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.

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

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

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

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. ...

At present there are a wealth of possibilities for relieving the existing traffic in Essex Junction and at the I-89 entrance near Tafts' corner, where the true traffic problems arise periodically.  A new exit where the Circ. was to have split off I-89 in Williston, or near old-town Williston, would do a lot to relive the traffic around the intersection of I-89 and route 2A near all the shopping plazas. 

Additional improvements such as "smart" traffic lights -- which can adjust signal times according to traffic patterns, the utilization of web-cams for pre-trip planning, and the efficient transmission of traffic information for use with on-board GPS systems - all of which can allow travelers to adjust their travel patterns according to current traffic patterns. ...

I would also like to say that there was no proper discussion given in the EIS to the wealth of possibilities that could be done with the existing Circ. rights-of-way.  Among them are what could amount to a great step to create one of the most beautiful and self sustaining metropolitan areas of the entire nation -- which I envision as a circumferential park -- with a series of parallel small roads and paths setup to accommodate a wealth of alternative methods of transportation -- seemingly the types of transportation supported by a large portion of the County's population. 

In particular, a bicycle path for self-propelled wheeled transportation path, a foot path for walkers and joggers etc., another path for small motorized transportation vehicles such as snowmobiles, dirt bikes and all terrain vehicles, and another rough and windy dirt path for wildlife observation, horse-based transportation, dog walking, and even for moving livestock when needed.  Then, along these parallel paths, there could be another right-of-way for a light rail system -- which could literally loop along the Circ's right-of-way down to Burlington and then back along I-89 past the big box stores etc. ...

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. 

These comments suggest the need to redo the Berger Circ EIS to realistically consider the roundabout alternative for all study area intersections, and absent that study, the default conclusion must be "roundabouts only."  ...

(1) In spite of repeated warning comments by some participants early in the technical meetings, the Berger Circ EIS totally misses the composition of projected population growth (it is over 65 population only!) for the County and study area with 20-64 population growth of 2,703, a growth of 3%. More important, in order to feed a model for vehicle travel growth, we are supposed to believe that a 3% growth in the 20-65 age County population translates into a County employment growth of about 50% 2005-2025, an absolute growth of about 60,000! ...

(2) The Berger Circ EIS completely fails to even identify much less address the demographic impact of basically no growth in the main driving age population 16 to 65 during the 2000-2030 period while the over 65 age group in Vermont more than doubles, an age group which yearly drives about 40% less miles than the 16-65 age drivers, according to studies including the latest U.S. DOT "National Personal
Transportation Survey."

(3) The Berger Circ EIS bypasses the historic change in Vermonter driving, the collapse of growth and even decline in annual vehicle miles of travel (AVMT) a trend now two decades old, and fails to evaluate the related factors, i.e., increasing motor fuel prices, flat incomes, and shifts in public policy to provide incentives for reduced driving (such as, for example, the EPA commuter choice initiatives).

(4) The Berger Circ EIS displays a complete ignorance of the transformational power of modern roundabout technology, treating the roundabout as another transportation tool, not a revolutionary technology which among other impacts enables and catalyzes denser urban development. i.e., its role as a sprawl buster. ...

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;

second, Senator Stafford, who died last December, left an estimable environmental legacy: a contributor to the federal Clean Air Act, a visionary behind the Superfund law and a sponsor of many other pieces of environmental legislation. As we traveled together through the hills of Vermont, he often viewed with sadness the increasing haze on our horizons. He distinguished for me between wet deposition sulfur dioxide (acid rain) and dry deposition sulfur dioxide (the summertime haze formed by the undesirable combination of heat and high humidity levels with the imported air pollution from the high sulfur coalburning plants of the Midwest). He commented often on the irony about ozone: a beneficial element in our upper atmosphere but a danger at ground level.  As the federal EPA website itself states: Ozone (O3) is a gas composed of three oxygen atoms. It is not usually emitted directly into the air, but at ground-level is created by a chemical reaction between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Ozone has the same chemical structure whether it occurs miles above the earth or at ground-level and can be "good" or "bad," depending on its location in the atmosphere.

In the earth's lower atmosphere, ground-level ozone is considered "bad." Motor vehicle exhaust and industrial emissions, gasoline vapors, and chemical solvents as well as natural sources emit NOx and VOC that help form ozone. Ground-level ozone is the primary constituent of smog. Sunlight and hot weather cause ground-level ozone to form in harmful concentrations in the air. As a result, it is known as a summertime air pollutant. Many urban areas tend to have high levels of "bad" ozone, but even rural areas are also subject to increased ozone levels because wind carries ozone and pollutants that form it hundreds of miles away from their original sources.

Senator Stafford was troubled by these facts and by their visual evidence in Vermont's Green Mountains. Because automobile exhaust is such a localized factor, I am certain that this wieghed heavily on him as he considered his original involvement with the circ. I personally have written in the local press that the circumferential highway is a "growth bomb." Yet, recalling now Senator Stafford's personal lectures about the threat of ground level ozone and knowing that automobile-generated carbon emissions having been the fastest increasing carbon pollution in Vermont, I am certain Bob Stafford would question not only his early role but also the sanity of continuing with this flawed and unwise project. I can imagine him saying, "If the circ were a horse, I'd put it out of its misery"; and

Finally, he would also observe that the promises of local circ boosters to include bike paths and other pro-pedestrian services were the first to be jettisoned as the costs of this project soared.

There is not much more that I can add to the volumes of testimony against the circ, but I conclude with these personal thoughts:

I am not a NIMBY (not in my back yard). Why? The circ already is in my back yard. As a resident of Essex, I can walk from my back door, through the Town Forest and to the circ without seeing another house or crossing another road. The destruction of habitat and walking trails that once linked neighborhoods is evident. I hope we do not visit such destruction on other areas of Chittenden County by completing this road to ruin; and

I have traveled the length of the entire proposed route with David Pinkham, when he was the director of the Circumferential Highway District. Mr. Pinkham personally related how one developer in Essex held up the circ for years because he feared it would decrease property values of additions to his development. Yet, in later years, this developer, having made his peace with the circ, proposed to our local planning commission that we remove the limited access designation, that we increase curb cuts and that we scale back scenic setbacks and greenbelts. To me, this is evidence that such a project is a seductive magnet for local development pressure and increased highway traffic. I miss Senator Stafford. He was my employer, my teacher and, most of all, my friend. I value his impact on my life and the lessons he taught me.  I cannot now speak for him as I once did, but I sincerely and earnestly appeal: Do not sully the undeniable environmental legacy of U.S. Senator Robert T. Stafford by continuing to support what has become a policy embarassment and a public health nuisance.

Sincerely,

Bruce S. Post
Essex Junction, Vermont 05452

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.

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!

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.

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!