DRAFT PEIS
DOCUMENT Concerns
1. Vision
The
PEIS vision should produce a sustainable solution that supports
the level of growth and development desired by Corridor Jurisdictions. Corridor communities have a critical role in
determining this vision as transportation capacity can stimulate or
suppress growth and place greater or lesser demands on local
infrastructure, (including local roads, schools, law enforcement,
emergency services, physical and legal water supply,
water treatment and sewer treatment facilities).
Corridor growth will also influence
community character and resident’s quality of life.
The transportation solution should
minimize disruption through the construction period, minimize the
disturbance footprint and environmental impacts and fully utilize
technology and incentives to create a viable long term solution.
The
Draft PEIS “Preferred” alternatives should provide a practical course
for I-70 mountain corridor improvements for the next 50 years.
Each
of the “Preferred” alternatives has a larger footprint than the current
highway and has a corresponding larger environmental impact. Each of the “Preferred” alternatives is
completed by 2025 and accommodates network capacity until 2030,
providing only a five year effective life beyond completion.
Each
“Preferred” alternative is also based in large part on petroleum based
technology that will be affected by world market oil prices. Each of these alternatives also relies heavily
on internal combustion engines that currently have very low energy
efficiency rates, (20% typical). Sustainability
of these solutions will require substantial improvements in highway
technology, vehicle technology and efficiency, as well as a stable
world oil market to be cost effective and practical solutions
throughout a 50 year period.
Our
vision should provide a high level course of action for improvements
over the next 50 years including alternate route development and
transit and highway components. Included
in this vision should be a number of reassessment points that allow the
Coalition to meet with CDOT/FHWA to review project progress, evaluate
current conditions and use adaptive management techniques to reshape
the vision if necessary.
Changes
in Front Range and Corridor growth, water availability and supply,
development, recreation locations, traffic patterns and travel behavior
will need to be evaluated to make sure that our implementation plan is
still on target. In addition, new vehicle,
highway, transit, excavation, boring, or other construction or tunnel
technologies may need to be considered as we review the implementation
plan. Changes in vehicle, fuel, highway,
transit or other transportation or construction costs, or changes in
available funding may require additional consideration.
If necessary, the Coalition and
CDOT/FHWA may agree to reshape the vision based on unanticipated events
or unexpected shifts in travel patterns, costs, technology, funding
availability and travel behavior.
2. Selection Criteria used for the Preferred
Group of Alternatives
The
two primary selection criteria used in determining the “Preferred”
group of alternatives are the following:
A. The
alternative’s ability to meet the project need, (increase capacity,
improve
accessibility and mobility, and decrease congestion) which is measured
by
the alternative’s
ability to accommodate projected 2025 baseline travel demand.
B. The alternative’s ability to meet economic
reasonableness as defined by a capital
cost
equal to or less than $4 billion.
The
alternative’s ability to address Safety issues, Community Values, and
Environmental Sensitivity were not given the same weight in the
selection of the “Preferred” group of alternatives as the ability to
accommodate projected 2025 baseline travel demand and capital cost
equal to or less than $4 billion. In
addition, the alternative’s Environmental, Economic, Social and
Mobility impacts during the Construction period and the alternative’s
Health impacts to adjacent communities were not considered as selection
criteria for the selection of the “Preferred” group of alternatives.
Clear
Creek County would suggest that the alternative’s Health impacts on
adjacent communities, ability to address Safety issues, Community
Values and Environmental Sensitivity, and the alternative’s
Environmental, Economic, Social and Mobility impacts during the
Construction period are just as important to the selection of the
“Preferred” group of alternatives as the alternative’s ability to meet
the project need and the alternative’s ability to meet economic
reasonableness.
We
would suggest that this Environmental Impact Statement consider each of
these items as a valid measure in determining the “Preferred” group of
alternatives.
3. Selection
Criteria needing further evaluation in Tier 1, prior to the selection
of the Preferred Alternative
A. Health Impacts to the I-70 Adjacent
Communities for each alternative
B. Environmental Impacts relating to each
alternative during and after the construction
period
C. Alternative Speed, Capacity and Reliability in
Adverse Weather Conditions
D. The potential disturbance of heavy metals from
23 Historic Mill Sites within the I-70
Right of Way in Clear Creek County
E. Potential Impact to Section 106, (historic)
& 4F (recreation & park) Properties in the
Corridor
F. Mobility Restrictions and related social
impacts during the Construction Period for
each Alternative
G. Economic Impacts for each County during and
after the construction period
H. Determination of Transit
Preservation Inclusion or Transit Preservation
Nonpreclusion prior to Tier 2
4. Transportation Planning
Transportation
planning is a crucial tool for managing growth and development,
however specific growth objectives are not provided by Corridor
communities in the PEIS. Instead of the Corridor communities
clearly defining the type and amount of growth and development that
they desire and then pursuing transportation alternatives to meet their
growth objectives; the PEIS selects alternatives based on their
ability to meet 2025 projected travel demand with only some general
assumptions for Corridor community growth goals.
Regional
Planning Organizations such as the Denver Region Council of
Governments include transportation planning in
their Metro Vision Plans in order to keep transportation
planning in sync with growth objectives. This does not
appear to be happening in the mountain corridor. Some communities
may be looking to stimulate growth, while others may be looking to
manage and control growth, and a regional consensus on growth
management has not yet been determined. Without a clear
objective for regional growth management, alternative selection is
difficult as each alternative differs in terms of managing, suppressing
or inducing growth.
5. Construction Concerns
The Draft PEIS states specifically that the residents of Clear Creek County, their visitors, businesses, governments and other
institutions, and the people traveling through the county (all of them)
will be affected by construction work associated with project
alternatives. It also states that
localized impacts are expected to be most prominent in Clear Creek County.
Although
the Draft PEIS identifies Clear Creek County as
being the most affected by the construction of the alternatives,
construction impacts are still not used as a measure for determining
the “Preferred” group of alternatives. In fact, all "Preferred"
alternatives are in the Greatest Construction Impact group.
In
addition, there is no suggestion as to how construction of the
“Preferred” group of alternatives will be scheduled.
Will construction occur year round,
(except for peak travel periods) or just from May through October
similar to the project schedule for the US 40
work on Berthoud Pass (to
provide some relief during the ski season)? The
Draft PEIS does not even suggest any alternate means of transportation
through or around the Corridor during the construction period, so it is
assumed that everyone traveling to the mountains will continue to use
I-70 and suffer through construction congestion and delays.
We
would recommend that construction impact and mitigation strategies be
disclosed in Tier 1 and included in the selection criteria for the
“Preferred” group of alternatives.
PREFFERRED
ALTERNATIVE OBJECTIVES
1. Safety
A. The preferred
alternative should make the I-70 Corridor through Clear Creek County
safer, reduce the number and frequency of traffic incidents and provide
improved incident management.
Clear Creek County
currently contains some of the most dangerous portions of I-70 through
the state of Colorado. The county is concerned for the safety of our
residents and visitors and the increasing frequency of incidents in the
Corridor. Traffic incidents overburden our
emergency service resources and infrastructure and can gridlock the
I-70 Corridor for hours. Traffic incidents
have a greater overall affect on I-70 congestion in the county than
vehicle traffic volumes alone due to their severity and
unpredictability. Decreasing
incidents may have greater potential for reducing congestion and delays
than any single alternative.
Improved
incident mitigation through safety improvements and improved incident
management should be a clear priority for any preferred alternative.
B. The
preferred alternative should not overly burden county emergency resources.
I-70
incidents continue to place a significant burden on county emergency
services including staff, resources, equipment and communications
infrastructure. At great expense to the
county, we are in the process of expanding our 911 communications
infrastructure and staff largely due to increases in I-70 incidents. We continue to struggle to find an appropriate
funding mechanism for our Fire Authority and Ambulance Department since
nearly 50 percent of their calls are on I-70 and not in our communities.
The
preferred alternative must address current safety concerns and provide
a potential reduction in annual emergency incidents. A state
funded reimbursement mechanism for I-70 incidents would also be
desirable.
2. Economic Impact
The preferred alternative
should have a positive impact on Clear Creek County's economy.
The
initial construction of I-70 allowed travelers to bypass Clear Creek County on
their way to more distant locations, (which were made closer by the new
interstate highway). With fewer visitors, Clear Creek County's
economy suffered. The new I-70 solution should contribute to Clear Creek County’s
economy by providing positive views, good access to our towns and
attractions including Clear Creek for rafting and fishing, the
Georgetown Loop Railroad, Herman Gulch, Bakerville/Stevens Gulch and
Loveland Ski Area. It should also protect our waterways and
minimize footprint expansion to protect private property in our towns
and the Dumont/Lawson/Downieville area.
3. Protection
of the Natural Environment of Clear Creek County
A. The
preferred alternative should improve water quality.
Silver Plume, Black Hawk, Golden and other Front Range Communities use
Clear Creek as their water supply. Traction sand,
chemical deicers and copper from vehicle brake linings migrate into the
creek and impact water quality. Water
quality can be degraded by increased highway runoff as additional
highway surface is added and by construction disturbance in mineralized
areas, (especially on abandoned mill sites). Those alternatives
that add highway lanes and increase vehicle traffic will have a greater
impact on water quality than those alternatives that do not.
Georgetown, Idaho
Springs, Silver Plume, Empire and the Clear Creek Sanitation District
all discharge effluent into the creek and any increase in metal loading
from highway runoff or highway construction may place greater and very
expensive performance requirements on these facilities. Increased
metal loading from runoff and construction may impact Clear Creek
fisheries and have a negative impact on our angler tourists.
Increased use of chemical deicers may kill surrounding vegetation and
increase erosion. The preferred alternative should require less
excavation in mineralized areas for construction, less sand and
chemical deicers for winter use, and utilize improved sediment control
measures.
B. The
preferred alternative should minimize highway expansion outside of the current
I-70.
We have waterways,
residences, businesses, bike paths, parks, recreational facilities,
fire stations, historic sites, wildlife areas and municipal facilities
located very near the current I-70 footprint. We also have
desirable land in the corridor for future commercial, residential and
Greenway growth, again located close to the I-70 footprint. Any
expansion of the current highway footprint could have a negative impact
on the county and its municipalities and require the acquisition of
private property.
C. The
preferred alternative should create less Carbon Monoxide, Entrained
Dust, PM-10, PM-2.5 and Air Toxics.
Residents in Clear Creek communities that surround the I-70 Corridor
have been exposed to potential health risks due to entrained dust,
PM10, PM2.5 and air toxics in the past. The current I-70 highway
is a significant contributor of entrained dust. We would like to
mitigate these potential health risks in the future by selecting a
preferred alternative that minimizes these airborne contaminants.
D. The
preferred alternative should create less noise in Clear Creek County communities.
Noise mitigation walls on I-70 through the county would have a huge
negative visual impact. Restricting the motorists’ view of the
county may also have a negative affect on visitors and tourism.
The best solution for Clear Creek county would be an alternative
that simply creates less noise. Ideally this would be less
noise than exists today in the Corridor.
E. The preferred alternative should mitigate
impact to county wildlife and provide wildlife
crossing areas.
A
portion of I-70 in Clear Creek County
borders Clear Creek Open Space Land that
is home to a large population of Big Horn Sheep. In addition to
the Big Horn Sheep, the county also has large elk and deer populations
that have seasonal migration patterns that cross I-70. The
preferred alternative needs to have adequate crossing areas to
accommodate seasonal migration patterns for our wildlife and minimize
vehicle/animal conflicts.
4. Downieville Weigh Station / Ports
Relocation
of the eastbound and westbound ports is desirable.
Entering and exiting trucks on short
entrance and exit ramps slow traffic and promote congestion. Westbound, (uphill) trucks leaving the port
create moving road blocks and a serious pinch point as they enter I-70
at significantly lower speeds than mainline westbound traffic. Extended periods of idling trucks in and
around the ports also create air quality problems in the narrow
constrained Downieville canyon which creates a health concern for area
residents.
5. Greenway Inclusion
Any
major construction activity in the I-70 Corridor in Clear Creek County
should not only facilitate the Clear Creek County Greenway as defined
in the Greenway Master Plan, but integrate it into the final solution.
6. Rockfall Protection of Highway Lanes on Georgetown Incline
Complete
sheltering, structuring or tunneling must be considered as options for
any additional climbing or descending lanes between Georgetown and
Silver Plume. Substantial rockfall
protection including complete sheltering should be included in all
action alternatives for this dangerous segment of I-70, even if no
additional lanes are included in the alternative.
