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?

It should be clearly laid out in the DEIS what the cost of the No Build alternative is and what projects are assumed to be built in it. This is important because in assuming that these projects are built in the DEIS analysis there is also an underlying assumption that they could reasonably afford to be built. It seems that the No Build alternative may be based more on the MPO's wish list for Chittenden County than a fiscally constrained TIP. 

Is the MTP fiscally constrained? If so, are the Circ Highway sections G,H,I,J in Colchester in the fiscally constrained MTP? I can't understand how you can assume in the No Build alternative that Circ Highway sections G,H,I, and J are built. There has never been enough money to build the Circ without putting many other transportation improvements on the back burner. If you assume the Circ in Colchester is built then you must assume that some other projects are not built for your analysis to be even slightly believable. In addition, how can you possibly assume the Circ Colchester will be built before a new Environmental Impact Statement on that section has been done as required by the Court decision. This is ridiculous and taints the entire DEIS analysis. Also, the condemnation procedure was never completed for Circ Highway sections I and J. 

When alternative 1 was discarded I spoke in opposition to doing so at a public hearing and I still feel this way. Although it was not expected to solve all the needs in the purpose and needs statement it helped meet the need for increased mobility. Section 3-22 mentions that, "It was recommended that a less extensive package of public transportation and TDM should be considered in combination with the short list alternatives:  however, alternative 1 was eliminated". By eliminating it completely the benefits derived from it were ignored. 

The analysis of population changes described at one public hearing acknowledged that there will be an increased number of seniors during the time period studied in the DEIS. Where is an analysis of how the transportation needs of these seniors will be met when they can no longer drive? For example, in Colchester we don't even have bus service as an option for seniors who have lost their independence when they could no longer drive. Is this not a mobility issue? Looking at 5-6 it seems that you define mobility only as it relates to cars and not people. If this is so, how does the DEIS address the mobility needs of those of all ages that are unable to drive or not able to afford a car? How do the alternatives meet the mobility needs of those who are looking to reduce their vehicle miles traveled due to either changes in gas prices or a desire to reduce greenhouse gas emissions from cars? 

Regarding truck traffic - I was surprised to see trucks added to the purpose and need statement so late in the DEIS process. Are you actually removing the trucks by shifting the freight to another mode such as rail, or are you not just moving them from one road to another? This should not be in the purpose and need statement. Instead, you should add something to the purpose and need statement relative to providing alternative transportations options to reduce vehicle miles traveled and increase mobility for all - not just car drivers. 

Regarding safety issues - does the DEIS include an analysis of safety issues on I-89 in the alternatives that include a new interchange on I-89? This is reasonable to request due to the proximity of the new interchange to the existing Williston I-89 interchange.

I would also like to request that since the DEIS does not have a preferred alternative to comment on that there be an opportunity for public comment after an alternative is selected.

-- comments submitted by Marilyn Sowles, Colchester, Vermont