this stretch is optimistic.

With 3.2 miles to travel after acceleration and prior to deceleration, at an *average* speed of 10 mph this stretch would require 19+ minutes. Adding in the 3 minutes for acceleration and deceleration and one minute to clear traffic projects a traffic delay of 23 minutes. At a more realistic average speed of 7.5 mph, the elapsed time would be 29.6 minutes. Stop at just one of the 10 rock faces for hand crabbing and we likely add at least 10 minutes, two rock faces at least 20 minutes. Note: In EI/CP’s revised plan they list *total* travel time for this stretch as 10 minutes. With even 1 minute allowed for acceleration and 1 minute for deceleration, EI is asking ITD to believe EI can travel this stretch with a narrow roadbed, numerous rock faces near the fog line, and sharp curves at an *average* speed of 24 mph.

**4. Mile 153.8 – 158.5 — a distance of 4.7 miles **

The first rock wall close to the inside fog line on this stretch of U.S. 12 appears at MP 155.2 on a sharp curve with a cross slope of 7.6%. A bridge at 155.7 requires deceleration to 5 mph, passing over the bridge, then acceleration back to full speed. The rock wall at 157.1 projects toward the highway with a cross-slope of 10.3%, requiring the use of transporter hydraulics to keep the load stable. The EI plan states “Hand steering of transporter will be required.” Another major rock wall appears at 157.5, where “Turning radius is very tight and hand steering of transporter will be required.” Below is the projected timing sequence:

• 1.5 minutes acceleration over .25 miles

• 5.5 minutes to travel .9 miles at average 10 mph

• 1.5 minutes deceleration over .25 miles and bridge crossing

• 1.5 minutes acceleration

• 7 minutes to MP156.9 at average speed of 10 mph

• 1.5 minutes deceleration to MP157.1

• 10 minutes hand steering of transporter around rock wall at MP157.1

• 5 minutes to travel the .4 miles to 157.5 at average speed of 5 mph (includes another acceleration and deceleration)

• 10 minutes hand steering of transporter around rock wall at MP157.5

• 1.5 minutes acceleration over .25 miles at average speed of 10 mph

• 3 minutes to deceleration point at MP158.3

• 1.5 minutes deceleration

• 1 minute traffic clearance

Total projected traffic delay time for this stretch of highway is 50.5 minutes. If “hand steering” of load can be accomplished in 5 minutes rather than 10, total time would be projected at 40 minutes. If the entire stretch could be run at an average speed of 10 mph, including all acceleration, deceleration, two sessions of hand steering and a bridge crossing, total traffic delay time would be 32 minutes. The revised EI plan claims 15 minutes as total travel time for this stretch. With no consideration given to acceleration and deceleration, this time would require that the transporter achieve an average speed of 19 mph past rock faces on sharp curves, over a bridge, etc. If a mere 1 minute were allocated to 1 time acceleration and deceleration, their projected average speed here is 22 mph.

We have used speeds in this analysis that may not be achievable, and the periods of traffic delay could easily be greater than we project. If an actual problem appears, e.g. getting a transporter stuck between the river and a rock face, the traffic delay at a given point could run into hours. If “a turning over incident” were to occur, and with the information provided in ITD Alert #4 concerning the use of a crane in such an emergency, traffic delays would be days or weeks.

In summary, the most consistent and operationally-defined variable in ITD’s position on the transport of overlegal loads across U.S. 12 is the maximum traffic delay of 15 minutes, which itself appears to violate Idaho statutes. A review of Emmert International/ConocoPhillips’ original transportation plan and actual examination of ground conditions and measurement of turnouts along this route strongly suggests ConocoPhillips cannot meet the 15-minute rule. Recognizing the narrow widths of the road (often as little as 21-22 feet between the fog lines), the frequent lack of solid shoulders or any shoulder at all, an axle width of from 18 to 21 feet with a load 29 feet wide, and the stated need at times to “hand steer” loads around sharp curves and rock walls, any prudent planner would likely add an additional 5 to 15 minutes to the travel time over the sample stretches of roadway provided above.

We have not yet reviewed the revised transportation plan filed by Emmert International around July 8, 2010. However, any modifications to the original Emmert International/ConocoPhillips transportation plan will not change the distances between turnouts, will not straighten one of the most winding stretches of highway in the nation, will not remove rock faces within the Northwest Passage Scenic Byway and Wild and Scenic River Corridor.

If this analysis contains significant errors, we ask ITD to point them out. If not, any issuance of permits for the ConocoPhillips loads will support the public’s suspicion that ITD has intended all along to issue these permits regardless of any public concerns or information regarding public safety, emergency response, highway conditions, Idaho statutes, or the much touted requirement that any such shipments meet ITD’s 15-minute rule.

**Note:** We recently received copy of the July 2, 2010 Emmert International/ConocoPhillips transportation plan. With a 225-foot transport length, EI/CP is now including traffic clearance stations (we presume in order to meet the 15 minute rule) with the following lengths in feet: 80, 115, 125, 150, 170, and 175 and “wide spots.” They are further asking ITD and the public to believe they can achieve *average* speeds (including acceleration and deceleration) between various turnouts, along both the Clearwater and Lochsa Rivers, of 20, 25, 28, 33, 35, and 49 mph.

The Rural People of Highway 12

To print the following list, click File>Print.