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A world without NEPA: Rochester Inner Loop East

Planned reconstruction of the Rochester Inner Loop East (2013) // Photo courtesy of the City of Rochester

The city of Rochester, New York, is located along the shores of Lake Ontario. Like many prosperous cities in the first few decades of the 20th century, Rochester experienced a rapid increase in vehicle ownership and local roadway congestion. In response, the New York State Department of Transportation (NYSDOT), working closely with city officials, began planning a series of projects to increase roadway capacity and improve traffic flow. A central element of these plans was a beltway that would circle the city that became known as the Inner Loop

At the time, state engineers expected that the region’s economy and population would continue to grow for decades to come, requiring an expansive facility able to accommodate steadily rising travel demand. Construction of the Inner Loop involved the condemnation of significant amounts of property around the city’s core – the widest section of the Inner Loop corridor would span nearly 355 feet, or 12 lanes, including frontage roads and access ramps. In order to maximize the speed and efficiency of vehicle movement, engineers also decided to make a large portion of the Inner Loop a grade-separated facility, meaning that the roadway is dug into the ground to avoid the need for intersections. This design allows the uninterrupted flow of vehicles.

The Inner Loop expressway opened to traffic in 1965. Unfortunately, NYSDOT engineers’ expectations did not match future realities. NYSDOT could not have anticipated the sprawl-inducing effects that the interstate highway system would have on the country, nor the loss of jobs and population that Rochester would experience due to structural changes in the economy.

While NYSDOT pushed forward with the Inner Loop, the federal government simultaneously began construction of the Interstate Highway System. In the Rochester area, this included the construction of Interstate 490, Interstate 390, and Interstate 590 to the south, west, and east of downtown. Over time, the mobility provided by these facilities pulled housing and jobs out of the city. This reduced the level of demand for the Inner Loop—especially the east portion, marked as State Route 940T, that runs northeast from the interchange with I-490 to Main Street.

Equally as consequential, Rochester’s population began to decline from a peak of 330,000 in the 1950s to approximately 209,000 today. For many years, the economic health of the Rochester region was tied to several Fortune 500 companies, including Eastman Kodak Co., Xerox Corp., and Bausch & Lomb Inc., as well as the University of Rochester and the Rochester Institute of Technology. At its peak, Kodak employed approximately 60,000 people within the region before layoffs pushed the number down to just a few thousand. In January 2012, Kodak filed for bankruptcy. Since that time, local leaders have pushed to diversify the economy by leveraging the technical expertise of the labor force in fields tied to optics and photonics, among others. Yet even with these proactive steps, overall population growth has not returned to the city.

Initial construction of the Inner Loop // Photo courtesy of the City of Rochester

For years, travel demand along the eastern portion of the Inner Loop has been so low that even during rush hour the expressway is sometimes completely empty. In fact, total daily traffic on the eastern portion often falls below 7,000 vehicles—substantially less than what the facility was designed to carry. This means that the city and its residents are left to deal with all the negative consequences of the size and design of the expressway while it delivers few of the intended mobility benefits. Additionally, maintaining this underused facility has drained resources that could have been spent on other projects over the years. 

Beginning in 1990, city officials adopted a plan to reconstruct the eastern portion of the Inner Loop as an at-grade boulevard. In 2013, the city successfully applied for funding from the U.S. Department of Transportation’s Transportation Investment Generating Economic Recovery grant program to undertake the conversion. When completed, the boulevard will have several key elements designed to reconnect the downtown to the surrounding area and facilitate more pedestrian access, including wide sidewalks, generous tree canopy, a two-way cycle track, and reconnected city streets. 

Overall, the boulevard is intended to achieve four key goals: first, to right-size the roadway to reflect the reduced level of travel demand; second, to avoid the expense of repairing aging retaining walls and several structurally deficient bridges that spanned the Inner Loop East; third, to eliminate the immense physical barrier created by the Inner Loop that separates the city center from surrounding commercial districts and residential neighborhoods; and fourth, to return nine acres of land currently used as part of the loop to productive use as a combination of green space and mixed-use development with housing and retail businesses.

The total cost of converting the loop to a boulevard is $23.6 million. A comprehensive analysis determined that the projected benefit-to-cost ratio is more than 2-to-1. The largest savings come from avoiding major repair costs associated with the aging bridges and retaining walls of the Inner Loop East. Overall, the conversion will save the city and state an estimated $25.9 million. Additionally, new development on the nine acres of reclaimed land is projected to generate $7.3 million in value. Finally, the value of adjacent parcels to the new boulevard is expected to rise by more than $15 million.

The Inner Loop East conversion project occurred long before the adoption of National Environmental Policy Act (NEPA) and other important statutes designed to protect the environment and ensure robust public participation in the government decision-making process.

The Inner Loop East during rush hour 2014 // Photo courtesy of the City of Rochester

Because NYSDOT engineers were singularly focused was on efficiently moving large numbers of vehicles during the design phase of the Inner Loop – each design element, from the number of lanes to the grade-separated, access-controlled alignment, was intended to maximize the speed and carrying capacity of the expressway – the broader socio-economic impacts on Rochester’s downtown core and the surrounding neighborhoods were simply not considered. The once fluid connection that existed between downtown Rochester and east side neighborhoods, including East End, Upper East End, and Manhattan Square, was eliminated by what the Wadsworth Square Neighborhood Association called a “moat like” structure. 

This singular focus was the product of two organizations factors. First, highway engineers operated and continue to operate from a regional perspective. After all, highways are not isolated facilities but rather connected structures that form an integrated system. Changing the design in one location has cascading effects throughout the regional network. Second, the unit of analysis for highway engineers is the automobile. Design choices are judged by their impact on vehicle speed, capacity, and safety—not the ease of pedestrian crossings, the number of disruptions to the surrounding street grid, or the amount of derelict and unusable land that surrounds the facility. In essence, the measure of a structure stops at the structure’s edge, with its value determined by what happens between the lines.

By comparison, people—and neighborhoods more broadly—experience highway facilities in a nuanced way. A highway is not simply a line on a map associated with a daily vehicle count. Instead, a highway is a physical object that affects property values, zoning, economic development, safety, and access to opportunity, among other outcomes. The environmental review process is how community members can connect with planners to try to expand the design objectives to include considerations beyond what happens to vehicles.

Modern laws like NEPA work to counteract these organizational biases, requiring the government to take a holistic approach by engaging in a review process designed to discover any significant socio-economic, environmental, or public health impacts before a decision is made. This ensures that those who manage federal projects make the best decisions based on the best information while involving the public.

Building major facilities almost always means change for nature and communities, and the NEPA review process would not have helped state engineers in the 1950s peer into a crystal ball to foresee large-scale population loss and declining travel demand. However, the NEPA process would have given That means the Inner Loop. Local leaders have worked for over 25 years to remediate the damage done by the Inner Loop, and had local communities been given the same opportunity to weigh in on the project back in the 1950s, there is no reason to think a more integrated and sustainable solution like the one designed in 2013 might not have been the end result.



“Inner Loop East Transformation Project: Final Design Report—Volume 1.” City of Rochester Department of Environmental Services, New York State Department of Transportation, and Federal Highway Administration. 2014. Available at:

Duncan T. Moore. “No Rust in Rochester.” The New York Times. February 2, 2012. Available at:

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