StopTheCirc

Circ EIS comments by EPA available

Most of you probably read in today's Free Press, or heard on VPR or TV news, about EPA's comments on the Circ Highway alternatives -- giving strong preference to the Route 2A alternatives.

I haven't had time to carefully read through them -- or other comments available on the VTrans web site (especially those from Essex, Williston, Milton, Burlington, and the Chittenden County MPO) -- but will try to do a summary posting next week.

In the meantime, you can download the federal, local, and all other comments via the VTrans page. Kudos to VTrans for making all comments available to easily download and read.

the cost of the full Circ Highway

About two months ago I asked the Vermont Agency of Transportation for current cost estimates for the construction of the full Circ Highway -- a project the administration and the Chittenden County MPO are still (at least on paper) committed to.

I finally received a reply from John Ziconni, the Agency's Communications Director.

As you'll see, there are apparently no current cost estimates.

But, as Zicconi notes, as of about four years ago the total price tag was approximately $220 million -- that's right, closing in on 1/4 of a billion dollars.

Apparently, it's anyone's guess what the total price tag would be today. But who cares when it comes to evaluating the highway's staggering cost against its meager (if any) benefits -- certainly not the so-called fiscal conservatives in Montpelier!

Here's the correspondence:

-----Original Message-----
From: Planning Commissioners Journal <editor@plannersweb.com>
To: Zicconi, John <John.Zicconi@state.vt.us>
Sent: Wed Oct 03 14:37:23 2007
Subject: Circ Highway costs

Can you tell me if VTrans has any cost estimates for the full build out of the Circ -- not just the "A-B" segments that are part of the current EIS, but also including the Essex Jct to Colchester segments?
If you don't have any current cost estimates, can you tell me what your last estimates for the full Circ costs were. If you have the cost broken down by category (e.g., engineering, ROW acquisition, construction), that would be especially helpful.

Thank you.

Wayne M. Senville 
Editor, Planning Commissioners Journal

---

From: Zicconi, John [mailto:John.Zicconi@state.vt.us]
Sent: Monday, December 03, 2007 1:24 PM
To: editor@plannersweb.com
Subject: RE: Circ Highway costs

Wayne,

We had to locate some old records, but I have an answer to your question.

When last estimated (2004), the cost to complete Segments A/B, G/H and I/J was approximately $138 million.  At that time, we had spent approximately $82 million in design and ROW acquisition for Segments A-J, and the construction of Segments C-F and Susie Wilson Road. Thus the total price tag of building the entire Circ Highway, as it was conceived back in 2004, was approximately $220 million.

Thanks,

John Zicconi, Communications Director, Vermont Agency of Transportation, Secretary's Office, One National Life Drive, Montpelier, VT 05633-5001

the promise of a "free" highway

Note: the following comments on the draft Circ EIS were filed by Marilyn Sowles of Colchester:

To: Kenneth R. Sikora Jr., Environmental Program Manager, Federal Highway Administration

I have followed the proposed Circ Highway as a private citizen since 1992. For two years ( 2000-2002), I followed it as a member of the Colchester Selectboard. I have also attended the public meetings held over the past couple of years as part of the Circ-Williston DEIS preparation.

Over the years, I have been continually amazed at how the promise of a 'free' highway taints the whole process of transportation planning. I say 'free' because from the standpoint of local officials it is 'free'. An $80 million Circ Highway costs not a penny to whatever town it goes through. However, local road improvements are paid for through the local town budget and arterial road improvements require at least a 10% local match. Usually, in Vermont, we clearly choose the least cost alternative that meets the needs. I hope we do so in the final alternative selected by the EIS. In the case of a 'free' highway, however, many local decision makers seem to feel that millions more is no big deal. Of course, federal money is not really 'free' even though it is often treated as such.

This DEIS does not do an adequate job of presenting the costs and benefits of the alternatives studied.  Since the DEIS analysis of Circ A/B alternatives includes "spot improvements" to VT 2A, the costs/benefits from these VT 2A improvements should be listed separately from the costs/benefits attributable to a new road. As the DEIS is written, how is decision maker supposed to analyze the comparative costs and benefits?

Circ EIS considers only narrowly defined needs

Note: The following are excerpts from comments filed by R. Stuart Hunt of Westford on the Circ EIS. You can also download Hunt's full comments (a 6 page pdf document).

I would like to express my opposition to the plan for extending the Chittenden County Circumferential Highway as outlined in the various "preferred alternatives" selected by the EIS study consultants.

Vermont is a special place which shall forever be remembered as a small and personal place.  It is a special place where the air is clean, the skies are bright, and has an abundance of wildlife, open space and is full of all sorts of people who greatly appreciate such things.

As far as I can tell the Environmental Impact Statement (EIS) released this Summer was completely biased towards considering the narrowly defined needs of the people who live near the area to be circumvented, namely Essex Junction, as well as by people who currently are facing traffic on their way to the interstate highway in Williston. 

However the EIS only cursorily mentions that the outlining areas, such as where I live, won't be affected because development has "already spread with the assumption that the Circ. Highway will be built."  I postulate that this is a preposterous assumption, and it is clear that the extension of an additional loop of interstate highway around the county will invariably lead to ever more rapid expansion of the suburbs out into the hinterlands and country. 

If people now live as much as 45 minutes away to get to a job in Burlington -- you can be sure that they will move ever further out if the opportunity presents them to zip around the county via superhighway on their way to work. This means new housing developments in places such as Fairfield VT, which is currently a mostly rural community. ...

EIS fails to accurately consider demographic trends & roundabout alternatives

The following are excerpts from comments filed by Tony Redington on the Circ EIS. Redington is a transportation policy analyst who formerly worked for the Vermont Agency of Transportation. You can also download Redington's full comments (a 29 page pdf document).

These comments in this presentation totally reject as misleading bordering on fraudulent the findings of the Berger Circ EIS, based on three major contentions:

1. Traffic throughout Vermont, including the target area, likely declines for the study period 2000-2030 for a number of demographic factors centered on population, and historical vehicle travel trends dating from 1990, almost 20 years ago, trends fed by a number of factors which include: (1) employment and income; (2) cost of motor fuel; and (3) growing initiatives to reduce pollution and global warming gases. Given this information the entire analysis, particularly 5.0 "Traffic and Transportation Affects of the Evaluated Alternatives," lack credible foundation and must be discarded as entirely
baseless.

2. The transformational impact of modern roundabout technology which applied to the study area as it must for the huge benefit cost not only places it as a necessary investment, a transportation categorical imperative if you will, but truly undermines and invalidates many of the conclusions regarding Berger CIR EIS performance measures particularly intersection Level of Service, accidents (both segment and intersections), motor fuel use, and land use. 

this flawed and unwise project

Note: this comment on the Circ EIS was filed by Bruce S. Post of Essex Junction, who served for years on the staff of the late Senator Robert T. Stafford.

Dear Mr. Sikora [of the Federal Highway Admistration]:

My name is Bruce S. Post, and from 1981 to 1985 and from 1986 to 1988, I served on the staff of the late U.S. Senator Robert T. Stafford, who secured the original federal seed money for the Chittenden County Circumferential Highway "demonstration project." I was first a professional staff member of the U.S. Senate Education Subcommittee, chaired by Sen. Stafford, and later I was his State Director here in Vermont. As such, I am very familiar with the rationale for his sponsorship of the original circ appropriation in 1982 and with his later thinking on his action. While many others have made eloquent comments on the EIS, I will add what I can from a perspective of one of Sen. Stafford's closest aides.

It has been circulated among a close circle of his former staff that Senator Stafford considered the appropriation of these funds as perhaps "the biggest mistake of his political career."  While I do not know the exact justification for his regret, I will put it in the context of his career so that we can reasonably and confidently surmise why he may have felt this way:

first, as you may know, the demonstration funds (better known today as "earmarks" or "pork") were intended to demonstrate how quickly a highway could be built with federal, state and local cooperation. By any measure, the circ proposal is an utter failure in this regard; to the contrary, it has demonstrated the persistent shelf life of a bad idea. Senator Stafford himself, when he took the first ceremonial ride on the Essex section, commented to the press, "I thought I would never live to see this day." To those unfamiliar with Senator Stafford's wry and often self-deprecating humor, they might think that he was discussing his health. To those of us who knew him well, we recognize the understated but unmistakable inference that the circ project certainly had failed to measure up to the marketing promises of its supporters in Vermont;

Governor's Climate Change Commission Punts on Transportation

At a Press Conference held today at the University of Vermont, Governor James Douglas and members of his Commission on Climate Change unveiled, as Commission Chair Ernie Pomerleau put it, "signature Vermont ideas and signature Vermont concepts."

Conspicuously absent from these signature ideas and concepts were any significant approaches to reducing greenhouse gas emissions from the transportation sector. Sure, there was some of the usual rhetoric about investing in downtowns, promoting energy-efficient buses, and encouraging growth centers, but there was very little to back this up.

Visibly missing from the Commission's lengthy report or the Press Conference was any mention of the Circ Highway and the $200 million or so the State of Vermont still wants to pour into building it. Not a peep about better ways of spending this princely sum -- such as on real alternatives to single-occupancy vehicle use. (See my post on a lost opportunity in the EIS process of developing a realistic transit alternative).

Even more remarkably, despite the report's rhetoric about the need to "reduce travel demand," the report calls for the state to "invest more in its transportation infrastructure, including highways, railroads, and park-and-ride facilities." The Commission's strange logic is that by doing this "the development of public transportation can be accelerated" (see page 4 of the Commission's October 2007 report). Wouldn't it be make more sense -- if the goal is really to reduce greenhouse emissions -- to invest more in public transportation, recognizing that this would, in turn, reduce vehicle miles driven and eliminate the need for building new highways?

But a lack of any true focus on dealing with the transportation sector's greenhouse gas emissions (see Chart at end of this post) didn't keep Governor Douglas from announcing his pleasure that "Vermont is ahead of the rest of the nation in addressing global warming."

Governor Douglas might, however, want to read respected environmentalist Bill McKibben's recent comments on the Circ Highway that: "Every other sensible jurisdiction in the country is trying to get past their 60s and 70s era over-investment in highways." As McKibben puts it, "the Circ can best be described as a global warming machine."

And, before I close, here's a chart from the Governor's Commission report, showing just how important a contributor to greenhouse gas emissions the transportation sector is in Vermont. Which makes it even more puzzling -- and disappointing -- that the Commission chose to punt when it came to calling for any signficant measures to curb our auto-dependency.

Circ EIS Comments Filed by Environmental Organizations

Comments filed today on the Circ/Williston Draft EIS by the Conservation Law Foundation; Friends of the Earth; Vermont Sierra Club; Vermont Natural Resources Council; Vermont Public Interest Research Group; Smart Growth Vermont; Vermont Smart Growth Collaborative.

Note from Wayne Senville: I'm setting out below excerpts from the start of the comments filed. I'd recommend you download the full comments, and if you want to see an excellent in-depth analysis of the major flaws in the Draft EIS, also download the technical analysis.

• Download the full comments (17 pages; pdf file)
• Download the technical analysis supporting the comments (27 pages; pdf file)

Excerpted from the beginning of the comments:

Based on our review we find:

• The DEIS violates crucial provisions of the National Environmental Policy Act (NEPA).
• A 404 Permit cannot be issued for the project as presented.
• The DEIS fails to perform the requisite analyses or implement the proper procedures pursuant to federal law, including illegally segmenting review of the overall Circ-Williston project.

In light of the following comments, the identified deficiencies in the environmental analysis should be corrected before issuing a final Environmental Impact Statement (FEIS) and selecting a preferred alternative.

Based on the analysis in the DEIS, none of the Circ A/B alternatives should be selected as the preferred alternative.

• The DEIS improperly excluded alternatives, including increased transit and transportation demand management (TDM) as well as rail projects that would be able to meet Chittenden County’s needs to move people and goods safely and efficiently at a lower cost and with less pollution and fewer environmental impacts than the alternatives considered.
• The DEIS improperly changed the purpose and need after eliminating alternatives from consideration.
• The analysis in the DEIS demonstrates that alternatives other than building within the Circ A/B Corridor would meet Chittenden County’s transportation needs at a lower cost and with fewer environmental impacts.

Note from Wayne Senville: my thanks to Vermont's environmental community for the time and effort that went into analyzing the morass of information (and mis-information) in the draft EIS. Also, thanks to those of you who took the time to file individual comments!

Bill McKibben comments on draft EIS

To: Kenneth Sikora, Federal Highway Administration, kenneth.sikora@fhwa.dot.gov

Dear Mr. Sikora,

I write in opposition to plans for building more of the Circ Highway. I have been involved in climate change issues for a number of years, having published the first book for a general audience on the subject in 1989 and organized the biggest demonstrations nationwide against global warming in the past two years.

In my opinion, the proposed Circ Highway can best be described as a global warming machine.

All analyses (and endless historical experience) shows such belt highways create sprawl. And they therefore lead to increased reliance on automobiles. They also rob the resources necessary for wiser investments in the solutions of the future. And perhaps most of all they help reinforce the notion that the central job for planners is to 'move more cars.' 

This is a project planned in the past, and it is a project that reeks of the past. Every other sensible jurisdiction in the country is trying to get past their 60s and 70s era over-investment in highways. We are the guys late to the party who seemed determined to drink a keg of beer in an hour just to catch up. It's a gross sight.

--
Bill McKibben
Scholar-in-residence, environmental studies
Middlebury College

Note from Wayne Senville: for more on Bill McKibben's background and publications on global warming and other topics. Join Bill in expressing your views on the Circ EIS to the Federal Highway Administration -- and letting our elected officials know what you think.

a bad investment in the future

I'm setting out brief excerpts from two comments filed on the draft Circ Highway/Williston EIS. If you've filed comments that you'd be willing for us to post excerpts from, please email them to me at: editor@plannersweb.com:

Again, as a reminder: the filing deadline for comments is this coming Wednesday, November 21st -- it's easy to comment: simply email your comments to Kenneth Sikora of the Federal Highway Administration at: kenneth.sikora@fhwa.dot.gov

From Liz Curry:

The purpose of this letter is not to dispute that road improvements are needed to relieve traffic congestion in the Williston-Essex corridor of Route 2 and 2A. The real question is will the proposed solution to build a new ring road bring our region the value we need given the cost? And can we relieve congestion in other economical ways that present longer-term solutions?

The Circ takes an outdated transportation technique -- the Ring Road. ... Indeed, ring roads all over the country have since demonstrated -- through suburban sprawl and reinforcement of single occupancy vehicle use -- what a failed transportation policy this is.

Like most rural Americans, we Vermonters value our independence and freedom to get in the car when we want and go where we want, without having to wait long. However, this desire is based on a century of access to inexpensive fuel that has shaped human behavior as it relates to transportation. I strongly believe that this desire does not warrant a $50 - $90 million investment in a new road, particularly at the direct expense of the multiple transportation and demand side improvements identified in the Metropolitan Planning Organization's MTP [Metropolitan Transportation Plan]. ...

Our problem today (single occupancy vehicle congestion) won't be our problem in ten or even five years. Our problem in five years will be the price of gasoline and the desire for alternative transportation solutions. ...

If VTrans only defines the Circ EIS goal as reducing congestion, then where can the public look to find both the money and the solutions to implement alternative approaches to single occupancy vehicular transportation?"

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From Kathleen Ryan:

"I have now come to the conclusion that this highway should not be built at all. There are too many other, more worthy projects that have been 'on the books' at VTrans, some ready to be built, that are much more deserving of funding. 

Although the State of Vermont has committed to supporting sustainable growth within their downtowns by providing some minor programs, it is denying these towns the important transportation infrastructure they desperately need. There are numerous transportation projects planned for many downtowns that should be built NOW. ...

If the result of building this highway were only that commuters saved a few minutes, as they believe they will, or it is a bit easier for folks on 2A to get out of their driveways, which may be true for a year or two, at least the road would do no harm. But the history of new highways and driving patterns has proven otherwise.  Many of us know that traffic grows to fill the void and, if built, it will encourage surrounding development and the Circ will be bumper to bumper in a few years. 

I believe an investment in transportation infrastructure in any or all of the downtowns mentioned above would reap a far better reward for these towns and a more healthy and sustainable future for Vermont."

Note from Wayne Senville: I've added the graphics to this post!