I-90 Tolling EIS Futility

I recently received notice I-90 travel surveys were due to be returned to the Washington State Department of Transportation by Tuesday, November 26.  The survey results will help “inform WSDOT study of the potential effects of different I-90 tolling options between Seattle and Bellevue could have on Mercer Island”. 

All this is part of a WSDOT “comprehensive environmental review of tolling Interstate 90 between I-5 and I-405 to manage traffic and provide funding for construction of the unfunded SR 520 Program from I-5 to Medina”. 
 The WSDOT is apparently receiving $8.32 million of federal and state funding for the environmental review.  It’s not clear what Mercer Island has spent on their “No-Tolls-On I-90” effort.

All of this seems rather bizarre.  The fundamental problem is the 15,000 vehicles a day added to I-90 traffic since 520 tolling began have increased congestion there and reduced 520 tolling revenue.  Obviously one way to alleviate both problems is to add tolls to I-90.  They would provide added revenue, eliminate the incentive for those avoiding tolls to use I-90, and also encourage all I-90 commuters to car pool.  It doesn’t take millions of dollars and months of study to reach that conclusion.

A far better way to deal with the I-90 congestion and 520 funding is for Mercer Island to use the permitting process to stop East Link.   The fact that Sound Transit has blatantly lied for years about the “benefits” of light rail is surely ample legal ground for doing so.  “Persuade” Sound Transit to use the $2.8 billion East Link funding to eliminate the need for tolling on either bridge.   If they fail, not only will their commuters be faced with tolls, their easy commute into Seattle will change forever in 2016 when the I-90 Bridge center roadway is closed down for light rail.

Sound Transit UW Extension Problem

The Saturday Times front page article “Station on a fast track” about the light rail extension to the UW continues their lavish praise of Sound Transit.  Their comment that light rail “carries 32,000 riders a day—a figure that trails initial estimates” trivializes the fact Sound Transit “initial estimates” were for 110,000 riders by 2010. They then make the prediction that the “3-mile tunnel to the university should eventually add 70,000 riders” and quote claims of a “pretty darn incredible 6 minute trip”.  

What the Times doesn’t understand is the failure of Sound Transit to locate a T/C at the University station makes a mockery of any 70,000 rider estimate.  Sound Transit claims for 15,000 riders from the “Northgate” extension requires they “persuade” Metro to end Route 51 from Northgate T/C; a faster and far less expensive alternative.  Even with those riders, it’s hard to expect anywhere near 55,000 riders each day between the UW and downtown.

The UW T/C would provide an excellent interface between 520 cross-lake BRT bus service and Central Link light rail.  Eastside residents could have express bus service from every P&R in the area to UW and a “pretty darn incredible 6 minute trip” into Seattle.  Seattleites could use the return routes to provide light rail/BRT connections to Microsoft and all the major work destinations on the eastside.  

Terminating the 520 bus routes at UW will alleviate the problems with merging the three 520 lanes with I-5 and reduce downtown congestion.  The large numbers of riders in both directions is the only way for the UW extension to approach 70,000 additional riders to Central Link.  If the Seattle Times is really interested in making Central Link viable they ought to advocate for a T/C at the University station.

Seattle Times Ineptitude

The Sunday Times editorial urging the legislators pass the “State Transportation Package” continues their ineptitude when it comes to dealing with the areas transportation problems.  They support raising gas taxes by 11.5 cents, making our rates 3^rd highest in the country.  Doing so will generate about $2.5 billion over the next ten years, a small part of the “$12.3 billion” supposedly needed for a “more functional transportation system”.   They propose to get the other $10 billion from a “buffet of local tax options”.  Some buffet!

The Times “fixes” do little to reduce the congestion that “makes Greater Seattle the fourth-most congested metro area in the country”.    They only apparent benefit from the increased gas tax for east side is the funding for “the west side landing of the Highway 520 floating bridge”.   The only significant eastside benefit from the “buffet of local tax options” will be the elimination of I-90 tolls.  Thus, the $12.3 billion the Times is advocating be spent over the next 10 years will do very little if anything to ease eastside congestion.  

Even more inept, the Times ignores the fact Sound Transit will spend $18.5 billion (2007$) on Prop 1 light rail extensions that will do absolutely nothing to ease congestion. Their $2.8 billion East Link extension will substantially increase cross-lake congestion when they close down the I-90 Bridge center roadway in 2016 to install light rail.  When completed (2023?) the trains will have a miniscule effect on cross-lake congestion because they lack both the capacity and accessibility needed for more than a fraction of cross-lake commuters.  (See 5/15/12 Post)

Sound Transit will spend the remaining Prop 1 billions on Central Link extensions to Lynnwood and Federal Way that fail any rational cost/benefit analysis.  The result will be a perpetual financial “black hole” from the huge construction debt and increased subsides to operate over the longer routes.  What’s absurd is the commute time for those who chose to ride the trains will be longer than what is currently available or could easily be available with far less expensive buses.  (See 4/26/13 Post)

In conclusion, the nearly $31 billion the Times advocates spending over the next 10 years will do very little to reduce congestion.   If that doesn’t qualify for “inept” I don’t know what does.  Obviously, the same adjective applies to the Sound Transit Board and the WSDOT who are directly responsible for this debacle and the legislature's Joint Transportation Committee members whose oversight failure continues to allow it. 

Mercer Island East Link Permit Approval Contingencies

 A recent article in the Times announced that home valuations on Mercer Island ranked 21^st in the country.   Undoubtedly one of the reasons for this is the fact the island provides a suburban atmosphere with easy commuting into Seattle.  Residents currently have exclusive single occupancy vehicle (SOV) use of the HOV lanes for fast, reliable commutes into and out of Seattle.  Anything that detracts from this favorable commute would seem to adversely impact the island’s “attractiveness” and home values

Presumably it’s this concern that prompted Mercer Island officials to lead the objection to WSDOT plans for tolls on I-90.   Unfortunately their attempt to use an Environmental Impact Statement (EIS) to prevent the tolls is “unlikely” to succeed (See 11/08/13 post).  

Even if they do manage to eliminate the tolls their resident’s commute into Seattle will change forever when Sound Transit shuts down the center roadway to install light rail (See 9/25/13 post).  What’s inexplicable is Mercer Island officials’ apparent willingness to go along with an East Link program with such adverse affects on the commute and the islands “attractiveness”.

Both Mercer Island and Bellevue have to approve permits allowing ST to proceed.  Bellevue officials are well on the path toward approval.  They’ve apparently concluded cross-lake light rail will improve access to Bellevue for Seattleites.  It seems they’ve also decided increased cross-lake congestion from light rail will make Bellevue more attractive than Seattle for future growth from suburban I-90 commuters.  They’re willing to accept the increased congestion for east side cross-lake commuters with limited access to light rail and the devastation along the route into Bellevue to achieve the future growth.  (The fact the WSDOT is a willing partner with ST plans to spend $2.8 billion on a transportation project that will increase congestion is beyond "inexplicable") 

Mercer Island only looses if they approve their 4 permits for ST.   It’s unlikely many Seattleites will use light rail to commute there and Bellevue is far more convenient for commuters facing congestion along I-90.   While there are limits to what they can do in not approving the permits, they surely have the ability to make it contingent on ST meeting certain requirements.  For example, make ST demonstrate their residents’ commutes will not be adversely affected by light rail.   

Require they demonstrate their EIS claim  “Travel times across I-90 for vehicles and trucks would also improve or remain similar with East Link”. Doing so would require ST expedite the 4^th lane on the outer roadway and temporarily close off the center roadway. The fact an FHWA study documented in Sept 2004 concludes the modified outer roadway wouldn’t have the needed capacity makes it even more imperative to insist on the demonstration (See 5/15/12 post). (The added lane would also eliminate the outer roadway congestion purportedly prompting I-90 tolls.)

Mercer Island officials surely owe it to residents to do whatever is possible to assure light rail will not degrade their residents commute and the value of their homes.   They can also use their resident legislators WSDOT oversight to support their demands.   Whether they will use the approval process and resident legislators to force ST to demonstrate adequate outer roadway capacity remains to be seen.  The FHWA results, if confirmed in the test, will force ST to concede light rail will increase not decrease cross-lake congestion.  The sooner that happens the quicker the WSDOT will be forced to disallow cross-lake light rail and East Link money can be used to fund 520 and 405 improvements that will reduce congestion not increase it.

Notollingon1-90 EIS Scoping Faiure

My engineering background frequently leaves me amazed at the methods the legal system uses to “resolve” issues.  For example, the 3/16/13 post details how the judge in the recent BBB suit based his decision on arguments the defendants never included in their filings.   The 9/23/13 post details how the State’s Attorney General praised lawyers who seemingly committed mal practice by either failing to read documents (or worse) they used to mislead a judge into allowing East Link to precede. 

The attempt by Mercer Island officials to stop tolling on I-90 is another example.

I recently received  “update #17 on the city’s efforts to oppose tolling of I-90”.   It referred to a WSDOY study of 6 different tolling options.   Typical of the WSDOT, they never considered “not tolling” the HOV lanes on the outer roadways, the best way to reduce congestion by encouraging carpools that would have reduced congestion.  

The update also referred to their final scoping letter “advocating for a thorough and broad study and for a comprehensive analysis for alternatives to tolling”.  The letter includes the following introduction:

The City continues to oppose tolling I-90. As with its February 22, 2013 scoping letter, however, the City's comments will focus on helping WSDOTto develop a comprehensive Environmental Impact Statement ("EIS") sufficient to withstand judicial review under NEPA or the SEPA.

As a participating agency, the City looks forward to working with WSDOT and Federal Highway Administration ("FHWA") on development of an EIS that thoroughly analyzes the environmental impacts of tolling I-90 and all reasonable alternatives, including significant diversion-related impacts to transportation, water quality, greenhouse gases, public health and safety, and air quality. While this letter points to certain alternatives that it believes could have less environmental impact, the City does not endorse any particular alternative. Instead, the City's goal is that the EIS will explore in detail all funding alternatives (as per Engrossed Substitute Senate Bill ("ESSB") 5024)) and all reasonable alternatives (as required by NEPA).

The executive summary continues: 

These comments build on the City's earlier comments but also reflect its concerns with the revised purpose and need statement and scoping materials.

They then identify specific concerns:

NEPA and SEPA require WSDOT to consider all reasonable alternatives, and failure to analyze a reasonable alternative is grounds for invalidation of an EIS. ESSB 5024 directs WSDOT to examine "all funding alternatives."

EPA and SEPA require WSDOT to analyze and disclose all significant environmental impacts, wherever they might occur. Given the likelihood of diversion to other routes, the study area for this EIS should encompass the entire Central Puget Sound Region

Mercer Island officials apparently base their opposition to I-90 tolling on concerns that “diversion” will result in “excessive” congestion on routes around the lake.  As one who spent several years commuting around the south end of Lake Washington I doubt many will find that a viable alternative.   Thus, the only way to reduce congestion with the current options under consideration is to toll I-90.  It will reduce I-90 traffic by eliminating the incentive for those avoiding 520 tolls and encourage others to car pool and share the costs. 

The Mercer Island argument for not tolling I-90 comes down not to reducing congestion but finding “alternative funding sources” for 520 bridge financing.   The rest of the letter goes into these alternate funding sources.   Since none of these funding sources reduce congestion it’s highly unlikely any “scoping” changes Mercer Island officials have proposed for funding will prevent tolling on I-90.

The only way Mercer Island officials can prevent I-90 tolling is to expand the EIS to include the option of adding a 4^th lane to the outer roadway.  Doing so would immediately reduce cross-lake congestion in both directions.  Other posts (1/22/13, 4/18/13, 9/04/13, 9/10/13, 10/17/13) detail the advantages and funding benefits that could result from this approach.  All have been forwarded to “no tolls on I-90” and Mercer City Council.  Their “final scoping letter,” supposedly based on months of study and public inputs, fails to include this option.

Bel Red Noise Mitigation?

The 10/29/13 post commented on the lack of “progress” reports concerning WSDOT/Sound Transit tests confirming 4-car light rail train operation would be allowed on I-90 Bridge.  (East Link is the first light rail installation on a floating bridge.)  This post raises similar concerns about the lack of information concerning ST plans for the Bel Red area.

The Sound Transit staff has conducted several open houses dealing with the status of the Bel Red light rail stations at 120th and 130^th.  Their notification for “sharing design plans” for the Overlake Village and Overlake Transit Center stations later this month includes the following:

The Overlake segment open house gives future light rail riders, transit center users and community members the chance to look at design concepts and provide feedback on the Overlake light rail segment and stations.

Sound Transit appears to be well along with their plans for the Bel  Red light rail stations and willing to share those with the public.    They’re far less open with details of critical issues to light rail installation and operation there.  For example, what is the status of their plans for the maintenance facility that the Bellevue City Council and Bellevue Reporter initially opposed?   ST has apparently “persuaded” the Bellevue City Council (no surprise) to accept the facility there, but what are their plans for “visual screening and noise mitigation” of a potential “eye sore” in the midst of the development?    

The more difficult issue is what are ST plans for dealing with the noise from light rail trains trundling through the area every 4-10 minutes for 20 hours each day.  A March 2013 document “East Link Extension, 2013 SEPA Addendum” reflects their need to expand on the June 2011 Final Environmental Impact Statement concerning their approach to light rail noise along the route into Bellevue and through the city center.

The addendum details how property acquisition will displace large numbers of businesses and homes and that mitigation will be required to avoid excessive noise for 400 noise “receptors”.   The mitigation will involve “trenching” part of the route and installing “noise walls” up to 18 feet above retaining walls along the remainder.   In some instances they will consider “insulating” houses along the route “allowing” them to shorten noise walls. 

In any case its clear ST considers light rail noise a serious issue. 

The noise envelope for the elevated tracks along major sections in the Bel Red area would seem to be a far more serious concern than for at-grade tracks along the route into Bellevue.  Central Link experience has also shown relatively small radius turns along the elevated Bel Red route can be particularly “noisy”. One would think ST would consider plans for noise mitigation to be at least as important as the final details for station design. However, the SEPA addendum makes no mention of any plans for mitigation and there has been no indication of any upcoming public presentations on the issue.  It’s just the latest example of ST’s misplaced priorities.

What’s absurd is noise mitigation wouldn’t even be an issue if ST had ever considered a “South Lake Union” type of streetcar system for Bel Red.   It would have been far less noisy, more accessible, less costly, and more esthetically appealing than any light rail system (see 7/26/12 post).   Of course all of the noise walls and trench on the route into Bellevue would not have been needed with BRT.   Sooner or later everyone is going to recognize that not only East Link, but the entire Prop 1 light rail extensions are an “unmitigated” disaster.  This blog is my attempt to make it “sooner”.

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