Last week Phil Washington, CEO of Denver International Airport, sent a letter to Denver City Council regarding the request for Denver to provide $5 million in DRCOG transportation improvement project (TIP) funding towards planning and design of DEN’s Pena Blvd expansion (Council Bill 24-0233, approving a proposed Intergovernmental Agreement (IGA) between the City and County of Denver and Colorado Department of Transportation, concerning the Pena Boulevard Capacity Improvement I70-E470^[1]). In advance of this vote, we would like to offer a response highlighting the shortcomings of a mobility plan that relies on a large, expensive highway expansion and does not consider more sustainable transit alternatives:

Subject: Council Bill 24-0233: IGA with CDOT for Peña Boulevard DRCOG TIP Grant

Sent on behalf of DEN Chief Executive Officer Phil Washington: Dear Denver City Council, We wanted to provide you with some additional information on Council Bill 24-0233, an IGA with CDOT for a Peña Boulevard DRCOG TIP Grant, in advance of

Sent on behalf of DEN Chief Executive Officer Phil Washington:

Dear Denver City Council,

Introduction:

The purpose of the Peña Boulevard (I-70 and E-470) Design and National Environmental Policy Act (NEPA) Project is to recommend improvements that increase mobility options, enhance safety, and manage demand on Peña Boulevard to accommodate continued economic growth at the airport and along the corridor, supporting the regional and state economy and to prepare for a required federal NEPA review of the project.

Purpose:

The Project involves an environmental review and conceptual design for potential improvements to Peña Boulevard between I-70 and E-470. This request is not a vote on a construction contract for a specific project, but rather accepting a grant from CDOT for $5 million. This is a planning process where options will be considered, including no action on Peña itself.

All options currently being studied by DEN (aside from no action, which is used just for baseline comparison) involve widening of Pena Blvd^[2]. Of the nine alternatives initially considered, “Multimodal and Equity Improvements” was eliminated as a standalone alternative at phase I of the study before detailed planning and analysis could be conducted. All remaining alternatives rely on highway expansion.

DEN has already received hundreds of public comments asking them to consider a transit alternative that does not commit hundreds of millions of dollars to highway expansion, but DEN has not been responsive to public input to date. We are therefore asking City Council to use the leverage at their disposal and ask DEN to include a core transit alternative in its study before granting millions from the city’s capital transportation budget. 

Background on FAA Restrictions:

Denver International Airport (DEN) is required by Federal law to spend its revenues only on costs related to the transportation of passengers and goods.  In 2018, the Federal Aviation Administration (FAA) determined that there was a 73% airport / 27% non-airport traffic use of Peña Boulevard and required DEN to reassess this split within 10 years to determine if the percentages changed. Therefore, at this time, DEN can only pay for 73% of the operations and maintenance, and capital improvement costs, for Peña Boulevard. Typically, the non-airport portion is paid for by the City’s General Fund. However, DEN can also assist the City by obtaining other, non-airport sources of revenue instead of receiving funds from the General Fund. DEN has attempted to do that here by obtaining a grant to replace City funds to contribute to these critical subregional roadway improvements. If DEN does not obtain Transportation Improvement Program (TIP) Grant funding, the City and County of Denver will have to identify other non-airport sources of revenue, such as the General Fund. The total cost of the project is $18.5 million and DEN funds can be used for $13.5 million (73%) and the balance of $5 million (27%) needs to come from non-DEN enterprise funds, such as this TIP grant or the General Fund.  

DRCOG TIP grants are a substantial source of funding for transportation projects in Denver. While not from the general fund, these grants can be spent entirely at the city’s discretion on transportation projects of their choice. Despite over 200 public comments opposing this project, the Hancock administration requested $5 million dollars from DRCOG to design the Pena Blvd managed lane. The following projects were waitlisted in order to fund this highway project^[3]:

If the Pena Blvd project is not funded this cycle, the funds can be applied to one of the many waitlisted projects. If Denver proceeds with funding 27% of DEN’s transportation infrastructure, it is critical to ensure these plans are compatible with our multimodal, climate, equity and air quality goals.

Regarding the A Line, DEN cannot generally fund RTD’s projects or services. Under Federal law, DEN can fund certain ground access projects like aspects of RTD’s infrastructure either if the project is integral to an airport project (the A Line station in the Hotel/Transit Center) or its owned/operated by the City and “substantially related to the air transportation” of passengers or cargo. The FAA must approve each project based on the law and as discussed in the 2010 FAA letter regarding the A Line construction, City must retain ownership of those stations though DEN is allowed to lease the HTC station and track right of way to RTD. The FAA also made clear that airport revenues cannot be used to purchase rail cars, construct a rail maintenance facility, or make infrastructure improvements (such as double tracking) that support rail operations off airport property. RTD has been a very important stakeholder in this process. We have been engaging with them and will continue to do so. It is our understanding though, that RTD do not have any current plans or the ability to pay for expansion of the A Line.

Colorado Public Radio investigated whether DEN could fund improvements to the A-line. They concluded that this remains an open question because DEN has declined to ask the FAA, even as the Biden administration has become more transit friendly- https://denverite.com/2023/10/12/dia-says-feds-wont-let-it-fund-rtd-a-line-improvements-but-it-hasnt-asked. It is irresponsible to commit hundreds of millions of dollars to highway expansion without investigating if those funds could be better directed to improve train and bus infrastructure.

Furthermore, DEN has included an alternative in its plan that adds frontage roads to Pena Blvd that would be used exclusively for local, non-airport traffic. DEN has not explained how this non-airport infrastructure would be allowed by the FAA but funding improved rail and bus service to the airport would be prohibited. Regardless, at this early stage of planning, all options should be considered, and the most effective and sustainable use of funds should be allowed to rise to the top.

Transit Alternative:

All modes of transit are important to DEN. This process will include a Bus-Only Lane Alternative. The Bus-Only Lane Alternative proposes to construct an additional lane along Peña Boulevard that would be reserved for use by transit buses, including RTD buses, Mountain carrier shuttles, regional shuttles (i.e., CDOT Bustang, United Landline), etc. This alternative seeks to provide dedicated lanes for transit on Peña Boulevard to improve travel time reliability and encourage more bus ridership along the corridor. A bus-only lane could also encourage transit operators to add new bus services along Peña Boulevard. Without improvements to Peña Boulevard, buses will be subject to the same congestion as general-purpose lanes.

Rather than spending almost $300 million dollars to add additional lanes to Pena Blvd, it would make more sense for the “transit alternative” to leverage the transit infrastructure we already have in place, most notably the A-line that runs parallel to the corridor. Increased use of park-and-rides and feeder bus lines, more frequent service and lower fares should be analyzed as part of the transit alternative that could diminish the need for a wider highway.  

Mobility Goals & Transportation Demand Management Strategies:

In line with DEN’s goal of becoming the greenest airport in the world, DEN is committed to encouraging more sustainable transportation. DEN’s Transportation Demand Management (TDM) Plan aims to reduce drive-alone trips along Peña Boulevard and improve access to the airport through more sustainable modes of transportation. The TDM Plan establishes long-term goals for how employees and passengers access the airport.

 By 2035 DEN seeks to:

• Decrease DEN employee drive-alone trips by 10 percent (from 71 percent to 61 percent).

• Increase DEN passenger transit trips by 10 percent (RTD A Line, buses, & shuttles; from 9 percent to 19 percent).

To achieve these goals, DEN identified 19 strategies, all recommended for implementation within the next ten years. A minimum of $1.2 million of the $5 million TIP funding will be used towards the implementation of these strategies.

According to the DRCOG TIP application, adding managed lanes to Pena Blvd is projected to cost $277 million^[4]. Allocating just $1.2 million (0.4%) from this highway project to discourage car use is not in line with our mobility and climate goals. If DEN is serious about reducing SOV travel, they could fund this relatively small amount without tying it to a massive highway expansion.

DEN’s TDM plan includes a total of 19 strategies which require $9 million of funding for full implementation and is expected to reduce SOV volume by 8%^[5]. DEN is only required to spend $1.2 million on TDM from the TIP grant. If the modest strategies in the TDM plan are able to provide such significant and cost-effective congestion relief, then additional funding and prioritization for TDM might be able to produce similarly scaled benefits as adding additional lanes but at a much reduced environmental and fiscal cost.

DEN Catchment Area:

An airport’s catchment area is the geographic area from which an airport draws passengers.  Given DEN’s unique geographic location with no large metropolitan areas or large-hub airports within several hundred miles, DEN’s catchment area spans a very large region encompassing more than 10 states.

Only 90% of DEN’s originating passengers come from Colorado; the remaining 10% originate from surrounding states including Wyoming, Nebraska, Kansas, Oklahoma, Texas, Kansas, New Mexico, Utah, Montana, South Dakota and North Dakota.  Of those passengers originating in Colorado, 72% have access to RTD bus stops and 22% have access to RTD rail stops; however, unless they have direct access to the A Line or one of the busses serving DEN, multiple transfers are often involved that can greatly add to trip time and passenger anxiety when trying to make a flight which makes it an undesirable or impractical option for many. Notably, El Paso County ranks as the 5th-largest county in terms of Colorado-originating passengers using DEN (1.5 million originating passengers per year, 8% of total); these passengers do not have any RTD bus or rail access as RTD does not serve El Paso County.

 From Moffat County in the northwest corner of the state to Baca County in the southeast corner, every single one of Colorado’s 64 counties generate originating passengers for DEN.  When examining direct RTD access to DEN, the data shows that 14% of Colorado-originating passengers have access to DEN via bus and just 4% have access to DEN via the A Line.

Although DEN is owned and operated by the City & County of Denver, it is an asset used by travelers across the wider Great Plains and Rocky Mountain regions.  The competitive air service offered at DEN results in airfares well below the U.S. average, benefitting all types of travelers, especially in today’s inflationary environment.  The Denver metro region and state of Colorado receive much of the benefit from the economic impact and job creation that supports the operation of DEN, but the wider impact in serving the growing population in the western U.S. is evident in the mix of travelers that use DEN as their primary airport.

The above catchment analysis entirely excludes the utility of expanded park and rides along the A-line that would reduce car travel along Pena Blvd. Investing in more reliable and affordable train service would free up capacity on Pena Blvd for those who do need to drive. Doubling down on a wider highway will instead just increase automobile dependency and lead to more congestion in 5-10 years as we have seen with every previous highway expansion in our city.