UBET Comments on West Davis Corridor EIS—Purpose and Need

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  • June 07, 2010

June 7, 2010 |


We are submitting these comments on the Purpose and Need Chapter of the West Davis
Corridor Environmental Impact Statement. These brief comments are based on planning principles and objectives that are currently being used to create long term viability and livability of communities and metropolitan areas by creating a better balance in mode share for future travel demand thereby reducing the rate of growth of vehicle miles traveled.

In particular, we support the Balanced Transportation, Principle of Agreement #4, in the Mountain View Vision Voluntary Agreement. This agreement was signed March 10, 2004 by the stakeholders convened to participate in the Mountain View Corridor Growth Choices study that was making recommendations for the Salt Lake County portion of the proposed “Legacy Highway” that is also part of the West Davis Corridor planning background.

Balanced Transportation 
We desire a balanced transportation system for our future that will involve more transportation choices. The phasing and implementation of transportation investments over the next decade will affect land use development patterns and therefore affect future travel needs and the availability and effectiveness of other viable transportation choices. The sequencing of transportation investments needs to be studied to recommend the most effective and cost efficient way to meet future travel needs, reduce the rate of growth of vehicle miles traveled, improve air quality through a better balance between auto, transit, walk and bike trips, and to recommend the best way to encourage the types of land uses throughout the corridor that will support these improvements. ” (Mountain View Vision Voluntary Agreement, March 2004)

These planning objectives are also included in the Wasatch Choices 2040: A Four County Land-Use and Transportation Vision in its Relevant Principle: Provide Regional Mobility through a Variety of Interconnected Transportation Choices. Two actions stand out:1. Develop a balanced, multi-modal transportation system, and, 2. Support actions that reduce growth in per capita vehicle miles of travel. The linkage of land-use development patterns supported by alternative modes of transportation (transit, bike, walk) is of course key to making the system work.

Accommodation of VMT Predictions versus Reduction of VMT Demand 
The past 50 or more years of surface transportation planning in the US has focused on accommodating the automobile as the preeminent way we move around, even in cities. Highways were not built to cities, like in Europe, but through cities. The measure was car through-put above all else. Constraints such as air quality, and carrying capacity of highways leading to interchanges or intersections, make a more balanced transportation system an essential component of our long term viability as a region.

Focusing our investments in ways to stimulate a better balanced mode share between single occupant cars, carpooling, transit, bike and walk trips will benefit us all.

A certain level of automobile congestion is inevitable at the peak travel hours in vibrant metropolitan regions around the world. Even in Salt Lake County with our 10-12 lane freeway we have morning and afternoon congestion. It’s just part of the physics of supply, demand and traffic. The most effective way to keep peak hour congestion at tolerable levels is to offer convenient travel options to the single occupant automobile.

Air Quality
The Wasatch Front has a particular air quality challenge in its geography and climate. With high pressure zones concentrating over our mountain valley we are particularly vulnerable to high levels of air pollution both summer and winter. The January 11, 2010 Salt Lake Tribune headline, “Northern Utah Air Worst in Nation” did not help our individual health nor our future economy. Even with improvements in automobile technology the VMT growth predicted to be accommodated with new highways could well wipe out the benefits of automobile improvements. The Environmental Protection Agency has determined that Davis County is at risk for violating the National Ambient Air Quality Standards for PM 2.5 and Ozone.

Our transition to a more balanced transportation system is based on the recognition that we don’t want to grow up to be Los Angeles.  The transit investments we have made along in the Wasatch Front in the past ten years should be optimized by providing connections and convenience for its use, especially at the peak hours. The need in Davis County should focus on east/west travel to provide efficient access and connections to the north/south transit system that we have developed and will continue to expand.

As energy costs increase, and air quality concerns grow, bicycle trips linked to transit become a more viable alternative for some. Every enhancement for these trips should be given top priority as behavior will follow infrastructure investment. If we build more highways, we will increase traffic. If we build bike paths and convenient, affordable transit, we will increase transit mode share.

Vehicle Delay
The graphs presented in the Purpose and Need Chapter aggregate individual delay in an attempt to dramatize the overall time and cost delay of congestion suggesting that our ideal would be free flow traffic even at peak travel times. In the Responses to Questions from the 5/19/2010 Stakeholder Working Group meeting information on the delay per vehicle does not add value in showing the need for the project, it is not included in the analysis.” Only when the User Delay is aggregated based on increased population and automobile use that shows a 140 percent increase or a computer prediction of an increase of 269 percent in Lane Miles Congested from 2009 to 2040 are the graphs used. Individual measures displayed might draw one to a different conclusion and better illuminate the outcomes from new road construction versus transit improvements.

The wetland systems of Great Salt Lake are of vital importance to millions of migratory birds. The Great Salt Lake has been designated a Western Hemisphere Shorebird Network (WHSRN) site for its critical breeding and staging habitat for 5-7 million shorebirds each year. The Great Salt Lake wetlands are also utilized by 3 million ducks along with hundreds of wintering American Bald Eagles. The Great Salt Lake wetlands have provided a reliable and unique habitat oasis in the Great Basin desert for tens of thousands of years. Much of this system has been lost to development. It is essential that care is given to prevent additional loss of critical habitat.

Efforts to maximize a strategy that provides more transit connections to Frontrunner commuter rail, improves bike/pedestrian friendly development, and shifts focus to reducing the growth of vehicle miles traveled will be essential in order to avoid the loss of Great Salt Lake wetlands. The Great Salt Lake wetlands are under the jurisdiction of section 404 of the Clean Water Act and are adjacent Section 10 waters of the Rivers and Harbors Act.

In conclusion, we urge you to establish the Purpose and Need of this EIS as creating a better balance in mode share for future travel demand and to reduce the rate of growth of vehicle miles traveled to insure that our transportation infrastructure will support better air quality, lower automobile congestion and reduce energy consumption.


Marc Heileson
Sierra Club Western Regional Representative
2159 South 700 East Ste. 210
Salt Lake City, Utah 84106
(801) 467-9294

Roger Borgenicht
Co-Chair Utahns for Better Transportation
218 East 500 South
Salt Lake City, Utah 84111
(801) 355-7085

Lynn deFreitas
Executive Director
FRIENDS of Great Salt Lake
PO Box 2655
Salt Lake City, Utah 84110-2655
(801) 583-5593

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