In a pointed letter submitted to WSDOT in mid-December last year the Federal Transit Administration (FTA) criticizes the deep bore tunnel (DBT), saying it would do little to improve transit and would in fact likely have “adverse” impacts on transit “even with mitigation”. The letter, sent by FTA Region X Administrator Richard Krochalis, a comment to the November 2010 Supplemental Draft EIS (SDEIS), states “… FTA remains disappointed [with] the Project’s impact on public transportation.”
It is normal for governmental agencies to submit comments to each other as part of the EIS process, with comments generally dry in nature and narrowly focused on refining the clarity of the document. This was only partly the case with this letter, posing many almost rhetorical questions, pointing out major gaps in the analysis, and calling the assessment of cumulative impacts “extremely optimistic”. The letter also take WSDOT to task for conveniently confusing language about transit investments which are identified in the EIS, but have no secured funding. This has been a disturbingly common meme of the pro-tunnel campaign.
While these comments are in response to the SDEIS and the details of the transit element of the plan have likely undergone some revision, the lack of secured capital and operation funds for transit investments and the large increase in surface street congestion are inherent and intractable problems with the tunnel as is.
Below are excerpts from the letter, emphasis mine:
F-004-005 We appreciate the work that went into the transit analysis. It appears to be advanced quite a bit from the previous SDEIS (e.g., assessing impacts to transit travel time). However in the broadest sense FTA remains disappointed that the Project’s impacts on public transportation are, from our perspective adverse, even with mitigation. In the short term, “Daily ridership growth between 2005 and 2015 with the 2015 Project would generally be similar to or slightly lower than ridership growth in the 2015 Existing Viaduct, depending on the screenline” (Appendix C p.222). Looking slightly farther out, transit share would grow between 2015 and 2030 due to “expanded bus and rail service, particularly Link LRT service in place by 2030, [and] higher automobile operating costs and higher parking costs.” (Appendix C, p. 224.) That is, transit share actually decreases by 2030 (SDEIS p. 215). The SDEIS ambiguously state that this decrease is both negligible and unacceptable (id.) FTA concurs that any project element that decreases transit ridership is not acceptable.
More after the jump.
F-004-009 The SDEIS states that “Since transit routes are designed to serve trips to downtown, while the tunnel is designed to serve trips through downtown, the impact of tolls on transit is negligible” (p. 215). This is simplistic and inaccurate. First, much transit does indeed serve trips through downtown both by design and necessity, sometimes directly and sometimes through connections. Second, the extent tolling affects the ability of transit to operate effectively – that is, if tolling affects access, reliability or travel time – it obviously affects ridership.
The SDEIS finds the impact of tolling on transit ridership to be “negligible” (p.215). However, FTA believes the assessment of the effectiveness of priority treatments to be optimistic. More realistic is the depiction of dramatically increased travel time on Second and Fourth Avenues (Exh. 9-15)… The Project should be ensuring that even the most conservative assumptions show increasing transit use and only minimally disrupted performance, even if getting to that point requires more mitigation funding than the Project has anticipated.
F-004-013 Cumulative impacts. FTA finds the discussion of cumulative impacts due to the Central Waterfront Project, Elliot Bay Seawall Project and Alaskan Way Surface Street Improvements (p. 170) extremely optimistic. It finds the discussion of cumulative impacts due to additional, “non-Program” projects (p. 170-175) perhaps even more optimistic.
F-004-017 Cost of mitigation measure. Will the project proponents pay for whatever mitigation measure adopted? Or are the measures in the SDEIS available for consideration bus continent upon funding? The document is confusing on this point… on p. 3 most readers would incorrectly infer that the 2009 agreement to proceed with a tunnel includes funding for a First Avenue Streetcar. FTA’s understanding is that the transit enhancements agreed to by Governor Gregoire, County Executive Sims, and Mayor Nickels assumed a revenue from an excise tax that has not be secured.