Purpose and Need: WEP vs. WETLANDS
The National Environmental Policy Act requires that an Environmental Impact Statement process must start with a “purpose and need” for a proposed federal project, and that this P&N is the baseline for developing a range of alternatives to consider during the project development phase. The WEP’s “purpose and need” (P&N) was written in 1985 as part of the original DEIS.
The P&N is so out of date that it needs to be rewritten. Since 1985, the BLM bought land in the path of the parkway for ecological restoration purposes, and its inclusion in the NEPA process as a “cooperating agency” meant that the agency needed to participate in the “scoping” of alternatives. Several analyses showed there is no need to build a large expressway in West Eugene to cope with traffic problems and poor land use designs. Public support for the WEP decreased as the project dragged on, and would have been almost non-existent if the region needed a new gas tax to pay for the budget shortfall. Perhaps the most important "new circumstance" that mandates a new P&N is the fact that we reached the "plateau" of petroleum production during the study period.
ODOT and FHWA were not able to design a version of the WEP that meets the five requirements of the 1985 P&N.
Purpose and Need
West Eugene Parkway
|"Provide a major access-controlled east-west connecting arterial ... between Highway 126 ... and the I-5 / I-105 corridor."||
The WEP would not connect to I-105.
The 2002 TransPlan amendment to approve most of the WEP removed funding for WEP also competes with Belt Line projects that are the main connection between 126 and I-5.
The 1996 ODOT traffic study predicted WEP traffic would overload 6th and 7th at Chambers and at I-105, causing congestion that does not meet a reasonable standard for “purpose and need.” This level of saturation also would violate ODOT’s standards for acceptable levels of congestion on major state highways such as 126. In addition, the Plan Amendments would cancel a road “modernization” project on 126/I-105 (widening the off-ramp from the Washington/Jefferson bridge onto 6th Street), which the Plan Amendments predict would cause even more severe congestion in Year 2015.
The "Couplet Alternative" unveiled in October 2005 would not build an "access-controlled" arterial east of Seneca, but instead would funnel Beltline traffic onto inadequate local roads with numerous driveways and intersections.
In July 2002, two projects on Belt Line (Belt Line Phase 3 from Roosevelt to West 11th, River Road to Delta Highway) were “futured” to find money for the WEP. The documents provided by the City and County as part of the TransPlan amendment process admitted that “futuring” the Belt Line widening from River Road to Delta Highway would cause it to degrade from Level of Service D to LOS E eastbound, and LOS E to LOS F westbound. This violates the WEP’s ostensible “purpose and need” to connect Highway 126 to I-5. In addition, the TransPlan will likely need to be revised again to accommodate the “heart transplant” of Peace Health hospital to the McKenzie River floodplain – which would require even more widening of the Belt Line.
ODOT’s “Frequently Asked Questions” about the WEP (Fall 2001) changed this purpose and need statement to “Provides a major, access-controlled, east west connection between Oregon 99 and Oregon 126 west of Eugene.” However, an alternative of an upgrade to West 11th west of Belt Line, the completion of Belt Line, and upgrade to the Roosevelt Blvd / Highway 99 intersection would meet this revised purpose and need statement, providing a (mostly) access-controlled, east-west connection between Oregon 99 and 126 to the west.
The WETLANDS alternative, Option 1, would complete Belt Line (the real 126 / I-5 connection) and permit its upgrade to Interstate Highway status.
The west 11th / Beltline route between Highway 126 and I-5 would be a better express through route than Highway 126 to I-5 with the WEP (fewer traffic lights).
Expanded public transit (including west Eugene Bus Rapid Transit), intersection repairs on West 11th, a few new roads (the First / Second connector), and zoning shifts could reduce congestion more than the WEP.
Peak Oil's economic impacts will reduce traffic demand long before the WEP's design year of 2025. The "Purpose and Need" need to be rewritten to include consideration of natural limits to growth, including Peak Oil and probable impacts of climate change on regional water supplies.
|"Improving access to the West Eugene industrial area via direct connections."||
The WEP's 5th / 7th couplet would make access to existing businesses more complicated. The partial access at Seneca (no left turns allowed from WEP) would not improve access to the area.
The WEP threatens to convert industrially zoned areas into commercial strip malls (which are more profitable near major highways). This would displace some industrial area businesses to more distant locations, defeating this ostensible purpose for the parkway. The partial access at Seneca (no left turns allowed from WEP) would complicate access to the area.
Existing north -south roads and Roosevelt Blvd. already provide sufficient access. The latter is is not congested during rush hour, and the SDEIS did not include traffic projections for Roosevelt, perhaps because the analysis showed that this major arterial would remain lightly used. ODOT’s 1995 approval of the Belt Line widening project would sever the Belt Line / Roosevelt connection, forcing industrial area traffic onto WEP.
The WEP would also divert traffic from existing businesses that depend upon West 11th traffic.
The WEP is an effort to extend the declining paradigm of boom and bust toxic industry that is unlikely to survive past the peak of petroleum production.
The First / 99 / Second connector would improve access to the industrial area better than converting 5th and 7th into the WEP.
Completing Belt Line, fixing 99 and Roosevelt, and intersection repairs around the industrial zone would better benefit businesses.
A long term program of shifting to green businesses and bioregional sustainability would ensure continued viability of industrial type jobs.
|"Better link West Eugene residential areas with downtown, thereby supporting orderly and planned growth."||
The WEP would bypass all three residential areas in west Eugene: River Road, Bethel-Danebo, and 18th Street - South Hills. Bethel area drivers are better served by Roosevelt, 99 and Belt Line, River Road would not benefit at all from WEP, and 18th Street congestion issues were ignored by the EIS.
The WEP’s overloading of 6th and 7th Avenues makes a “link”
with downtown more difficult.
New links between Highway 99 and Northwest Expressway would improve neighborhood connectivity. The First - Second connector would improve connectivity for the west Eugene industrial area (the WEP would reduce connectivity for some businesses). The intersection repairs along west 11th and nearby roads would improve traffic flows more effectively and cheaper than WEP.
|"Implement an important part of the area-wide roadway system as envisioned in ... TransPlan."||
The WEP would not fulfill the 1986 TransPlan (which WEP was originally designed for), which included Terry Street from WEP to 11th, a Danebo / WEP intersection and Beltline extended to 18th Street.
It would not even meet the current Transplan, Regional Transportation Plan or any other government planning document, since no version of these plans included all of the WEP in the 20 year fiscally constrained budget. The WEP / Beltline interchange was not in the TransPlan when it was developed. WEP funding cannot be accommodated in the region's long term transportation budgets.
The WETLANDS alternative would integrate existing roads with new connectors better than the overpriced , ineffective WEP.
The alternative could be fit into the 20 Year fiscally constrained list with projected highway funds.
A new TransPlan / Regional Transportation Plan amendment is required whether a Final EIS is ever published or No Build is selected.
|"Relieve congestion and improve safety on West 11th Avenue."||
The SDEIS admitted that West 11th intersections with Belt Line, Bertelsen, Bailey Hill and Seneca would exceed acceptable levels of congestion. The WEP would merely add a new congested route through west Eugene, not “relieve congestion and improve safety.”
The WEP would increase traffic on north-south roads between the highway and West 11th (Seneca, Bailey Hill, Bertelsen, Belt Line, Green Hill), clogging these West 11th intersections.
The worst congestion in Eugene is on 6th & 7th Avenues and on Beltline.
|Fixing West 11th intersections for safety and capacity would cost about $2 million. Completing the Supplemental Final EIS is expected to cost at least another $1.7 million (money that cannot be used to solve the problems).|
ODOT officials have repeatedly suggested that there are three purposes for WEP (beyond the 1985 P&N statement).
|1. To facilitate through traffic in the region.||The WEP would not significantly improve this, and if funds for WEP delayed fixes to Beltline, it would reduce this goal.||The WETLANDS alternative would meet this goal through finishing the Beltline (Phase 3 - Highway 99 to West 11th). The travel from 126 to I-5 would have 2 traffic lights without WEP, and 3 lights with it.|
|2. To accommodate local residential traffic.||The WEP would have minimal improvement, if any, to local residential traffic in the three main residential areas of west Eugene (northwest Bethel, River Road, 18th Street).||The WETLANDS alternative would better serve existing neighborhoods through fixes to existing roads and a few new roads (none on WEP route) to provide better connectivity.|
|3. To serve the west Eugene industrial zone||The WEP would not improve access to the industrial area, and some businesses would see reduced access from the "Couplet Alternative." The WEP would also provide significant incentives to convert industrial zoned lands to commercial areas (near intersections).||The WETLANDS alternative would provide better mobility and access for the industrial zone. The First / Second Connector would better serve the industrial zone than converting 5th and 7th Avenues (from Seneca to 99) into the WEP|
Piercy defends push for parkway forum
By Edward Russo
Published: Friday, December 9, 2005
The Federal Highway Administration, in collaboration with two other federal agencies, next year plans to decide if the environmental studies that have been done for the roadway comply with federal law.
If so, the federal agency could issue a recommendation to build, something the Oregon Department of Transportation needs in order to start construction.
The mayor's proposal, which could use a mediator with transportation expertise, would provide another opportunity for public input, said Emily Lawton, assistant administrator of the Federal Highway Administration's Oregon division, who attended the MPC meeting.
"This would give the public a chance to say have you considered this (alternative) before?" she said.
If the answer is "no" and the alternative fits the official purpose of the parkway, which is to improve traffic through the west part of town, then it's possible the environmental review would "go back to square one," she said.
California style "donut" development to ensure a permanent Republican majority
James Howard Kunstler notes that the Atlanta Outer Perimeter is a
“collective wet dream of all the panting suburban realtors / commercial homebuilders / car dealers / strip-mall developers / parking-lot pavers, and other pathogenic characters who fed off the metastasizing tumors of suburban sprawl.”
The real purpose for the WEP is to facilitate new subdivisions in an expanded City of Eugene that would attract conservative Christians -- many from southern California -- who presumably are habituated to giant freeways and monoculture sprawl dominated by franchises for multinational conglomerates that lack any local identity. The WEP would make Eugene look more like southern California so new arrivals from L.A. will feel more comfortable. These new citizens, who are not yet taxpayers for the region, could then ensure a socially conservative, financially unconstrained city Council. The WEP would spread sprawl around Fern Ridge reservoir with “ticky-tacky little boxes that all look the same.” This puncturing of the UGB would also facilitate trophy homes on the ridgeline above Willow Creek (which would pour lawn chemicals into Willow Creek headwaters). Another purpose is to centralize the regional economy with Wal-Mart type stores to concentrate economic power at the expense of locally owned businesses.
The west Eugene Wal-Mart / Target combination, one of the ugliest locations in the metro area, is the best example of the real “purpose” of the parkway.