Date: March 25, 2011
To: West Davis Corridor Environmental Impact Statement (EIS)
Re: Alternatives Advanced to the EIS
From: Sierra Club
These comments follow our submittal June 10, 2010 on the draft Purpose and Need Chapter and our submittal September 15, 2010 on Screening and Performance Criteria for the West Davis Corridor Environmental Impact Statement. In those comments we highlighted the need to follow the principles and objectives of the Wasatch Choices 2040: A Four County land-Use and Transportation Vision which was developed by elected officials, governmental agencies and private and nonprofit businesses and organizations to ensure that we will continue to “enjoy an unparalleled quality of life along the Wasatch Front" as our area grows in population.
Two of the key principles for transportation planning from that visioning effort are to:
We also highlighted the Balanced Transportation, Principle of Agreement #4, in the Mountain View Vision Voluntary Agreement. This agreement was signed March 10, 2004 by the stakeholders convened to participate in the Mountain View Corridor Growth Choices study that was making recommendations for the Salt Lake County portion of the proposed "Legacy Highway" that is also part of the West Davis Corridor planning background.
The alternatives advanced to the to the Draft EIS must include a shared solution that will provide convenient travel alternatives for some of our trips (walk, bike, transit) that will reduce the rate of growth of vehicle miles travelled (VMT) especially at the peak hours of travel demand. incentives for alternatives to To reduce automobile congestion, improve air quality and provide more viable mobility choices for Davis County residents we should utilize performance criteria that optimize access to I-15 and FrontRunner commuter rail as the main north-south facilities for needed transit or automobile trips. Focusing our investments in ways to stimulate a better balanced mode share between single occupant cars, carpooling, transit, bike and walk trips will benefit us all by reducing automobile congestion, improving air quality and supporting active life styles.
Transportation improvements in west Davis County should focus on a integrated, shared solution that seeks to provide viable choices in the way we take some of our trips. Convenient transit, safe bikeways, in addition to our roadway system can provide alternative ways of travel than always taking a car. A more balanced travel-mode-share especially at the peak travel hours would reduce congestion, improve air quality and provide many affordable, convenient and healthy travel.
The first piece of the proposed "Legacy Highway" through Weber, Davis, Sal Lake and Utah counties, the Legacy Parkway and Preserve, was an integrated, shared solution and indeed the courts found that the Final Environmental Impact Statement on the Legacy Parkway was inadequate because there was "failure to consider alternative sequencing of the Shared Solution; and, failure to consider integration of the Legacy Parkway and transit;"
The "Shared Solution" for the Legacy Parkway involved integration of our overall transportation system that was based on the recognition that we don't want to grow up to be Los Angeles. The transit investments we have made along in the Wasatch Front in the past ten years should be optimized by providing convenient connections for its use, especially at the peak hours. The need in Davis County should focus on east/west travel to provide efficient access and connections to the north/south FrontRunner commuter rail as well as the I-15 Freeway and other north/south roadways and trails
Alternative Alignments - Wetlands
For example, the Weber County and northern Davis County section of the study area, the variations of the “G” and the “A” alternative alignments all pose direct impacts to the wetland ecosystem of the Great Salt Lake. Whereas, the more eastern alternative alignments better avoid this critical wetlands system. This in turn, greatly increases the likelihood that the western alignments will be unpermittable under section 404 of the Clean Water Act.
In addition, the alternative alignments north of 4000 South near the Davis/Weber border to 12th South in Ogden all pose major impacts to valuable wetland and upland habitats critical for wildlife. We believe that demand in this area is unripe and the need for any facility at this time is questionable. A premature facility in this area will instead result in “inducing demand” for increased automobile travel by enticing sprawling automobile-dependant development. These alignments should be removed from consideration at this time from this EIS process.
The alternative alignments “A-1” and “B-1” in western Farmington south of alignment “E-1” greatly and unnecessarily impact the wetlands of Farmington Bay when there are other connections to I-15 and Legacy Parkway that avoid this wetland system. They should also be promptly dropped from consideration.
Alignment land purchasing before the proper NEPA process completed