Sound Transit/Bellevue East Link MOU "Deficiencies?

The 4/17/15 email notification announcing access to the ST/BCC East Link MOU is another example of the two organizations providing public access to a critical agreement when it’s far too late to comment or do anything about it.   The current MOU has what can only charitably be called “deficiencies”.

The most immediate “deficiency” is covered in Section 23.0 PERMITTING, PROJECT CERTAINTY, AND MITIGATION where paragraph 23.4 South Bellevue Park-and-Ride Closure, includes the following:

At least 60 days prior to the closure Sound Transit will identify and implement alternate parking and transit access for the commuters who utilize the existing park and ride in consultation with the Transportation Department Director and King County Metro.

Anyone who viewed the Feb 9^th Sound Transit presentation to the Bellevue City Council for accommodating those who used the South Bellevue P&R would have concluded they don’t have a clue as to how to accommodate those commuters.  They still haven’t responded to the council’s request for “clarification”.   The idea the council would agree to an MOU that allows ST to wait until just 60 days before they close the P&R to provide an alternative that is “unlikely” to have the needed parking capacity or bus access is a sure indication they either don’t understand the problem or don’t care. 

Another likely MOU “deficiency” is the following statements in Paragraph 23.1 “Noise”

At least 6 months prior to commencing vehicle testing and system start-up, Sound Transit shall submit for approval by the Director of the Development Services Department (“DSD”), a 3-year noise and vibration monitoring program for the Project to confirm that operating light rail train noise levels meet FTA ROD criteria and DMP requirements applicable at the time of DMP approval.

The problem with this “understanding” is the FTA Record of Decision is based on the East Link Supplemental Draft Environmental Impact Statement (SDEIS) which claimed light rail noise would not impact noise levels in the park nor substantially affect park use, the park’s features, activities, and attributes, or diminish the park’s value. 

   

The fact ST found it necessary to shield properties across a major roadway and hundreds of feet away from the tracks “suggests” any meaningful FTA noise measurements in the park will exceed the “de minimis” level required by federal law. 

The MOU includes the following “remedy” for the excess noise

If measured levels show that noise or vibration attributable to the Project exceed FTA criteria or DMP requirements applicable at the time of DMP approval, and track or light rail vehicle modifications are not sufficient to bring the Project within compliance, Sound Transit shall submit a mitigation plan within 60 days with appropriate reasonable mitigation for approval by the Director of DSD to achieve compliance.

At that point it’s “unlikely” ST will agree to add all the noise barriers needed to protect the Mercer Slough, essentially ignoring the MOU and initiate light rail service that will end forever the quiet solitude of the park.

The biggest “deficiency” by far is the MOU failure to include any “understanding” as to how East Link will meet its main objective; namely cross-lake transit requirements.  The ST 2008 DEIS promised capacity of up to 24,000 riders per hour (rph).  Later they promised 50,000 daily riders by 2030.  Their Integrated Transit Service requires all I-90 transit riders to switch from buses to light rail at either the South Bellevue or Mercer Island light rail stations. 

Yet the MOU makes no mention of East Link capacity, the number of light rail trains per hour, or the number of light rail cars in each train; critical data for any transportation system.  ST has indicated in other documents East Link will provide one 4-car train every 8 minutes.  However, that schedule doesn’t provide promised capacity.   Even worse that schedule may not be achievable because of floating bridge/light rail compatibility structural concerns. (East Link is first attempt to install light rail on floating bridge)

ST chose to demonstrate their 1-90 bridge design could accommodate light rail using 2 car trains.  The fact ST had still not finalized the design at the Feb 9^th review may reflect FHA concerns as to whether it can withstand the loads from 4-car trains.   Any operating limits imposed by structural concerns will further degrade capacity.

In conclusion, the council’s MOU agreement with ST does very little to resolve East Link problems.