Some researchers have noted that the current procedures in the "Highway Capacity Manual" (HCM) may not be appropriate for analyzing complex or oversaturated freeway facilities. The results of a comparison of an HCM-based procedure with field data from six such freeway sites are reported. Because simulation has often been suggested as an alternative to the HCM for oversaturated freeway facilities, three simulation models (CORSIM, FREQ, and INTEGRATION) were also used to analyze these same six sites. The results suggest that the HCM-based procedures do as well as the three simulation models in reproducing the average speeds across the freeway facilities.