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 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;

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?"

---

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!

Did you comment yet on the Circ Highway EIS?

If you haven't, please done so yet, please submit your comments on the draft Circ EIS ... even if your comments are brief.

The new deadline for receipt of comments is Wednesday, November 21st.

For some ideas, take a look at the excellent Op-Ed remarks of Virginia Clarke in our previous posting.

You are also welcome to download the comments I am filing for ideas. Feel free to email me at: pcjournal@yahoo.com

Key points to stress:

1. We need to consider the sustainability of our transportation investments (this was a point made by the Burlington Planning Commission: "

"Infrastructure investments like this [referring to the Circ alternatives] enjoy a fairly short period of time before their capacity/functionality is again stressed an additional investments may be necessary. The Commission would strongly urge that the sustainability of the investment be included in the decision-making regarding a preferred alterrnative. Thus, consideration of which combination of capital investments and transportation services will serve the region most effectively over the longest period of time. Questions such as: How long will it be effective at meeting the purpose and need? How adaptable to change or flexible to accommodate future growth is it? How can it serve the most people over time?" [emphasis as is in the Planning Commission Memorandum]

2. We need to focus more on public transportation -- this closely relates to the above, since it provides a better long-term investment, especially in light of gas price trends and real global warming concerns. Take a look also at my earlier post about discarded Alternative 1 -- and in your comments consider requesting that Alternative 1 be reconsidered.

In terms of global warming, note that the just released "Final Report and Recommendations of the Governor’s Commission on Climate Change" (October 2007) states that: "The climate change crisis may represent the most important and comprehensive global challenge of our lifetime." ... [T]he upward curve of Vehicle Miles Traveled (VMT) ... is the most significant source of greenhouse gas production in Vermont." As a "quick tip" the Report also recommends: "Use public transportation wherever possible -- if public transit is lacking in your area; express your concerns and ideas to local officials."

3. In selecting an alternative, an important factor should be cost. The draft EIS indicates that the cost of the limited highway Circ alternatives is upwards of $15 million more than building a "Circ Boulevard." And even lower cost alternatives are available for dealing with Essex-Williston congestion by improvements to Route 2A. If you want more detail on these points, download the Memo I prepared several weeks ago for the Burlington Planning Commission, and look at pages 3 and 4.

You can also download the Summary Matrix page from the draft EIS that sets out the comparative costs of the ten alternatives. (If you need a quick alternative to the ten alternatives under consideration (bearing in mind they do NOT include Alternative 1 and its package of public transportation enhancements), download the EIS' Executive Summary).

The full draft EIS is available online. If you want to locate detailed information -- I'd suggest starting with the Table of Contents, as the full document is extremely long.

You can file your comments by emailing or mailing them to:

Mr. Kenneth R. Sikora, Jr., Environmental Program Manager, Federal Highway Administration Region 1, P.O. Box 568, Montpelier, VT 05601
email: kenneth.sikora@fhwa.dot.gov

-- As an alternative if you're pressed for time, you can use a form available on the CLF web site -- you can easily modify the comments they've prepared to stress the issues / concerns most important to you, and then submit them by email.