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1 April 2008
Subject: SR-520 Supplemental EIS Must Include, and Must Fully Analyze, Improved and Transit-Optimized Alternatives
Dear Gov. Gregoire, Secretary Hammond, Mayor Nickels, Ms. Earl, and FHWA:
The Sierra Club Cascade Chapter urges you to ensure that the SR-520 Supplemental Environmental Impact Statement (EIS) include, and fully analyze, improved and transit-optimized alternatives of both four- and six-lane widths. We understand the current intention is not to include an improved, transit-optimized four-lane option, and we find the six-lane options do not adequately provide for high-capacity transit connections, especially light rail, within the context of a regional network. We urge you to correct these deficiencies in the scoping process for the supplemental EIS.
Climate Impact Assessments Need to Influence Project Scale and Elements
The identified and expected impacts of climate change demand that we reduce our carbon footprint in all sectors, especially transportation. Sierra Club urges the development of transportation options that support state, county and city greenhouse gas (GHG) emission reduction goals. We urge that GHG assessments be conducted and used to evaluate, rank, and select project elements and design configurations. These assessments should be based on GHG emissions from construction as well as from operation of the various travel modes through the SR-520 corridor over the life of the facility. Since high capacity transit (HCT) promotes compact, walkable residential and commercial areas around transit stations thereby reducing associated GHG emissions, design for the SR-520 bridge should optimize the role of transit.
Sierra Club emphasizes good transit connections, minimized environmental impacts, and inclusion of high-capacity transit in the design of this SR-520 bridge project. In the sections that follow, we identify a key need in the evaluation of all alternatives, summarize a set of design elements that should be incorporated into a transit-oriented six-lane alternative, and then provide a set of elements for a transit-optimized four-lane alternative. A set of rationale for including the four-lane alternative is then described in brief.
Update Traffic Models to Consider Effects of Tolls
We request that the EIS process commit to evaluating all alternatives with traffic projection models that are updated to reflect the effects of variable price tolling on trans-Lake corridors and on all limited-access highways in the region, and to reflect the availability of an integrated, advanced regional transit network. This step would more accurately depict the changes in travel behavior that regional residents can make in response to user premium pricing and to more mobility options. For example, variable pricing of all-traffic lanes renders HOV lanes less effective, since it can keep traffic flowing and creates a monetary incentive for carpooling. Early action to enhance transit choice could be used to reduce cost with a transit-optimized structure that emphasizes moving people and goods rather than vehicles.
Accommodate HCT From the Outset in Six-Lane Alternative; Don’t Wait to Retrofit
Elements that should be added to a high-capacity transit oriented improved six-lane alternative: (1) Designate as transit only the two lanes that are identified in the intent section of ESHB 3096 as being “for transit and high occupancy vehicle travel”. Include all necessary features for these lanes to accommodate light rail transit from the outset. Allow use of these lanes by certified vanpools only during any short interim period prior to light rail operation. (2) Include a light rail only tunnel (or other suitable crossing) underneath (or over) the Montlake Cut to connect the transit lanes on the bridge with the UW Medical Center light rail station. The potential alignments should consider such possibilities as a westward continuation of the line towards Ballard and not be solely designed to connect with or merge into the Capitol Hill North Link LRT tunnel. (3) Optimize the alternative for bus transit through priority right-of-way such as rush-hour bus priority lanes on City streets, signal pre-emption, and other transit-friendly measures. Study a set of center access (left-hand exit and entry) ramps that buses and general traffic can use to and from SR-520 at the Montlake Blvd. interchange. (4) Design center access ramps for connection with the South Kirkland Transit Center to be suitable for joint LRT train and bus use. (5) 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. (6) Substantially reduce the new floating bridge’s height over the water. (8) Configure SR-520 interchange at Montlake Blvd. to improve eastbound access from the south such as direct right-hand turn on-ramp with either left-hand or right-hand merge. (9) Eliminate the berm and cut and cover tunnel options for the highway, which interrupt the hydrology within the Arboretum wetlands near Marsh Island.
Requested Elements in an Improved Four-Lane Alternative for SEIS
The following elements, which the mediation process has developed for one or more of the six-lane alternatives, should be applied to an improved four-lane alternative to be included in the Supplemental EIS: (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 seven 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 Blvd., 10th Ave. E., and E. Roanoke St. (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, in addition to those identified through mediation as suitable for the six-lane plans, include: (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 set of center access (left-hand exit and entry) ramps that buses and general traffic, or buses only, can use to and from SR-520 at the Montlake Blvd. interchange. (2) Study the alternative in two formats:
(4) Substantially reduce the new floating bridge’s height over the water. (6) Configure SR-520 interchange at Montlake Blvd. to improve eastbound access from the south such as direct right-hand turn on-ramp with either left-hand or right-hand merge. (7) Study both a new bridge and as a retrofit of the existing bridge. (8) Only HCT use of any new bridge or tunnel crossing the Montlake Cut.
Reasonable Four-Lane Alternative Needed in SEIS, Not Inadequate Version in Draft EIS
Public comments on the draft SR-520 EIS identified many ways in which the four-lane alternative was unnecessarily expensive, damaging to the environment, and unhelpful to transit. It lacked serious provisions to speed transit buses to and from the floating bridge. It did not include any lids to reduce noise and to stitch neighborhoods back together; the six-lane alternatives in the draft EIS had such lids. With improvements such as those listed above, the four-lane alternative would be very different from the one that was analyzed in the draft EIS.
Under both the National Environmental Policy Act and Washington’s State Environmental Policy Act, reasonable alternatives, those considered to “feasibly attain or approximate a proposal’s objectives” should be analyzed. The objectives for the SR-520 bridge replacement project need to be expressed as moving people and goods while contributing to the reduction of GHG emissions from our transportation system. The passage of ESHB 3096 by the 2008 Legislature, despite its description of a corridor design, does not preempt the obligation of your agencies to analyze and select a preferred alternative consistent with NEPA and SEPA processes.
The SR-520 project mediation process is no legal substitute for the scoping of reasonable alternatives. An improved and transit-optimized four-lane alternative is clearly a reasonable alternative, and as such should be included in the supplemental EIS. When a final action is chosen, the decision-makers will need a complete analysis and legal basis to allow them to choose transit-optimized alternatives whether the bridge configuration is four or six lanes.
An improved four-lane alternative is reasonable because: (1) it can be optimized for transit, without the increase in single occupancy vehicle traffic that most six-lane alternatives induce by building new HOV/transit lanes.
(2) it accommodates some additional general traffic through improved roadway geometry, but not so much as do most six-lane alternatives, which contribute to global warming. The four-lane alternative will assist the state in meeting the reductions in vehicle miles traveled called for in HB 2815.
(3) a well-functioning temporary four-lane bridge is already planned during bridge replacement. 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.
(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 available funds.
(5) it is easier and quicker to build and has less construction impacts than six-lane alternatives.
Summary of Rationale
Past assumptions and practices concerning our transportation system will no longer serve us in a changing world. We know that our future will bring us climate change impacts and rising energy costs, the only question is how rapidly. When we invest in our transportation infrastructure for half or three-quarters of a century as with a new SR-520 bridge, the region needs to take into account the imperative to reduce GHG emissions and to provide high quality HCT in such a corridor. The Sierra Club strongly urges the inclusion in the Supplemental EIS of a transit-priority six-lane alternative that accommodates light rail from the opening of the facility. We also believe that inclusion of an improved, transit-optimized four-lane alternative is essential based on the financial and environmental risks associated with this project. The objectives that all these alternatives seek to achieve must emphasize moving people and goods rather than vehicles. The objectives must also seek to reduce GHG emissions.
Thank you for your time and consideration of our perspectives.
Sincerely,
Mike O’Brien, Cascade Chapter Chair
Tim Gould, Chapter Transportation Committee Chair
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| [LetterS] |