Judge Amy Berman Jackson vacated the agencies’ decision to proceed with the 15th Street Cycle Track Removal and Road Repaving Project, ruling that the administrative record lacked reasoned decisionmaking and failed to adequately consider relevant safety data.
The dispute centers on the government’s plan to strip the 15th Street corridor of its dedicated bike lanes and restore a conventional vehicular configuration. The agencies cited Executive Order 14252, which calls for the District of Columbia to showcase "beautiful, clean, and safe public spaces," and argued that removing the lanes would relieve traffic congestion during upcoming America’s 250th anniversary celebrations.
The court found the agencies’ justification deficient because it relied on vague aesthetic and logistical goals without explaining how removing the lanes would achieve them. The opinion noted that the decision documents offered no factual or statistical underpinning for the conclusion that traffic would flow more smoothly with an additional car lane.
Critically, the court highlighted the agencies’ failure to properly weigh a post-installation study by the D.C. Department of Transportation. That study showed the bike lanes reduced all roadway crashes by 46 percent and bicycle injury crashes by 91 percent, while also decreasing peak-hour travel times.
Although the Federal Highway Administration issued an internal review claiming the DDOT study had methodological flaws, Judge Jackson found the agencies gave the study only "limited weight" without providing their own data or conducting a cost-benefit analysis. The court stated the record was devoid of any examination of whether allowing cyclists to return to shared roads or sidewalks would advance the agencies’ stated safety and mobility objectives.
The court also rejected the agencies’ reliance on the National Environmental Policy Act’s categorical exclusion for the removal project. It held that the agencies failed to address the "extraordinary circumstance" of significant impacts on public health and safety, which precluded reliance on the exclusion.
The decision vacates and remands the removal project. The court denied the plaintiff’s motion for interim injunctive relief as moot given the vacatur.