Date: March 25, 2011
To: West Davis Corridor Environmental Impact Statement (EIS)
Re: Alternatives Advanced to the EIS
From: Sierra Club
Utahns for Better Transportation
FRIENDS of Great Salt Lake
Breathe Utah
These comments follow our submittal June 10, 2010 on the draft Purpose and Need Chapter and our submittal September 15, 2010 on Screening and Performance Criteria for the West Davis Corridor Environmental Impact Statement. In those comments we highlighted the need to follow the principles and objectives of the Wasatch Choices 2040: A Four County land-Use and Transportation Vision which was developed by elected officials, governmental agencies and private and nonprofit businesses and organizations to ensure that we will continue to “enjoy an unparalleled quality of life along the Wasatch Front" as our area grows in population.
Two of the key principles for transportation planning from that visioning effort are to:
“Develop a balanced multi-modal transportation system” and to
“Support actions that reduce growth in per capita vehicle miles of travel.”
We also highlighted 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)
The alternatives advanced to the to the Draft EIS must include a shared solution that will provide convenient travel alternatives for some of our trips (walk, bike, transit) that will reduce the rate of growth of vehicle miles travelled (VMT) especially at the peak hours of travel demand. incentives for alternatives to 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 reducing automobile congestion, improving air quality and supporting active life styles.
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.
Transit
Our transition to a more balanced transportation system depends on shared solutions to meeting the future mobility needs in our growing metropolitan area will require shared solutions. If we continue our past patterns of growth and behavior we will grow the vehicle miles we travel each day in our region even faster than our population growth. This is the prediction that we need to avoid if we are to maintain our high quality of life in this wonderful metropolitan area.
Transportation improvements in west Davis County should focus on a integrated, shared solution that seeks to provide viable choices in the way we take some of our trips. Convenient transit, safe bikeways, in addition to our roadway system can provide alternative ways of travel than always taking a car. A more balanced travel-mode-share especially at the peak travel hours would reduce congestion, improve air quality and provide many affordable, convenient and healthy travel.
The first piece of the proposed "Legacy Highway" through Weber, Davis, Sal Lake and Utah counties, the Legacy Parkway and Preserve, was an integrated, shared solution and indeed the courts found that the Final Environmental Impact Statement on the Legacy Parkway was inadequate because there was "failure to consider alternative sequencing of the Shared Solution; and, failure to consider integration of the Legacy Parkway and transit;"
The "Shared Solution" for the Legacy Parkway involved integration of our overall transportation system that was 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 convenient connections 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 FrontRunner commuter rail as well as the I-15 Freeway and other north/south roadways and trails
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.
Respectfully,
Roger Borgenicht
Co-Chair, Utahns for Better Transportation
218 East 500 South
Salt Lake City, Utah 84111
801 355-7085
[email protected]
Marc Heileson
Sierra Club Western Regional Representative
2159 South 700 East Ste. 210
Salt Lake City, Utah 84106
(801) 467-9294 (801) 467-9296 fax
[email protected]
Lynn deFreitas
Executive Director, FRIENDS of Great Salt Lake
PO Box 2655
Salt Lake City, 84110-2655
(801) 583-5593
[email protected]
Cameron Cova
Co-Chair, Breathe Utah
(801) 583-8563
[email protected]
