Monday, December 16, 2013

Great letter re: Bridgeasaurus Boondogglus

 If the Bridgeasaurus Boondogglus "Oversight Team" weren't doing so much dealing from the bottom of the deck, these kinds of comments would not be necessary, but thank goodness someone submitted them. The "Oversight Team" should be focused on ensuring that the "Edifice Complex" doesn't result in a gargantuan waste of resources in the name of a passing auto-dominated era, instead of being focused on how to package and sell a still-evolving proposal that's typical of the worst thinking of that era. But the Oversight Team was and remains stacked with unabashed Bridgasaurus boosters, pols who are firmly committed to a retrograde vision of more auto infrastructure (more is better).
*Comments to Oversight Team on the Salem Alternative for the Salem River Crossing *

I urge the Oversight Team to keep in mind the Purpose and Need for the DEIS that you have developed.In summary, the project will attempt to reduce congestion levels at the existing bridgeheads and remediate safety and operational deficiencies in the existing bridges and in the
study area (DEIS, ES-2). The federal regulations point out that the focus of the alternatives analysis in the EIS is "to serve as the means of assessing the environmental impact of proposed agency actions, rather than justifying decisions already made" (40 CRF Sec. 1502.2(g)). The purpose of this expensive study process is NOT to justify building a new bridge over the river on the outskirts of Salem.As the Federal Highway Administration points out:

"The decision-making process should first consider those alternatives which meet the purpose and need for the project at an acceptable cost and level of environmental impact relative to the benefits which will be derived from the project" (U.S. FHWA memorandum, 9/18/90).

Please consider the following comments and observations as you continue to review the alternatives in the Salem River Crossing DEIS:

*1.**The Oversight Team must do a thorough traffic comparison of the Salem Alternative with all of the other alternatives in the DEIS.*

The information available to date on the new Salem Alternative does not adequately compare the new hybrid alternative with other reasonable alternatives in the DEIS. The information available from the Oversight Team's October meeting compares the Salem alternative only with alternative 4D and a "no build" alternative. That is not consistent with NEPA requirements.

The Salem Alternative was proposed by the Salem City Council as an alternative to Alternative 4D, which was recommended by the Oversight Committee.Alternative 4D was never selected as the"preferred alternative." That process requires the concurrence of the cities of Salem and Keizer, Polk and Marion Counties, SKATS MPO and ODOT.Then FHWA ultimately selects the preferred alternative.That process has not yet happened.

Therefore, in order to determine if the Salem Alternative is truly the best alternative, it must go through the same process as the other alternatives in the DEIS. The alternatives analysis is the heart of the environmental impact statement.It should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public (40 CFR, Sec. 1502.14).

The Oversight Team is required to "rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated."

Before you make a new recommendation to the decision makers,the Salem Alternative must go through the same analysis as the prior recommendation did.If the other alternatives are being discarded, you should explain why.For example, the hand out from the November Oversight
Team Meeting contained traffic comparisons of the Salem Alternative with Alternative 4D and the No Build Alternative but none of the other alternatives...

...It is clear that the biggest impact of the Salem Alternative is the increase in congestion for several intersections in north Salem. Liberty and Pine, Liberty and Hickoryand Commercial and Pine do not benefit from the Salem Alternative.(The numbers for Commercial St. and Hickory Street are somewhat of an anomaly it appears.)Traffic between downtown Salem and Keizer would suffer. In addition, for the most part the Salem Alternative increases congestion at the Commercial/ Marion and Marion/Liberty Street intersections as compared to Alternative 2A.

2.***The Oversight Team should be sure that the traffic study done for the Salem Alternative uses the same assumptions that were usedto analyze all of the DEIS alternatives.*

The traffic analysis for all of the alternatives needs to take into account current data reflecting travel behaviors.Traffic levels are already well below the estimate in the DEIS.Studies find that Americans
continue to drive less than they did several years ago, and it is not related to the recession.(See Statesman Journal article, December 5, 2013.)

3.*The Salem Alternative is clearly not designed to be an "expressway" as was anticipated by the Keizer city council.*

Expressways do not have bicycle/pedestrian facilities, and the v/c ratio for Salem should be .85 or less, according to the Oregon Highway Plan. Keizer's interest in a free-flowing thoroughfare from I-5 and Keizer Station to Polk County would be thwarted by the number of on-grade intersections proposed in the Salem Alternative.From what I can tell from the drawings and description, twonew intersections on the east side of the river and six on the west side would slow traffic considerably. At
least some of those intersections presumably would have traffic lights.The Oversight Team must compare the travel times of the Salem Alternative with the other alternatives, as done in Table 3.1- 35 in the DEIS.

4.***The true cost of the Salem Alternative should take into account the cost of a new interchange on Highway 22.*

The proposed Salem Alternative eliminates the west bound access to Rosemont in West Salem.That traffic is supposed to use Wallace Road or Edgewater, decreasing the usefulness of the new facility for those residents headed for the west end of West Salem. The Salem Alternative requires another new, expensive project to fix that access problem, and kicks the can down the road for many West Salem residents.

5.***The Salem Alternative will require goal exceptions on the west side, and maybe an extension of the urban growth boundary.*

Those exceptions will be difficult to justify when some of the alternatives, particularly 2A, are reasonable and do not require any exceptions.Any analysis needs to evaluate minor revisions to 2A that do not require exceptions.There may be refinements to 2A that would reduce congestion (such as the full extension of Marine Drive,further reduction of private access onto Wallace Road[1] , and signage to channel traffic into the correct lanes before getting on the bridge from the east.) Other refinements would include retro-fitting to make the existing bridges more earthquake proof; and emergency vehicle access to the bicycle/pedestrian bridge from the west.
6.***The Oversight Team should urge that Salem move forward with the construction of Marine Drive, which is already in the Salem Area TSP.*

That project can be built independently of any alternative in the DEIS.Marine Drive would take a considerable amount of pressure off of Wallace Road, which would greatly relieve the back up onto Marion Street Bridge.Salem could re-evaluate the congestion at the bridge heads after
the new Marine Drive is built to see if a new, expensive bridge can still be justified.

Thank you for your consideration.

Kathy Lincoln

 [1]  I recently counted 8 private approaches on to Wallace Road on *each *side of the road,between Edgewater and Glen Creek. Many businesses have more than one driveway to Wallace Road and also have alternative access to the side or rear of the property. Closing those accesses would go a long way toward alleviating congestion on Wallace Road.