September 15, 2010 |
These comments follow our submittal June 10, 2010 on the draft Purpose and Need Chapter of the West Davis Corridor Environmental Impact Statement in which we stated that the principles and objectives of the Wasatch Choices 2040: A Four County land-Use and Transportation Vision should be used to develop and evaluate alternatives for transportation improvements in west Davis County. Two of the key principles for transportation planning from that effort are to:
“Develop a balanced multi-modal transportation system” and to
“Support actions that reduce growth in per capita vehicle miles of travel.”
Growth Principles and Implementation Strategies
Wasatch Choices 2040 was a planning effort in 2005 involving public, private and community stakeholders that identified growth principles and implementation strategies based on integrated land-use/transportation planning. In the Wasatch Choices 2040 process four scenarios were developed to define the configuration and measure the performance of various approaches to growth. The report outlined lessons learned from the scenarios such as:
Mixed-use development reduces driving distances and congestion.
Growth near transit opportunities encourages people to ride transit.
People will walk and bike if the trip is short and the design is right.
Transportation choices help determine where growth will occur.
Transit is a key means to reduce congestion during the all-important rush hour.
We also highlight the Balanced Transportation, Principle of Agreement #4, in theMountain 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.
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)
We support performance and screening criteria that measure and support a better balanced mode share split between transit, walk/bike and automobile trips especially at the AM and PM peaks when road and intersection capacity is challenged by automobile demand. To reduce automobile congestion, improve air quality and provide more viable mobility choices for Davis County residents we should utilize performance criteria that optimize access to I-15 and FrontRunner commuter rail as the main north-south facilities for needed transit or automobile trips. 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 by implementing shared solutions to future mobility needs.
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.
Alternative Alignments – Wetlands
As stated in our previous comments, the wetland systems of Great Salt Lake are of vital importance to millions of migratory birds. The Great Salt Lake has been designated as 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 for migratory birds. It is by far, not an ordinary wetland issue. Impacts to this system will have negative repercussions to wildlife across the western hemisphere and “avoidance of wetland impacts” must take highest priority. The wetlands of the Great Salt Lake are under jurisdiction of section 404 of the US Clean Water Act which requires this avoidance first policy.
For example, the Weber County and northern Davis County section of the study area, the variations of the “G” and the “A” alternative alignments all pose direct impacts to the wetland ecosystem of the Great Salt Lake. Whereas, the more eastern alternative alignments better avoid this critical wetlands system. This in turn, greatly increases the likelihood that the western alignments will be unpermittable under section 404 of the Clean Water Act.
In addition, the alternative alignments north of 4000 South near the Davis/Weber border to 12th South in Ogden all pose major impacts to valuable wetland and upland habitats critical for wildlife. We believe that demand in this area is unripe and the need for any facility at this time is questionable. A premature facility in this area will instead result in “inducing demand” for increased automobile travel by enticing sprawling automobile-dependant development. These alignments should be removed from consideration at this time from this EIS process.
The alternative alignments “A-1” and “B-1” in western Farmington south of alignment “E-1” greatly and unnecessarily impact the wetlands of Farmington Bay when there are other connections to I-15 and Legacy Parkway that avoid this wetland system. They should also be promptly dropped from consideration.
Alignment land purchasing before the proper NEPA process completed
We have great concern that there may be possible bias in the alternative analysis resulting from premature land purchasing by the state of a single alternative. Utah state entities have already begun purchasing land for a particular alignment in this study before the EIS process had begun. This alignment also poses major impacts to the wetlands of the Great Salt Lake. We fear that this committing of public resources to a single alternative may inject bias to the proper balancing of consideration of other alignments or transit alternatives.
Co-Chair, Utahns for Better Transportation
218 East 500 South
Salt Lake City, Utah 84111
Sierra Club Western Regional Representative
2159 South 700 East Ste. 210
Salt Lake City, Utah 84106
(801) 467-9294 (801) 467-9296 fax
Executive Director, FRIENDS of Great Salt Lake
PO Box 2655
Salt Lake City, 84110-2655