Who is Completing the Application?

Please provide contact information for the person who will complete the online application for this project. The email address and password entered here will be used to complete and submit both Pre-Applications and Applications.

Mariana Raschke

Associate at the Goodman Corporation


[email protected]

Primary Agency Information

Please provide contact information for the agency official who is representing the project sponsor. This individual will be considered the official applicant and must be authorized by their agency to submit this request for funding and make necessary assertations and representations on the agency’s behalf.

Memorial Heights Redevelopment Authority

Sherry Weesner



[email protected]

1980 Post Oak Boulevard, Suite 1380




Additional Agency Information

City of Houston

Sharon Moses-Burnside

Division Manager, Transportation Planning


[email protected]

611 Walker Street




Project Information

Shepherd & Durham Drive Complete Streets and Resiliency Project

Harris County

Shepherd, Durham, 24th, 20th, 19th, 18th, 15th, 14th, 11th

IH-610 eastbound frontage road to approximately White Oak Bayou. Shepherd and Durham are the limits for the cross-streets.

The Corridor Is Unsafe The four-lane configuration of both roads, poor access management, and failing infrastructure makes the project area unsafe for all users. Poor sight lines, failing pavement, a lack of multi-modal facilities, and an outdated design which encourages speeding (posted limit of 35 mph) have resulted in 672 crashes within the project area between 2015 and 2017. This includes 12 pedestrian and bicycle crashes. This crash rate is three times the Statewide average of similar facilities. There are a total of seven school crossings within the project limits, which exemplify the need for non-motorized user safety. The Corridor Is In Disrepair The roadways are in extremely poor condition with 2016 City of Houston pavement condition scores on Shepherd in the 20’s and 30’s, which are defined as “impacting the ability to drive at posted speeds” and pavement condition scores on Durham in the 40’s and 50’s, which are defined as “requiring significant maintenance and should be replaced.” Examples of poor conditions included with this application includes a screen capture of a sink hole that was present in early 2018. Alternative Modes Are Not Supported It is common to see bicyclists navigating four lanes of traffic, transit users walking along dirt paths, and young families pushing strollers over curbs to access Wright-Bembry Park. The under-construction H-E-B at 23rd and Shepherd will stimulate additional multimodal activity, as witnessed at the location on Dunlavy and Alabama in Montrose. The alternative mode demand in this area is enhanced by high frequency METRO routes, the proximity of the White Oak Bayou Trail system, and the Heights Hike and Bike Trail. This activity is hindered by existing conditions that feature no bike accommodations, dirt paths, broken and inconsistent sidewalks, missing curbs, and non-ADA compliant infrastructure. The Corridor Is Inefficient The corridor currently experiences congestion at the intersections of 11th and 20th due to a lack of optimized turning movements. Delay is also experienced due to extremely poor access management along the corridor. The majority of driveways are not delineated, and many businesses operate parking within what is currently the public right-of-way, creating delay during ingress/egress. Existing Infrastructure Does Not Support Economic Growth The project area is undergoing significant densification and redevelopment, with area American Community Survey (ACS) and Travel Demand Model data depicting annual growth rates of ~1.4% for residential and ~1.2% for commercial uses. This growth is resulting in increases in activity for all modes. The current infrastructure does not support the integration of all modes at the level of activity demonstrated today, let alone in the future. Furthermore, upgrades to infrastructure are projected to enhance local and regional economic activity, per the supplementary data provided.

SHEPHERD DRIVE Project Length: ~12,440 ft Project Limits: IH-610 EB Frontage Road to Larkin St. Scope: Reconstruct Shepherd from the IH-610 EB frontage road to the bridge structure just south of 6th. The project will include the replacement of all infrastructure within public ROW. Improvements include a 6-ft+ sidewalk, ADA ramps, a high-comfort bike facility, 4-ft clear zone buffers from the roadway, three 11-ft drive lanes (down from four currently), improved sight lines at turning movements, mast arm signalization, curb and gutter. The project will include landscaping such as street trees every 30-ft. METRO shelters will also be added and moved to the far side of each intersection, further reducing vehicular delay and improving transit ridership. The project includes intersection improvements at 20th and 11th to improve left/right turn movements which will reduce intersection level delay. Access management improvements (driveway consolidation/channelization) will serve to reduce corridor level delay. Storm sewer will be upgraded to meet code requirements for 2- and 100-year storm events, sanitary sewers and water lines will be upgraded to COH standards. MHRA will use local funding for the sanitary and water sewer improvements, as they are not grant eligible. Above ground and below ground utilities will be relocated as necessary to avoid obstructions. These will be completed via the franchise agreement between CPE and the COH. From 6th to Larkin, the roadway and bridge structure will be re-striped to accommodate an on-street, separated, bike lane. Another option under review is the utilization of the Shepherd Drive frontage road (located between 6th and 7th) to avoid the bridge entirely. In either scenario, no bridge structure will be modified as a component of this project. At Larkin, shared use path improvements will be constructed to tie Shepherd into the White Oak Bayou Trail system and Durham. DURHAM DRIVE Project Length: ~11,915 ft Project Limits: IH-610 EB Frontage Road to Darling Scope: Reconstruct Durham from the IH-610 EB frontage road to the bridge structure just north of 6th. The improvements to Durham are identical to those identified above for Shepherd, to include a reduction in travel lanes from four to three. From 6th to Darling., the bridge structure will largely be unchanged. At Darling, bike/pedestrian improvements will be constructed to tie Durham into the White Oak Bayou Trail system and Shepherd. Bicycle users will transition to Shepherd at 11th. 11TH, 14TH, 15TH, 18TH, 19TH, 20TH, 24TH STREETS Project Length: ~4,330 ft Project Limits: Shepherd Drive to Durham Drive Scope: Reconstruct facilities to accommodate curb and gutter cross section and improve sight lines at turning movements. Scope includes pedestrian facilities and public utilities to meet AASHTO/COH standards. Reconstruction of these intersection streets would accommodate the COH Bike Plan, which prescribes bike accommodations on 11th, 14th, 18th, and 24th.

Safety – Safety will improve for all users. The project area experiences, on average, 224 crashes annually. The modernization of the facility will reduce the crash rate by 15% which will reduce annual crash incidence by 34. The completion of access management through driveway consolidation/channelization will further improve safety for all users. Accommodate All Modes – Due to the improvements, it is estimated that there would be approximately 267 new bicycle users using the facility daily in 2025 and 873 new daily pedestrian users using the facility in 2025. Through 2018, the METRO #27 Shepherd Line experiences 2,700 average daily boardings, which ranks at #16 out of #28 high frequency routes. This is without reasonable bike/ped accommodations. It is expected that ridership will increase and overall system performance will improve as a result of the project. Ease Congestion – Even with the removal of a travel lane, the proposed intersection improvements will reduce daily vehicle hours travelled during the peak period in the project area by 258 hours in 2040. A supplemental benefit sheet has been provided to capture this benefit. Access management improvements will further serve to reduce delay and improve congestion within the project area, though this is unable to be quantified via a traditional Synchro analysis. This is captured via the H-GAC benefit sheet. These benefits should be considered as additive. State of Good Repair – The condition of the infrastructure would improve. The SOGR benefits were independently evaluated for Shepherd and Durham and do not include the intersecting streets identified as part of the current project scope. It is estimated that these projects would obviate maintenance costs and user delay to a $2018 value of $46.7M. This number would grow if the intersecting streets were taken into consideration. Economic Development – Over 20 years, this project will stimulate a significant amount of property value, sales tax, and general economic growth associated with construction. The estimated value, calculated through an IMPLAN analysis is $173.6M. Additionally, the one-time property value increase in the area due to the increased walkability and bikeability of the project area is estimated to increase by a total of $9.6M for Shepherd and by $6.2M for Durham. Resiliency –This project will incorporate upgraded stormwater capacity with upsized pipes as well as inline detention in the form of 8’x8’ boxes. This will allow compliance with COH stormwater requirements and will decrease localized flooding in the surrounding community along White Oak Bayou and the Turkey Gully tributary. According to COH datasets, approximately 1,473 structures within ½ mile of the project corridors flooded during Hurricane Harvey. This project will create a significant amount of additional storm water storage capacity via inline detention, which is a critical component of a sub-regional and regional drainage solution.



More than $100 million


1_Resolution of Support and Funding Commitment.pdf

Project Development/Readiness


Categorical Exclusion (CE)


• (d)-list Open-Ended Approval Authority for CEs. • 23 CFR 771.117(d) provides a means to approve categorical exclusions that are not specifically included on the (c)- and (d)-lists. FHWA refers to this as “(d)-list open-ended approval authority for CEs,” or more simply, an “open-ended (d) CE.” To qualify as an open-ended (d) CE, a project must meet all the criteria listed in 23 CFR 771.117(a) and the definition of a CE in 40 CFR 1508.4. A project meeting the Section (a) criteria automatically meets the definition in 40 CFR 1508.4. In addition, the project cannot have substantial controversy on environmental grounds.









Portions of 4 (at 11th Street)







Memorial Heights - TIRZ 5.pdf

7_SD Schedule.xlsx

What is unique about this project, and the alternatives analyzed, is that this project is able to achieve benefits for ALL users (bike/ped/transit/SOV) in ALL categories (safety, delay, state of good repair, and economic development) while reducing the amount of travel lane and without acquiring ROW to any significant degree. Several alternatives have been analyzed in the development of this project. 1. Four travel lane option – reviewed via traffic analysis and determined that LOS is not positively impacted with a four v. three lane option when intersection improvements at 11th and 20th are considered. The intersection improvements at these locations will allow for the 3-lane cross-section to function at an acceptable LOS. 2. On v. Off street bike facilities – the distinction between an off-street and on-street bicycle facility will be evaluated through a formal 30% process with the City of Houston and TxDOT. In either scenario, the facility will be a high-comfort facility with a clear separation from vehicular traffic. 3. One-way v. Two-way bike facility – the distinction between a one-way and two-way bike facility will be evaluated through a formal 30% process with the City of Houston and TxDOT. There are strong justifications for both options, which need to be evaluated by all potential project partners (MHRA, TxDOT, COH) under a funded scenario to adequately resolve. Part of this discussion revolved around implementation of the project. If only Shepherd or Durham were to be implemented, it would be beneficial to offer a two-way facility while the other corridor was in the funding and design stage. However, as both the Shepherd and Durham Corridors (to include the identified intersecting streets) have been included in the funding request, it may be most beneficial to offer two, one-way facilities to flow best with existing traffic and the commensurate one-way pairs. 4. Flood improvements – stormwater components were analyzed and upgraded to the current cost estimate level after the results of Hurricane Harvey were analyzed. It is important that TxDOT participate in these costs fully should this project be funded (typically TxDOT does not agree to participate in stormwater costs over and above a 2-year flood design level, regardless of MPO funding award). A scoping meeting was completed with TxDOT on December 20, 2017. This meeting was attended by the following TxDOT staff: Bill Brudnick, P.E., Eliza Paul, P.E., Pat Henry, P.E., and Mark Patterson, P.E. Meeting minutes from this coordination effort are included with the grant documentation. This project will require a Phase I ESA and will require completion of the TxDOT NEPA process. The Phase I ESA has been completed and the corridor is designated as a PPCA corridor, which requires monitoring during construction for contaminants and does not necessitate any Phase II work. This will help to expedite the HAZMAT component of the NEPA process. Additionally, a desktop environmental assessment for the project corridors was completed in 2015. At that time, no major impediments to implementation were identified. Engineering and planning began on this project in late 2015 with the creation of a new capital planning analysis for the Redevelopment Authority. Since then, what would be considered a preliminary engineering report, or 30% submittal, has been predominantly completed. To fulfill 30% design criteria, the full write up would be developed and submitted to the City of Houston and the project would complete a design summary report (DSR) process with TxDOT. It is anticipated that if funded, the full 30% submission could occur within 3-6 months of a funding decision. The formal 30% process will include the provision of solutions to the project alternatives listed previously. Additional milestones achieved include: • Coordination with METRO has occurred relative to bus stop placement and upgrades. • The completion of full topographic and boundary survey for the project area. This was completed in mid-2018. • Coordination with the COH has occurred regarding this project, cross sections, alignments, and other design considerations. • This project has been discussed in depth at MHRA board meetings, which are held on a monthly basis and include comment from the general public. Additional property owner coordination has occurred with all large property owners, on an individual basis. A public meeting for this project was also held on May 2, 2018. This meeting was held at the Heights Firehouse and was advertised via a public notice and a posting on NextDoor. The meeting was well attended. A summary of the meeting is included with these application materials. • This project will follow the standard COH/TxDOT utility coordination process which includes coordination at 30%, 60%, 90%, 95%, and 100% design. Utility relocation costs will be covered via the COH franchise agreement and/or the private utility provider. Due to the “road diet” concept, there will be sufficient ROW to efficiently relocate above ground utilities. The Redevelopment Authority is committed to the local share requirement for the federal funding being requested for this project, which is approximately 35%. In addition to this amount, the Redevelopment Authority is also providing funding for the PS&E, environmental, corner clip acquisition, and other incidental project costs. These other costs are estimated to be approximately $6M. When viewed holistically, and considering the entire project development timeline associated with this project, the local match for this project would be approximately 40%. The project team associated with the conceptual design on this project has an existing agreement with the Redevelopment Authority to complete 30% design. If funded, that contract will be extended to carry the project through 100% PS&E. This will allow the project schedule to proceed in the most efficient way possible.

MHRA - S&D TIP Readiness Materials.zip


MHRA Shepherd_Durham MPK map.zip

Project Budget

SD Budget Worksheet.xlsx


Benefit/Cost Analysis

MHRA Shepherd Durham_Roadway-Safety-Benefits.xlsx


MHRA Shepherd Durham__Roadway-Emissions-Benefits.xlsx

Shepherd Durham Synchro 092518.zip

MHRA SD Additional Benefits and Supporting Files.zip

Narrative Benefits

• Additional benefits have been generated in the areas of congestion (delay), bicycle and pedestrian estimated users, economic growth/development, and state of good repair. The congestion benefit provides an alternative look at the delay reduction experienced due to the intersection improvements completed due to this project. Note that the H-GAC benefit sheet captures congestion benefits due to access management. The intersection improvements should be considered as additive to the access management improvements. Bicycle and pedestrian estimated users provides a non-monetized qualitative benefit to demonstrate the amount of alternative mode utilization these facilities will receive. The economic growth/development benefit analysis proves the return on investment that this project will generate without the use of blanket assumptions regarding property value growth. In other words, economic development benefits are completed only using IMPLAN and via documented methodology. Finally, a state of good repair benefit analysis is completed to demonstrate the amount of maintenance savings (maintenance cost + user cost) that will be experienced due to the reconstruction of these facilities.

Planning Factors - Strengthen Regional Economic Competitiveness


The project area has been experiencing significant densification and growth over the past several years. The American Community Survey projects 1.49% of population growth each year through 2040 and the H-GAC Travel Demand forecast demonstrates job growth by approximately 1.2% annually. This growth can be witnessed through the conversion of 1950s-era 1,000 sqft bungalows being transformed into 2,500 sqft town and patio homes. It can also be seen in the new retail and restaurant uses springing up along the corridor. However, the infrastructure in the project area does not support this growth from the standpoints of modern-day mobility needs, safety, aesthetics, and general infrastructure upkeep. The project corridors, including the intersecting streets, are crumbling and falling apart. The intersecting streets are composed of ‘rural’ open-ditch cross-sections. Four travel lanes encourage speeding on roads with 35 MPH speed limits. This causes dangerous situations for pedestrians and non-motorized users, including families with young children using the facility. Stormwater and other public utilities are undersized and past their useful life. Transit facilities offer no refuge from the elements. Bicycle and pedestrian facilities are non-existent. All of these factors may convince property owners and investors to invest in a different area (to include a different region or state) with better existing infrastructure conditions. These conditions are undoubtedly depressing property values within the project area; especially given the proximity to the Downtown CBD. When this project is implemented, under-utilized land uses will be transformed into development of the highest and best use, which will result in additional property tax revenue for HISD, HCC, the COH, the Port of Houston, and other taxing districts within the area. Furthermore, when retail and restaurant uses are created, this additional sales tax revenue can be used by COH, METRO, and the State of Texas. One way of projecting taxable value benefit is by evaluating the property value increases experienced due to increased walkability and “bikeability” due to the introduction of sidewalks, bike lanes, and other supportive infrastructure. Research shows that an improved “Walk Score” can increase adjacent property values. Based on analysis completed in early 2018, independently for the corridors of Shepherd and Durham, these improvements could result in a onetime area property tax increase due to improvements on Shepherd by $9.6M and due to the improvements on Durham by $6.2M. Over 20 years, this project will stimulate a significant amount of property value, sales tax, and general economic growth associated with construction. The estimated value, calculated through an IMPLAN analysis, looks specifically at sales tax generated from new in-migration residents, commercial uses, and the on-time stimulus of sales taxes through the construction of the project, is $173.6 million.

Planning Factors - Enhances or Provides Intra/Inter-Regional Mobility


This project improves intra/inter regional mobility options in the following ways: a. This project significantly improves state of good repair (SOGR) for the corridors of Shepherd and Durham. These two major principal arterials provide connectivity between LP 610, IH-10, and ultimately, US-59/IH-69. This improved SOGR of the roadways will reduce roadway repair related user delay (which is frequently experienced in the form of concrete panel replacements and asphalt patches) and reduce user costs associated with potholes and other road failures which create flat tires, damaged suspension, and cause other detrimental impacts. These improved facilities are also critical urban freight corridors, extending benefits to freight users as well. This will improve inter and intra-regional mobility options for all motorized users. b. The project will significantly reduce crash rates along the project corridors. The projected crash reduction percentage varies (dependent upon HSIP codes used and which version of the HSIP criteria), but a total of 672 crashes were experienced in the project area between 2015 and 2017. The crash reduction associated with the modernization of the facility, improving traffic signals, adding new turn lanes, improving pedestrian signals, installing sidewalks, and adding demarcated bike lanes (not captured via HSIP criteria) will reduce the crash rates experienced. This reduction in the crash rate will not only improve safety and produce a commensurate monetized benefit but will also reduce delay experienced due to the collisions themselves as well as associated disruption due to EMT crews, fire, and police. This delay reduction will improve intra and inter-regional mobility options for all users. c. This project will reduce congestion related delay along both Shepherd and Durham via intersection level improvements and access management treatments. This delay reduction will benefit users of single-occupancy motor vehicles, fixed route transit, rideshare users, transportation network companies, and freight users. This improvement will benefit both inter and intra-regional mobility as this corridor provides access to LP 610, IH-10, and ultimately, US-59/IH-69. d. The project creates new alternative mode connections amongst the White Oak Bayou, Heights Hike and Bike Trail, the Nicholson Trail, and numerous residential, restaurant, retail, and business uses. These new connections will improve and provide new intra-regional mobility by providing a new multi-modal corridor and by improving the safety and reducing the barrier of entry for alternative mode users. e. This project will significantly improve access to transit (via pedestrian/bicycle transit access improvements). The access will facilitate improved connectivity to nearby transit hubs such as the Northwest Transit Center, Uptown BRT line, proposed High Speed Rail connectivity at the Northwest Mall, and the via connections, the entirety of the METRO fixed route system. These benefits will improve existing inter and intra-regional mobility options for alternative mode users.

Planning Factors - Resiliency/Flood Mitigation Strategies


This project will incorporate upgraded stormwater capacity with upsized pipes as well as inline detention in the form of 8’x8’ boxes. This will allow compliance with COH stormwater requirements and will decrease localized flooding in the surrounding community along White Oak Bayou and the Turkey Gully tributary. According to COH datasets, approximately 1,473 structures within ½ mile of the project corridors flooded during Hurricane Harvey. This project will create a significant amount of additional storm water storage capacity via inline detention, which is a critical component of a sub-regional and regional drainage solution. In addition to reducing structural flooding, the increased stormwater capacity will reduce localized ponding and flooding during rain events. This reduction in ponding will result in greater transportation access (emergency and non-emergency) during and after future rain events. These benefits will also occur on the connecting streets which are included in the project scope. These are 11th, 14th, 15th, 18th, 19th, 20th, and 24th Streets. Many of these streets are currently composed of a “rural” open ditch cross-section. These open ditches frequently are filled with debris (trash, vegetation, tree limbs, etc.) which prevent effective localized drainage into the stormwater system. Additionally, these ditches, over time, erode and become filled with sediment. As this occurs, it further degrades the ability of the ditch to convey stormwater. The project will upgrade these areas to an “urban” curb and gutter system with subsurface stormwater infrastructure. This subsurface infrastructure will include reinforced concrete pipe (RCP) to COH standards which will be able to capture a greater amount of stormwater than is currently possible. Furthermore, the subsurface RCP will prevent future drainage issues created by the open ditch system currently utilized.

Planning Factors - Improves Multimodal LOS




Highway/Freight LOS - Highway and freight LOS is improved via a reduction in delay achieved through the implementation of access management and intersection improvements. This will benefit all motorized users. Freight users will experience this benefit, as the corridor is designated as a critical urban freight corridor. Per the TxDOT Statewide Planning map, 10% of the traffic on Durham is trucks, and 15% of traffic on Shepherd is freight. LOS will improve via improvement in the corridors state of good repair, which will reduce user delay associated with roadway repair. Finally, LOS will improve via a reduction in crash rates associated with the proposed improvements. This LOS improvement will come as a result of decreased user delay associated with traffic disruptions due to EMT, fire, and police presence. Transit LOS - Transit LOS will experience the same improvements in travel time reliability and levels of service because of the delay reduction associated with the project listed above for general auto and freight users. Transit LOS also considers ridership and the entire spectrum of a transit trip: Ridership will increase via improved and accessible pedestrian facilities. Ridership increases will also occur due to accommodating pedestrian realm with wide sidewalks and street trees to provide shade. Transit travel times will decrease due to traversable sidewalks which may reduce the need for pedestrians to take indirect routes to reach bus stops or reach their end destination. Transit travel times will decrease due to new bicycle accessibility which may convert a portion of the trip to a bicycle trip from a pedestrian trip. This will reduce total travel time. Bike/Ped LOS – Bike/Ped LOS will improve due to many of the same reasons listed above for transit LOS. Improved pedestrian facilities will streamline pedestrian trips and eliminate the need for pedestrian users to use indirect routes due to existing pedestrian conditions. Achieving ADA compliance within the project area will provide accessibility which is currently not possible for wheelchair and other similar users. This is demonstrated by several of the photos submitted with this application which demonstrate a lack of ADA facilities. Bicycle LOS will increase due to the introduction of a high-comfort facility which will accommodate safe access through signalized intersections. Non-expert bike users typically travel on alternate and indirect routes to complete their bike trips to avoid the danger that is present along Shepherd and Durham. The introduction of the high-comfort facilities on these roads will allow all users to utilize direct routes This project will create new bicycle and pedestrian users by providing superior accommodations and enhancing connectivity to surrounding and supportive alternative mode infrastructure. These new users will enhance transit LOS by increasing ridership. All of these converted trips will improve roadway and freight LOS.

Planning Factors - State of Good Repair


While on-going maintenance costs can be considered, most of the benefit from a project such as this comes from the analysis of the repair v. replace scenario through a life-cycle cost analysis (LCCA). A LCCA is used determine the most cost-effective option to replace or maintain a roadway surface, when each option is equally appropriate to be implemented. It is important to note that in this situation most projects will include the replacement of sub-surface utility upgrades that make it necessary to reconstruct the entirety of the facility. As such, the LCCA is being completed not to justify the reconstruction, but to explore the benefits associated with reconstruction as opposed to continued on-going preventive maintenance of the existing roadway surface. These benefits include an analysis of agency costs (actual reconstruction versus repair) as well as user costs (time delay associated with one-time reconstruction versus more frequent repair). The methodology used in this analysis assumes that if the proposed project is not implemented, a full depth concrete panel repair/replacement or mill and overlay would be conducted at intervals to maintain the functionality of the roadway. Full-depth repair reinstates the structural integrity of the roadway and fixes localized structural problems. The expected life extension for full-depth repair or mill and overlay maintenance is between 6 and 18 years. This analysis assumes that the service life of concrete repairs is 15 years, and mill and overlay for asphalt is 10 years. For the Shepherd and Durham Corridors, the following was assumed based on existing conditions of the pavement as reviewed in the field in 2017. These conditions are substantially unchanged as of October 2018. Shepherd – Replace 10% of existing concrete panels in 2020 and 25% in 2035. Perform a mill and overlay on the entire surface every 10 years beginning in 2020. This repair scenario was chosen because the roadway is composed of concrete panels with an asphalt overlay. Durham - Replace 5% of concrete panels in 2020 and 25% in 2035. This repair scenario was chosen because the roadway is composed of un-asphalted concrete panels. The cost associated with construction and user cost (travel time delay) is $31.7M in $2018 for Shepherd and $15M in $2018 for Durham. These costs will not be incurred if this project is funded and the project is implemented as proposed. The model and methodology associated with this analysis has been included with this grant application. As it relates to reducing on-going maintenance costs, the COH now requires a minimum 50-year life span of proposed pavement. This is an increase from previous requirements of 30 to 40 years, depending on loads. This new pavement thickness criteria will reduce repair rates and delay incidence. This will improve SOGR and ultimately reduce costs for the City, the Redevelopment Authority, and the public.