Seattle’s World-Class Congestion

The February 21^st Seattle Times article about Seattle metro area congestion ranking 20^th in the world and between 4^th and 10^th in the United States is no surprise to the area’s commuters.  What will be a “surprise” is the fact their recent ST3 approval giving Sound Transit the authority to spend $54 billion over the next 25 years will do little to reduce congestion along I-5 or I-90.  And that the WSDOT attempts to use HOT lanes to “manage congestion” on I-405 will only increase congestion for those using GP lanes.  .

The vast majority of ST3 funds will be used to create a light rail “spine” between Everett and Tacoma along I-5 and between Redmond and Seattle along I-90.  Unfortunately Sound Transit chose to route the spine through the Downtown Seattle Transit Tunnel (DSTT).  The Puget Sound Regional Council (PSRC) concluded in 2004 the DSTT limited light rail capacity to 8880 riders per hour in each direction.  The did so on the assumption that the DSTT station lengths limited light rail trains to 4 cars, that safe operation required 4 minutes between trains, and that each 74 seat car could accommodate an average of 148 riders. 

One can haggle over train frequency and car capacity but whatever the result, light rail through the DSTT will never have capacity needed.  The fact the Tacoma and Redmond spines have to share this limited capacity exacerbates the problem.  ST3 funding will increase I-90 bridge congestion due to light rail confiscation of center roadway and the WSDOT failure to demonstrate FHWA was wrong to claim center roadway lanes were still needed with R-8A lane added to outer roadways.

Worse, Sound Transit doesn’t commit to adding the P&R stalls and connecting bus routes to use its limited capacity, apparently assuming large numbers of commuters will chose to live within walking distance of light rail stations.  Without the added P&R stalls and connecting bus routes the light-rail-spine trains will likely be used to replace transit buses having minimal effect on I-5 and I-90 congestion.  Even with the added parking the light rail spine will fail any rational cost/benefit analysis due to cost of light rail construction and light rail car operating costs

Seattle congestion could benefit from ST3 funding with light rail extensions to Ballard and West Seattle, the “likely” reason for the 70% Seattle voter approval critical to its passage.  The relatively short route lengths will minimize construction and operating costs.  The lower costs combined with the number of commuters within walking distance of light rail stations dramatically improve any cost/benefit assessment.  Yet Sound Transit delays the two extensions that will benefit Seattle residents for 20 years. 

Most commuters along I-405 face ever increasing congestion because the WSDOT has concluded the way to “manage congestion” is to make it more difficult for carpoolers to use HOV lanes and for those unwilling or unable to carpool pay a HOT fee to use HOV lanes.  They chose to initiate HOT on the HOV lane between Lynnwood and Bothell despite the fact the PSRC had concluded the delays there were minimal. 

Between Bothell and Bellevue they used a new lane for HOT rather than GP use without ever demonstrating the ability of the added lane to reduce GP congestion.  Even worse the WSDOT plans to use added lanes between Lynnwood and Bothell, and Bellevue and Renton for HOT.  WSDOT proposals to “manage congestion” by limiting two of four roadway lanes to +3HOV and those willing to pay tolls will only increase current congestion and future growth will surely exacerbate.  They already have plans for HOT on the I-90 bridge as the way to “manage congestion” when the bridge center roadway is closed this summer.

The bottom line is the Seattle area’s ranking as a “world class city for congestion” is only going to “improve” if Sound Transit and WSDOT continue as planned.

MI Should Demand SOV Access Lane on ICW Onramp.

The Bellevue Patch article concerning Sound Transit’s response to Mercer Island’s intent to sue over SOV access to westbound I-90 via Island Crest Way typifies Sound Transit’s approach to “disputes” claiming: 

"It is highly regrettable that the City of Mercer Island is now attempting to delay the project in mid-construction," Rogoff said in a statement released Tuesday. "Neither the Washington State Department of Transportation nor Sound Transit are empowered to reverse the Federal Highway Administration’s decisions regarding access by single-occupant Mercer Island traffic to the new HOV lanes across Lake Washington."

Sound Transit justified their claim with the following

"In 2004 all of the parties to the 1976 agreement and Sound Transit signed an amendment establishing plans for constructing high capacity transit in the center lanes," Sound Transit said in a statement. "That conversion was stipulated to occur following the addition of one new HOV lane in each direction to the outer roadways. The 2004 amendment did not identify Mercer Island SOV access to the new HOV lanes as a project component, but instead provided that transportation studies would be used to determine if the changes to I-90 would cause a loss of mobility to and from Mercer Island and that WSDOT satisfactorily address any such loss."

However Rogoff “neglected” to mention a 2006 letter from the Governor’s Office & WSDOT to MI reconfirmed MI residents should be permitted HOV access until converted to HOT.  That commitment was later reconfirmed in a 2007 letter.   It was not clear how the WSDOT intended to implement allowing MI SOV access to I-90 HOV lanes. The fact both letters preceded the 2008 East Link vote, when Sound Transit needed MI votes, “may” have influenced their “commitment”.  

Even after the vote Sound Transit’s 2011 East Link Final EIS “Confirmed that any changes to the HOV lane eligibility including MI SOV use, to be addressed in future analysis, approval or agreement”.  It’s “unfortunate” neither WSDOT, nor Sound Transit, nor MI bothered to check with the FHWA about SOV access to I-90 HOV until March 2016.  Mayor Bassett’s June presentation to the FHWA advocating for MI SOV resulted in an August FHWA response citing federal prohibition on SOV traffic for any part of the HOV ramps or lanes. 

The Patch article included Sound Transit’s response to their commitments of “future analysis, approval or agreement concerning MI SOV access to I-90 HOV lane”

 “Sound Transit says that it has tried to work with Mercer Island and WSDOT to determine if loss of SOV access will harm mobility on the island, taking into account that light rail would reduce traffic. 

It doesn’t take much “work” to determine loss of SOV access will “harm mobility on the island”.  MI isn’t even asking for HOV access on I-90 Bridge, only westbound access to I-90 via Island Crest Way for single-occupancy vehicles.   Sound Transit could have addressed that problem by doing what was necessary to add a controlled SOV lane to the ICW access.  They surely could have done so as part of adding the 4^th lanes to the outer bridge roadways.  Providing an additional controlled SOV onramp would ease MI central area access problems. (The reality is easier access to I-90 will inevitably still require MI commuters as well as all cross-lake commuters to choose between expensive HOT fees or heavy congestion on GP lanes.)

Instead Sound Transit makes the truly absurd argument “light rail would reduce traffic”.   They continue to ignore the fact their East Link extension website video depicts operation as “one three-or-four car every 8-10 minutes”, a fraction of what’s needed to meet current transit demand let alone future growth.  East Link trains will be full well before they even reach MI station during most of the commute.

The bottom line is MI should demand Sound Transit add the SOV lane to ICW access prior to allowing them to proceed with East Link.  The fact there seems to be some concern as to whether Sound Transits I-90 bridge design can accommodate light rail trains and outer roadway capacity may make any delay because of the added lane less "onerous".

Sound Transit’s Absurd Response to RCW Compliance Concerns

An earlier post included the following letter concerning Sound Transit’s “apparent” failure to comply with Revised Code of Washington (RCW) regarding planning for their light rail spine.

Dear Attorney General Ferguson,

The Revised Code of Washington RCW 81.104.100 details the code requirement for high capacity transit system planning.  RCW 81.104.00 (2) and section (b) are shown below:

(2) High capacity transportation system planning is the detailed evaluation of a range of high capacity transportation system options, including: Do nothing, low capital, and ranges of higher capital facilities.  High capacity transportation system planning shall proceed as follows:

(b) Development of options. Options to be studied shall be developed to ensure an appropriate range of technologies and service policies can be evaluated. A do-nothing option and a low capital option that maximizes the current system shall be developed. 

Sound Transit’s 2008 Draft Environment Impact Statement DEIS included a “no build” option for their East Link light rail proposal, presumably their response for a “Do nothing, low capital option”.  It included adding 4^th lanes to the I-90 Bridge outer roadways and maintaining current procedure, reversing the two center roadways for morning and afternoon commutes.  They apparently never considered initiating permanent inbound and outbound bus rapid transit (BRT) only lanes on the center roadway.  Doing so would have provided “low capital” cross-lake capacity far exceeding light rail.

There is also no indication Sound Transit ever considered BRT use of limited access HOV lanes along the I-5 corridor.  Again, an option that should have been considered as a “do nothing, low capital,” response to the RCW.  Especially in view of the Seattle Downtown Transit Tunnel limitations on light rail capacity.

Surely your office has a responsibility to require Sound Transit comply with the RCW.

The Attorney General’s Office response included the following:

We referred your complaint to the following agency. Please contact the identified agency directly with questions about the status of your complaint.  

Sound Transit Board of Directors

c/o Board Administrator

401 Jackson S

Seattle, WA 98104

I wasn't "surprised" Attorney General Ferguson refused to respond as he has done so earlier when I contacted his office regarding WSDOT lawyers claims about I-90 outer roadway capacity and light rail noise impact on Mercer Slough Park.  I was “surprised” Sound Transit chose to respond since they had  ignored countless emails concerning their “Prop 1 and Beyond” extensions.  Apparently the Attorney General’s letter “persuaded them’.  What was even more of a “surprise” was the below response (the italics are mine).

Dear Mr. Hirt,

Sound Transit is in receipt of a complaint you filed with the Attorney General’s office asserting that Sound Transit failed to comply with RCW 81.104.100 in the development of options for the 1-90 Project.

As you noted in your complaint, Chapter 81.104 RCW requires development of a high capacity transportation system plan, and RCW 81.104.100 specifically sets forth the requirements that must be included in that system-wide plan. Sound Transit developed draft and final system plans that complied with these requirements and included extensive public outreach from 2005 to 2008. Draft and final supplemental environmental impact statements (EISs) on the updated system-wide plan were prepared in 2004 and 2005 respectively. The decision to implement East Link light rail was made as part of Sound Transit 2 (ST2), the system plan that was adopted by the Sound Transit Board and authorized by voters in Sound Transit’s taxing district in 2008.

Project level reviews are not subject to the requirements in RCW 81.104.100. As noted in your complaint, the project level review of the East Link project did include a no-build option. Your presumption that this was due to the requirement in RCW 81.104.100(2)(b) is not correct. As indicated above, this statutory requirement applies to system-wide plans, not project level reviews.

HOV lanes on 1-90 were evaluated as part of the 1-90 Two-Way Transit and HOV project (also known as R8A]. This project is not a part of the East Link project. Draft and final EISs were prepared for the project in 2003 and 2004, respectively. Your assertion that Sound Transit’s failure to consider bus rapid transit (BRT) use of the center roadway failed to meet the statutory requirement outlined in 81.104.100(2](b) is misplaced. As noted above, the cited statute does not apply to project level reviews. In addition, the project did evaluate conversion of the center roadway to two-way bus and operation, among other alternatives. The project to build chosen by the Sound Transit Board for the project includes lanes on the outer roadways of and the work to add those lanes will be completed this year.  

Sincerely,

Amy Joe Pearsall
Senior Legal Counsel

Their response should not have been a “surprise", as it typifies the level of “competence” Sound Transit has shown over the last several years with their "Prop 1 and Beyond" light rail extensions as a way to deal with the area's transportation problems.  First of all my “complaint” concerned Sound Transit’s apparent failure to comply with the RCW planning requirements for the entire light rail spine.  There has never been any indication Sound Transit ever considered bus rapid transit (BRT) along a limited access HOV lane as a “low-cost” alternative to the Central Link extension now planned from Everett to Tacoma.  Money that could have been spent adding thousands of P&R stalls for access to BRT has instead been spent on light rail extensions whose capacity will be limited by the Downtown Seattle Transit Tunnel to a fraction of potential BRT capacity. 

Second the “legal council” neglected to refer to any documentation showing Sound Transit “complied with these (RCW) requirements” for planning for any of the light rail spine extensions that are presumably part of the "system wide" plan.  (What difference does it make as to how ”the decision to implement East Link light rail was made” if they ignored the RCW 81.04.100 planning requirements?)   Even more absurd, the “legal council” claims East Link is not required to meet RCW 81.104. 100(2)(b) since "this statutory requirement applies to system wide plans, not project level reviews".

 It’s not clear why East Link is a “Project Level” review rather than a “System Wide” project.  Also what is Sound Transit’s basis for claiming “Project Level reviews are not subject to RCW81.104.100(2)(b)".  If, as the letter claims, ”project did evaluate conversion of the center roadway to two-way bus”, why did they do so, and why wasn’t it considered as the “no build” option in the 2008 DEIS?

Again, the bottom line is the Sound Transit letter exemplifies their level of “competence” when it comes to dealing with the area’s transportation problems.  They simply ignore the fact they failed to comply with RCW on the light rail spine between Everett and Tacoma.  Maybe they considered it another “Project Level Review”.   Only a Dow Constantine led Sound Transit Board would claim East Link does not have to meet the RCW.  The entire area will pay a heavy price if they are allowed to continue.

P.S. 2/18/17

I decided to send the following to Attorney General Ferguson. I will post his response if he chooses to do so.

Dear Attorney General Ferguson,

As your office suggested the Sound Transit Lead Legal Council responded to my concerns about their apparent failure to comply with RCW 81.104.00 (2) (b) regarding planning for their light rail spine.  Does your office concur with the following response?

Project level reviews are not subject to the requirements in RCW 81.104.100. As noted in your complaint, the project level review of the East Link project did include a no-build option. Your presumption that this was due to the requirement in RCW 81.104.100(2)(b) is not correct. As indicated above, this statutory requirement applies to system-wide plans, not project level reviews.

Sincerely

Bill Hirt

WSDOT HOT “Managing Congestion” Absurdity

The February 5^th Seattle Times front-page article “Life in the Toll Lane” exemplifies the WSDOT failure to consider HOT “deficiencies”.   What began as a way to reduce travel times for all I-405 commuters, was later decreed “the only unallocated source of revenue generated in the state”.  Now, according to the article, the WSDOT changed its prime goal from "financing more road capacity to managing congestion”. 

It’s not clear what “managing congestion” means, but it’s clear spending $484 million to limit one of the three I-405 lanes between Lynnwood and Bothell, and two of the five lanes between Bothell and Bellevue, to +3 HOV and HOT fees has done little to reduce travel times for most commuters.  A PSRC, “Stuck in Traffic: 2015 Report” dealing with the area’s major roadway congestion showed I-405 had little if any delays until Bothell on the route from Lynnwood to Tukwila or after Bothell between Tukwila and Lynnwood.  Thus there was no need to restrict that portion of the route to +3HOV and HOT as a way to “manage congestion” (assuming doing so means reducing congestion).  And there is little indication it has. 

The more heavily congested Bothell-to-Bellevue portion benefitted from an additional lane in each direction over much of the route.  Rather than use it as an additional GP lane the WSDOT chose to use it as a second HOV lane, both with HOT and +3HOV.  They could have better “managed congestion” by temporarily allowing GP use of the existing lane and +2HOV on the new lanes to see the impact on velocities and commute times.   How much would GP lane velocities increase and how would that affect +2HOV lane velocities.    

The WSDOT could use the I-405 “Pilot Program” results to predict velocities with the single +2HOV or with a  single +3HOV and HOT lane along that portion of the route.  It provided them with all sorts of data as to how average lane velocities decrease with increasing number of vehicles and how HOT use and tolls increase as GP velocities decrease.  Not only could they predict what velocities would be today they could do so for commuters with the projected 800,000 added population.  There is little indication the WSDOT has done so and will likely never do so dooming I-405 commuters to a choice between Lynnwood and Bellevue of ever increasing GP lane delays and ever increasing HOT fees.  

Even more “dubious” is the WSDOT approach to “managing congestion” by planning to use two of the future four lanes from Bothell to Lynnwood and from Bellevue to Renton for +3HOV and HOT.   The PSRC report concluded the Bellevue to Renton portion of I-405 had the most delays; “likely” because there are only three lanes.  Common sense “managing congestion” would surely require the WSDOT estimate how many vehicles would be allowed on the two HOV lanes to meet the 45 mph goal and what the two GP lane velocities would be with the remaining vehicles with future traffic projections before embarking on an additional $1 billion for HOT. 

Instead the legislature’s only requirements for WSDOT doing so are the I-405 "Pilot Program" toll revenue exceeds operating costs and average velocity exceeds 45 mph 90% of the time. They claim the $16 million profit, triple "state predictions", and the anticipating $22 million this year shows, "They’re so popular”.  They ignore the “possibility” GP congestion forces them to do so. The fact that average tolls during the year increased from $1.75 to $2.99 “suggests” increased GP lane congestion will compel even more commuters pay higher tolls. The state commissioners’ decision not to raise the peak tolls this year to $15.00 apparently delays the inevitability that will likely make them “less popular”. 

The WSDOT (and Seattle Times) claims “success” because average velocities met the 45 mph requirement 89% of the time. They chose to average them over 8 hours and for the entire year.  A far more “meaningful” basis for proceeding would be requiring some percentage of commuters averaged 45 mph. The WSDOT should publish what that level was during the last quarter.  It’s likely far lower than 90% and will only decrease with future growth unless HOT fees increase substantially forcing more vehicles on GP lanes and more congestion.  I-405 commuters on GP and HOV lanes surely deserve to know what to expect.

The bottom line is the I-405 HOT Pilot Program has been a disaster for the vast majority of commuters that future traffic growth will only exacerbate.  It's absurd the WSDOT concludes the way to “manage congestion” is to limit two of the future four lanes between Lynnwood and Bothell and Bellevue to Renton to +3HOV and HOT.   Those leading the WSDOT and the House and Senate Transportation committee that don’t recognize that reality need to reconsider or be  replaced.

Use I-405 HOT “Pilot Program” Results to Demonstrate Absurdity of Extensions

The WSDOT attempt to portray the results of the $484 million they spent initiating HOT on I-405 between Lynnwood and Bellevue as a boon to commuters is only the beginning.  They’re reportedly already planning to spend another $1 Billion extending HOT to Renton. 

The whole idea that HOT can reduce congestion for everyone is mathematically absurd.    If everyone is allowed to use GP lanes on a five-lane freeway, each lane can nominally accommodate 20% of the vehicles.  If, to encourage transit and carpoolers, one of the lanes is restricted to HOV that attracts 12% of the drivers, the percentage using each of the four GP lanes increases to 22%.   Thus HOV lanes benefit at the expense of a 10% increase in GP lane congestion.

HOT was purportedly initiated as the way to increase HOV lane velocities in response to legislation requiring they maintain 45 mph for 90% of the time by reducing the number of vehicles on the lane.    If HOV lane velocity with 12% of the vehicles is less than 45 mph, the number of HOV vehicles must be reduced by requiring +3HOV and setting HOT fees sufficient to do so.  If, for example, doing so requires reducing HOV to 8%, GP lane velocities presumably far slower with 22% of traffic will be slowed further with 23% of traffic.

The WSDOT, presumably attempting to generate more revenue and the probability of very high tolls needed to achieve 45 mph with a single HOT lane, initiated HOT on two lanes between Bothell and Bellevue where congestion is heaviest.  If the 45 mph edict requires limiting the HOT lane to 8%, two lanes could accommodate 16% of riders with lower HOT fees for each lane.  However, that requires each of the remaining 3 GP lanes accommodate 28% of traffic, three and a half times the congestion for those paying the HOT fees.  It’s no wonder 32,000 commuters have signed on to the “no tolls on I-405” agenda.

All of the above discussion was predicated on an assumption as to the percentage of vehicles a lane can accommodate and still maintain the 45 mph.   What’s needed is how does the actual number of vehicles affect the lane average velocity.   The $484 million, 2 year, I-405 HOT “Pilot Program” provides all sorts of data as to how HOV and GP velocities decrease with increasing number of vehicles and how HOT lane use (and tolls) increase with slower GP lane velocities. 

They should use that data to predict how allowing GP use on one of the two HOT lanes would affect average velocities between Bothell and Bellevue assuming half the HOT traffic switched to GP lanes.  At least in theory, the remaining HOT lane velocities would not change.   The WSDOT could use their data to show how the increased GP velocity would affect the number of those willing to use HOT lane, what the tolls would be, and the resulting average HOT velocities.   Fewer HOT vehicles will increase HOT velocity and decrease GP velocity and vice versa.  Both GP and HOT I-405 commuters surely have the right to know what allowing GP use of one of the HOT lanes would affect their commute.

One way to increase HOV velocities without increasing tolls would be to add P&R stalls with access to 10 BRT routes an hour during the peak commute.   (Way beyond ST3) Allowing 1000 commuters an hour to pay bus fare rather than HOT fees (and the savings from leaving their car near where they live rather than where they work) would undoubtedly reduce the HOT tolls needed to maintain some average HOV velocity.   The WSDOT could use the I-405 pilot data to predict HOV lane velocities and HOT fees with the added BRT routes.  They could also use the data to predict how future growth will affect the velocities with one or two HOT lanes.

The WSDOT needs to do a similar analysis before they decide to spend $1 billion extending HOT to Renton and whatever it takes to implement HOT on the new lane between Bothell and Lynnwood.   Again assuming an HOT lane requires limiting HOT lanes to 8% of the traffic requires the two GP lanes accommodate 84% of vehicles.   Increasing HOT lane users to 10 or 12% of vehicles would reduce HOT lane velocities but still require around 80% of commuters to use the two GP lanes.  While the WSDOT could use the “Pilot Program” average velocity results to predict HOT and GP lane velocities with the various splits between the two, common sense would “suggest” the GP lane velocities would be a debacle.

Unfortunately Rep Clibborn, the chairwomen of the House Transportation Committee, shows very little “common sense” when she insists they proceed with implementing the two HOT lanes on both extensions as a way to provide “the only unallocated source of revenue generated in the state”.   I-405 commuters will pay a very heavy price if she is allowed to prevail.