|
|
|
|
|
 |
|
 |
|
|
|
|
||||
|
STUDY REASONABLE SR-520 ALTERNATIVES
SR-520 SUPPLEMENTAL EIS MUST BE SCOPED TO INCLUDE, AND MUST FULLY ANALYZE, AN IMPROVED AND TRANSIT-OPTIMIZED FOUR-LANE ALTERNATIVE
Dear Gov. Gregoire, Secretary Hammond, Mayor Nickels, Ms. Earl, and FHWA:
As you know, FHWA, Sound Transit, and WSDOT are the co-lead agencies for the SR-520 Environmental Impact Statement (EIS). We urge you, as the responsible parties, to ensure that the supplemental EIS is scoped to include, and that it fully analyze, an improved and transit-optimized four-lane alternative. We write with great urgency because we understand that the current intention is not to do so.
NEPA and SEPA require consideration of reasonable alternatives. The SR-520 EIS is being carried out under both the National Environmental Policy Act and Washington’s State Environmental Policy Act. We need not remind you that both laws require that every reasonable alternative be analyzed. The NEPA regulations (40 CFR 1500.2) require the identification and assessment of “reasonable alternatives to proposed actions that will avoid or minimize adverse effects of these actions upon the quality of the human environment.” The SEPA regulations (WAC 197-11-786) require the examination of every “reasonable alternative,” defined as “an action that could feasibly attain or approximate a proposal’s objectives, but at a lower environmental cost or decreased level of degradation.”
As outlined below, an improved and transit-optimized four-lane alternative is clearly a reasonable alternative--in fact, depending on the outcome of the supplemental EIS, it could emerge as the only alternative that is feasible financially, environmentally, and in traffic impacts. To exclude it from the supplemental EIS would leave the entire process open to successful legal challenge. When the EIS is finalized and FHWA, Sound Transit, WSDOT, and the Governor are choosing a final action, it would also leave them without the analysis or the legal option that would allow them to choose an improved and transit-optimized four-lane alternative--even if the final EIS were to disallow the six-lane alternatives as environmentally destructive, financially unaffordable, and/or unsustainable traffic-wise.
ESHB 3096 does not remove the obligation to study a reasonable four-lane alternative. Earlier this month, the Washington legislature passed ESHB 3096, which states that SR-520 “shall be designed to provide six total lanes, with two lanes that are for transit and high occupancy vehicle travel, and four general purpose lanes.” That law also designates a “savings” to be realized from “Early construction of a single string of pontoons to support two lanes that are for transit and high-occupancy vehicle travel and four general purpose lanes.” These provisions of state law have no legal standing regarding your agencies’ selection, under NEPA and SEPA, of a preferred alternative in the supplemental EIS or in your choice of a final action in the final EIS. The legislature did not, and legally could not, designate a preferred alternative for the draft supplemental EIS, which is up to the agencies to decide as a part of the EIS analysis. Nor did the legislature designate a final action, which again is for the agencies, and then only as part of a legally concluded EIS.
The four-lane alternative in the draft EIS was poorly designed; the supplemental EIS must include a four-lane alternative that is substantially improved. Timely public comments on the draft SR-520 EIS identified many ways in which the four-lane alternative by its design was unnecessarily expensive, damaging to the environment, and unhelpful to transit. It had maximum sized lanes and shoulders—bigger than those in the six-lane alternatives that will be in the supplemental EIS. It had an eight-lane Portage Bay Viaduct (six striped lanes plus two lane-sized shoulders)—more than those in the six-lane alternatives that will be in the supplemental EIS. It lacked serious measures to make it easier for transit buses to get to and from the floating bridge; some of these measures are in the six-lane alternatives that will be in the supplement. It did not include any lids to reduce noise and stitch neighborhoods back together; the six-lane alternatives in the draft EIS had such lids. With these and other improvements, the four-lane alternative would be very different from the one that was analyzed in the draft EIS. Thus a greatly improved four-lane alternative should be studied in the draft supplemental EIS.
The mediation process is no legal substitute for the scoping of reasonable alternatives. Attempts have been made to call the state-funded mediation process the scoping process for the supplemental EIS. That cannot be, because the mediation process expressly prohibited discussion of any four-lane alternatives, and developed improvements only for the six-lane alternatives. As laid out below, many of these improvements can and should also be included in an improved four-lane alternative, along with other improvements that the mediation process did not consider because they are specific to a reasonable four-lane alternative.
An improved four-lane alternative is reasonable because (1) it can be optimized for transit, without the huge increase in single occupancy vehicle traffic that the six-lane alternatives create by building new HOV/transit lanes. The combination of ramp meters and tolls would keep a four-lane SR-520 bridge’s traffic free-flowing, so it is not clear that, once buses and car pools are on the bridge, they need their own HOV/transit lane (as suggested below, the improved four-lane bridge alternative should be studied with and without HOV/transit lanes). But it seems clear that helping buses get quickly to and from the bridge provides far more “bang for the buck” than building new HOV/transit lanes, and without dramatically increasing the bridge’s single occupancy vehicle capacity.
An improved four-lane alternative is reasonable because (2) it accommodates some additional general traffic, but not so much as the six-lane alternatives, which contribute to global warming by thwarting statewide goals to reduce vehicle miles traveled. Because lanes and shoulders would be wider than on the current bridge and the roadway geometry is improved, any four-lane alternative would carry somewhat more traffic than currently. But a four-lane alternative is much more help to the state in meeting the reductions in vehicle miles traveled (eighteen percent by 2020, thirty percent by 2035, and fifty percent by 2050) that the recently passed H.B. 2815 requires as statewide goals.
The draft EIS did not address global warming, prompting the Seattle City Council in its Res. 30974 to call on the SR-520 project to “develop a carbon footprint analysis for project alternatives and take steps to reduce carbon emissions in the corridor, consistent with the City of Seattle’s commitment to reduce greenhouse gas emissions and address the threat of global climate change." If the draft supplemental EIS is seriously to do so, it must consider an improved four-lane alternative. If the supplemental EIS considers only six-lane alternatives, it will be considering alternatives that would cause at least a 40 percent increase in single occupancy vehicle traffic.
An improved four-lane alternative is reasonable because (3) a well-functioning temporary four-lane bridge is already planned during bridge replacement. The temporary bridge is optimized for transit and has other features that WSDOT believes will allow it to function well during several years of construction. If the temporary four-lane bridge is so reasonable as to be included in all of the alternatives, certainly it is reasonable to study an improved four-lane alternative in the supplemental EIS.
An improved four-lane alternative is reasonable because (4) it is more financially affordable than the six-lane alternatives. According to WSDOT’s own cost estimates, most of the six-lane alternatives that have been studied in the draft EIS or will be studied in the supplemental EIS would cost billions of dollars in excess of the available funds. ESHB 3096 recognizes the following revenue sources for SR-520: $1.785 billion in state and federal funds; and between $1.5 and $2 billion in tolling revenue. Many observers think that these tolling revenue estimates are over-optimistic, but even if $2 billion is assumed, the state, federal, and tolling funds will total only $3.785 billion--well below the estimated costs of most of the six-lane alternatives that have emerged from the mediation process.
An improved four-lane alternative is reasonable because (5) it is easier and quicker to build, and has less construction impacts. A four-lane replacement can more quickly produce a safer and more functional bridge. Its construction impacts (truck noise, vibration, dust and pollution, fisheries, and traffic safety and tie-ups) would be far less than the six-lane alternatives, especially those that involve tunneling.
REQUESTED ELEMENTS OF THE IMPROVED FOUR-LANE ALTERNATIVE
The following elements that the mediation process has developed for one or more of the six-lane alternatives should be applied to an improved four-lane alternative:
(1) Width of lanes and shoulders reduced from FHWA standards (still would be larger than today). (2) Reduce to six the number of lanes on the Portage Bay Viaduct (from eight in the draft EIS). (3) Study the alternative both with and without the noise walls on the floating bridge and on the aerial and viaduct portions that create box-like visual obstructions and shadowing (4) Study the alternative both with and without lids at Montlake, 10th, and Roanoke (5) Study the transit enhancements that were developed for the six-lane alternatives
Other elements that should be added to an improved four-lane alternative:
(1) Optimize the alternative for transit through special bus lanes, ramps, rush-hour bus priority lanes on city streets, signal pre-emption, and other transit-friendly measures. Study a “Texas T” bus ramp to and SR-520 near the Montlake interchange. (2) Study the alternative in three formats: as general purposes lanes; with two lanes for HOV/Transit; and with two lanes for buses, with the remaining two lanes to be shared by High Occupancy Vehicles, freight-trucks, and surcharge-paying single occupancy vehicles. (3) Study the alternative both with continuous safety shoulders; and with safety shoulders that are intermittent, and thus cast less shadow and cannot later be converted to travel lanes. (5) Substantially reduce the new floating bridge’s height over the water. (7) Study both a new bridge and as a retrofit of the existing bridge. (8) No widening of Montlake Blvd., 25th, 45th, or Sand Point Way. (9) No new bridge or tunnel across the Montlake cut.
Request for update of traffic models. We request that the EIS process commit to evaluating all alternatives with traffic projection models that are updated to reflect the availability of an integrated, advanced regional transit network. This step would level the playing field, where early action to enhance transit choice could be used to save money by a smaller structure, to move people and goods rather than vehicles.
Signatories (unless noted, organizations are listed for identification purposes only)
Carolyn Allen, Montlake resident Russ Amick, Laurelhurst resident Mary and John Bailey, Roanoke Park residents Rick Barrett, Haller Lake resident Doug and Mary Bayley, North Capitol Hill residents Earl Bell, retired UW faculty and University Park resident Dominique Blachon, Madison Park resident Roderick A. Cameron and Heather Howard, Laurelhurst residents Harriett Cody & Harvey Sadis, Madrona residents Robert Corwin, AICP, North Capitol Hill resident Herbert Curl, Jr., University District resident and oceanographer Eliza Davidson, North Capitol Hill resident and board member of Friends of Seattle’s Olmsted Parks Diana T. Forman, Portage Bay resident Judy Foss, Save Union Bay John Fox, Seattle Displacement Coalition Paul Gibson, Montlake resident Lester Goldstein, Wallingford resident Al Hallstrom, UW faculty and Eastlake resident; and Eileen Hallstrom, Eastlake resident Tom Hammond, UW employee and Arboretum advocate Katherine Hanson, and Michael Schick, Portage Bay residents William Hanson, Madrona Community Council Susan Harmon and Richard Meyer, Portage Bay residents Alan Hunt, Portage Bay resident Douglas E. Jackson, Past-President of Friends of Seattle’s Olmsted Parks, and Queen Anne resident Giff and Mary Jones, board of Floating Homes Association (which has endorsed this letter) Brooks Kolb, President, Friends of Seattle’s Olmsted Parks; Lakewood/Seward Park resident Linda R. Larson, Queen Anne resident Chris Leman, Vice President, Eastlake Community Council Penny Lewis, Portage Bay resident Jan and Sid McFarland, Eastlake houseboat residents Mike McCormick, Roosevelt neighborhood Ruth McCormick, Eastlake resident Mahlon Meyer, Portage Bay resident Paul Michelson, Meadowbrook/Lake City resident Susan Moss, UWBG Director's Guild Ed Newbold, wildlife artist Heather and Greg Oaksen, North Capitol Hill residents Erin O’Connor, Friends of Roanoke Park Kari Olson, North Capitol Hill resident Donna Peters, Eastlake resident and former Vice President of the Eastlake Community Council Gerald Pollet, JD; Executive Director, Heart of America Northwest (which has endorsed this letter) Dorli T. Rainey, Queen Anne resident Marilyn Robertson and Dr. James Weyand, Portage Bay houseboaters Catherine McNutt Rooks and Harold R. Rooks, North Capitol Hill residents Tom and Anna Rudd, North Capitol Hill residents David Rudo, Madrona resident Richard Saunders, Ravenna/Bryant resident Deborah Shattuck and Jim Flint, Bryant neighborhood residents Ann P. Streissguth, North Capitol Hill resident Joyce Talbot, Laurelhurst resident Ted Choi Tam, Montlake resident and former president of Eastlake Community Council Cheryl Trivison, Seattle Urban Forest Stakeholders and North Capitol Hill resident Ronald Turner, Belltown Housing and Land Use Subcommittee Vernon Van Steenkist, Eastlake Bus Riders Coalition Catherine van Veen, Eastlake resident Lisa White and Kevin Kogut, Laurelhurst residents. Lindy Wishard, Madison Valley resident Barbara Zegar, Eastlake resident and former president of Eastlake Community Council
|
|
|
| [LetterC] |