Slog

For years now, the national Sierra Club has been shorthand for mainstream, yuppie, Utne Reader environmentalism. But our local chapter—man oh man. Make. It. Plain, brothers and sisters. From lobbying hard for real CO2 cap legislation in Olympia to their early support for the surface/transit option on the waterfront, our local club, the Cascade Chapter, is the real deal.

Case in point: late last week, they wrote a letter about the grating Utne Reader compromise joint ballot title for light rail and roads.

I’ve attached the entire letter below. Here’s a snippet:

Sierra Club support for the ballot measure would require fundamental changes to the project list as well as legislative changes to restructure RTID objectives. Given the inherent structural defects in RTID and adverse environmental impacts of certain projects, we do not believe that a joint ballot can gain our support. Therefore, the Sierra Club adopts the position that Sound Transit be allowed to proceed to the November 2007 ballot separately.

Shawn Bunney, Chair of Executive Board John Ladenburg, Board Chair
Regional Transportation Investment District Sound Transit
411 University St., Suite 1200 401 South Jackson Street
Seattle, WA 98101 Seattle, WA 98104

Dear Councilmember Bunney and Executive Ladenburg:

The Sierra Club is providing comments on the joint Roads & Transit investment package proposed by the Regional Transportation Investment District (RTID) and Sound Transit (ST). We evaluate and comment on the proposals of the two regional agencies together since they are being presented to the public as a regional transportation plan, and the vote is presently structured to produce an all up or down outcome. We sense--as others in the region do--the need to address transportation planning and investments in a comprehensive and holistic manner.

We first summarize the Club’s position on the joint ballot proposal. The important criteria by which the Sierra Club evaluates the transportation projects is described, followed by specific assessments of the RTID projects, and then the ST Phase 2 projects. We offer recommendations for alternative projects, and suggest alternative ways of structuring a regional transportation plan.

Summary of Sierra Club Position
Sierra Club support for the ballot measure would require fundamental changes to the project list as well as legislative changes to restructure RTID objectives. Given the inherent structural defects in RTID and adverse environmental impacts of certain projects, we do not believe that a joint ballot can gain our support. Therefore, the Sierra Club adopts the position that Sound Transit be allowed to proceed to the November 2007 ballot separately. The Sierra Club could also support a separate roads funding package, whether financed directly by the Legislature or placed on the ballot, so long as the projects meet certain key criteria.

Club Principles Guide Evaluation Criteria
Emissions of greenhouse gases (GHG) from the transportation sector account for about 51% of all such emissions in the Puget Sound region (2002 data). The impact of these emissions for climate change as documented by the Intergovernmental Panel on Climate Change (IPCC) and the potential effects this can cause in the region and throughout the world prompt the Sierra Club to prioritize reduction of GHG emissions to protect our climate and the many processes and human systems that depend on it. We must be serious about reducing GHG emissions from the transportation sector given the majority share it contributes within the central Puget Sound region.

Sierra Club calls for systematic GHG emission estimates to accompany all evaluations of specific transportation projects and regional transportation plans. The region needs to prioritize the avoidance and reduction of GHG emissions so we can reduce the environmental impacts from chosen actions, especially transportation projects. Based on the immediate need to address climate change impacts and our transportation principles, the Sierra Club is using the following set of criteria to evaluate the proposed investments in the Roads & Transit plan.
• Cost-effective mobility which emphasizes moving people and goods in a well-connected and maintained multi-modal system;
• Tangible reduction in GHG emissions, other environmental effects, and improvement in human health and safety;
• Better integrated regional transportation and land use planning, and transportation investments that support smart land use and minimize or prevent additional sprawl;
• Preserve fiscal resources that allow local jurisdictions to fund transit, sidewalks, bike paths, maintenance projects, and local arterial improvement projects.

We see the reduction of GHG emissions and related environmental and health impacts as paramount in the selection of specific transportation investments. Prioritizing the movement of people and goods to maximize the productivity of our transportation system is nearly as important an evaluation factor that we consider.

RTID Policy and Program Need Revision
We identify some fundamental problems with RTID and seek changes in its objectives, the way it approaches its mission, and the principal source of revenue used to fund the road projects. RTID not only needs to evaluate the environmental impacts of its projects but adjust the selection to reduce GHG emissions and other environmental effects. The present approach does not appear to consider the system-wide effects but instead has us dig ourselves even deeper into a climate impact hole.

RTID investments should improve transit service reliability and improve mobility for people and goods, rather than focusing on movement of vehicles. The improvements to interchanges and corridors must support land use plans that encourage compact, walkable communities, not promote further sprawl development that pushes auto-dependent sub-divisions to the edge of the urban growth boundary. Freight mobility should not be used as a justification for more highway lanes when other options, such as rail, exist. A Legislative fix is needed to change the emphasis that directs 90% of funding to highways of state-wide significance, so arterials can receive more funding.

The financing of RTID highway projects should originate from user sources, related as directly as possible to the rate of use of the road network, and resulting environmental and infrastructure burden. This means no general sales tax monies for roads, and preferably no MVET either. Local option gasoline tax, sales tax on gasoline, sales tax surcharge on auto parts, and vehicle weight-based fees are more appropriate revenue sources since they apply to one’s use of the road system. Furthermore, the Sierra Club urges that RTID adopt a policy of no unpriced, new general-purpose lanes on limited-access highways anywhere in the Puget Sound urban area. Additionally, the RTID should provide the mechanism to introduce dynamic tolling (i.e., congestion pricing) of all, including existing, limited-access highways in the region. Taxes based on GHG emission levels would also be appropriate to align market forces with the region’s need to reduce our climate impacts.

RTID Project Assessment Identifies Good and Bad
Using the evaluation criteria described above, the Sierra Club assessed the proposed projects in the RTID funding package. We have classified the projects into four broad categories of acceptability that indicate whether we feel each project is worthy of inclusion in the investment plan. The best projects, which should serve as a guide for selection of other projects, are presented in Table 1 below.

The next tier of projects we judged to be marginally acceptable, but they are not particularly good to use as models for additional projects. The reduction of interchange and intersection chokepoints we generally regard as favorable, but we question whether these investments continue to be worthwhile if dynamic tolling is used on the limited access highways. Table 2 lists the satisfactory projects.
Table 1. Good Projects – More should be like these.
Project Evaluation Comments
I-5 Transit Direct Access Ramps at S. Industrial Way Builds on existing transit investments in S. King, Pierce
SR 99 North Bus Rapid Transit improvements in Shoreline Completes BRT corridor and complements Snoh. project
South Park bridge replacement Safety & maintenance; arterial
I-5/ Spokane St. Viaduct and Lander St. Improvements Safety & maintenance; arterial flow helps transit
Snohomish Co. Transit Improvements Multi-modal; local needs
I-405 from SR-520 to Downtown Bellevue only (braided ramp to eliminate weave) Safety; eliminate bottleneck so existing lanes work better
I-5 Approach Mercer Street Widening Safety; support local land use
Snohomish Co. Local Arterials (non-HSS) Arterial; fills in street grid

Table 2. Satisfactory but not Exemplary Projects
Project Evaluation Comments
I-5/ 38th Street Ramp Tacoma Mall Helps local access
SR 167/I-405 Interchange HOV to HOV Direct Connection HOV incentive; may increase VMT & GHG emissions
Snohomish Co. I-5 corridor HOV and interchange reconstruction Helps local access; may increase VMT & GHGs
SR 167 Green River Valley Corridor Congestion Relief, Complete HOV System Auxiliary Lanes HOV incentive; may increase VMT & GHG emissions
Snohomish Co. East-West Arterial Widening with Bike and Pedestrian Amenities Safety & multi-modal; may promote increased sprawl

In Table 3, we list projects that cause us greater concern due to their impacts on carbon emissions and potential for promoting sprawl.

Table 3. Concern with Design and/or Expense of Project
Project Evaluation Comments
SR-9 Widening with Transit Amenities Safety vs. GHG & sprawl
SR 520 Bridge HOV lanes, safety shoulders, bike-lane Fund basic 4 lanes first; big $s
I-5 & SR 18 Interchange (Federal Way) Safety vs. GHG & added VMT
US-2 Trestle & SR-204/Everett Arterial Access; Monroe bypass Safety vs. GHG & added VMT; transit impact unclear
SR 162 Widening and Interchange Reconstruction Arterials vs. GHG & sprawl

Finally, in Table 4, we list projects that we judge should be eliminated from the RTID plan. The scope and specific elements of these highways make it very unlikely that any revisions could modify the project sufficiently to win our favor.

Table 4. Bad Projects Viewed as Package “Poison Pills”
Project Evaluation Comments
I-5/ SR 509 Corridor Completion Tolling; sprawl; no transit +
I-405 Corridor Bellevue to Renton added lanes Tolling; GHG & VMT; big $s
SR 167 Port of Tacoma Freeway extension Tolling; sprawl/wetland; big $s
SR 704 Cross Base Highway Lakewood to SR-7 Fails all Club criteria; fails RTID internal criteria

Alternative Road Projects Emphasize Maintenance and Transit Operations
Not only do projects we rate poor fail to accomplish climate change stabilization, multi-modal mobility, and land use goals, they also consume vital fiscal capacity which would no longer be available for other important needs. Better use of large RTID expenditures includes two crucial preservation projects not currently funded: I-5 repaving (about $2B), and the basic four-lane replacement of the SR-520 floating bridge. Sierra Club suggests additional smaller projects that can make a large difference in mobility at key intersections and transit markets. These include the following:

• Third phase of R-8A to create two-way transit in the center roadway of I-90 ($55M to $60M);
• I-90, center access at SR-900 in Issaquah which would build upon the Eastgate transit center access ramps and help eastside transit routes 214 and 554;
• I-5, northbound transit lane between Olive Way and SR-520 for East King County transit routes;
• SR-520, center access from (new) HOV lanes at 108th Avenue NE for Kirkland-bound transit routes 255 and 540;
• I-5, reversible center access to and from the north at NE 50th Street for CT services to/from the University District. This could be implemented a decade before Link LRT reaches Lynnwood; builds upon the Lynnwood center HOV access ramps;
• I-405, center freeway transit stops at NE 85th Street to provide access to downtown Kirkland bus routes;
• I-5 center access from (new) HOV lanes south of SR-512 to provide direct access to Lakewood Transit Center.

Sound Transit Project Assessment

The Sierra Club position in favor of cost effective mobility that promotes sustainable, people-oriented land use patterns supports expansion of the light rail system, but prioritizes the corridors through dense urban areas where all-day two-way high capacity transit will attract significant ridership. The north Link segment to Northgate is the most important component of the entire combined package of transportation investments, and we wish to see it completed as soon as possible within the financial and construction constraints. A November 2007 vote to authorize financing of this segment is of paramount importance.

The extension of Central Link LR both north and south as far as the available funds will take it does not appear to be the most productive use of transit funds as detailed in the Sierra Club email letter to the Sound Transit Board dated January 25, 2007. Integration of high capacity transit with urban land use where well developed street grids promote denser development and walk-up transit access suggests building light rail in the designated urban centers of Everett and Tacoma. Light rail is less cost effective where long trips go through less dense areas. The urban center approach helps direct benefits to each ST sub-area, improving the chance of success with voters. We reduce the impetus for further sprawl which residents will realize to be unsustainable as petroleum prices rise and the effects of climate change become more apparent.

The proposed extensions of North Link LRT into Snohomish County and especially South Link LRT to Fife in Pierce County attempt to serve relatively low density suburban areas with less ridership potential than the primary urban centers in those two counties. Intercity and inter-subarea trips are better carried on express buses using HOV lanes and direct access ramps, and commuter rail. We support further expansion of Sounder service, particularly south, using partnerships with the Ports, WSDOT, and competing railroad companies to leverage more favorable terms with BNSFRR. The high capacity of light rail should be located where it will support the land use patterns and designated urban centers of the PSRC Destination 2030 plan. We favor ST2 fixed rail investments for Pierce and Snohomish Counties be made directly in Tacoma and Everett, respectively. In Tacoma, extensions of Tacoma Link both westward to Tacoma Community College and southward along the SR-7 corridor to PLU and Parkland have merit. Light rail or streetcar from downtown Everett south along the SR-99 corridor to as far as Lynnwood (if funding allows) connects growing urban areas with high quality service.

The proposed East Link LRT connects urban centers Seattle, Bellevue, and Redmond via a defined corridor with quickly increasing density that shows ridership promise within the ST2 time frame. We judge the Seattle – Bellevue segment to be the most important in this corridor given likely ridership and system integration with other transit services. But we also urge ST to maintain reliable, quality bus service to other East King destinations by making joint light rail and bus operations possible on the center roadway of I-90 except for the floating bridge deck (we understand technical concerns preclude this where roadway is over pontoons). Further, we urge ST and other transportation partners to seriously consider the BNSF Eastside Rail corridor for use as a rail transit route, whether for commuter service or all-day two-way local eastside service. The lead time to place passenger rail in this corridor is much shorter than constructing a new line in need of additional right-of-way. Rail service parallel to I-405 is superior to adding vehicle lanes in reducing GHG emissions and preventing further sprawl.

Integration of Projects into Regional Transportation Plan
The Puget Sound region needs true integration of transportation projects to make transit function better, promote smart land use patterns, and reduce greenhouse gas emissions. Sierra Club finds that the proposed “Roads & Transit” investment package is not a compelling model of the integration we need. Rather, it too often appears to be a political marriage of two distinct plans that do not sufficiently reinforce each other. Far from a path forward, RTID appears to Sierra Club to be a broken path.

For the region to meet its GHG reduction targets, which elected officials and citizens have and are setting for themselves, much of the needed reduction will have to come from transportation even as the regional population and desire for travel grows. Easy emission reductions, such as from increasing vehicle fuel efficiency, only counteract the projected growth in emissions due to population, and do not lead to real reductions. A comprehensive regional transportation plan needs to select its investments so as to reduce GHG emissions and other environmental effects from highways. We will need policies that reduce car trips. Use of the pricing tools described above is one way to make our transportation system more productive and reduce its burden on the environment.

Conclusion
The region needs to expeditiously move towards systematic GHG emission estimates for all evaluations of specific transportation projects and regional transportation plans. In the proposed Roads & Transit plan, some projects appear to accomplish multiple objectives and make the transportation system function better consistent with our principles, but many—and especially large expenditure projects—do not. The RTID package contains inappropriate projects and is fraught with structural defects that require changes in the authorizing legislation. We do support allowing Sound Transit to proceed separately to the November 2007 ballot. ST2 contains valuable projects to enhance regional mobility in an environmentally sustainable way, although some spending priorities appear inconsistent with effective integration of land use. The region needs to better address ways to reduce our climate change impacts in the design and operation of our transportation system.

We thank you for the opportunity to comment and look forward to working with our transportation partners to promote a sustainable future.

Sincerely,

Mike O’Brien Tim Gould
Chapter Chair Chapter Transportation Committee Chair

cc: Senator Mary Margaret Haugen, Senate Transportation Committee Chair
Senator Chris Marr, Senate Transportation Committee Vice Chair
Senator Ed Murray, Senate Transportation Committee Vice Chair
Senator Dan Swecker, Senate Transportation Committee Ranking Member
Representative Judy Clibborn, House Transportation Committee Chair
Representative Dennis Flannigan, House Transportation Committee Vice Chair
Representative Fred Jarrett, House Transportation Committee Ranking Member
Sound Transit Board
King County Council
Pierce County Council
Snohomish County Council