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New Alternatives’ Comment on the Supplemental Draft Environmental Impact Statement
Critique of road proposal
February 26, 2002 |
Great Lakes Bulletin News Service
COMMENTS ON THE US-31 NOTE: These comments are submitted as an attachment to the comments prepared by the Michigan Land Use Institute and the Environmental Law and Policy Center and are intended for inclusion in the official record of the Petoskey Area Improvement Project.I. INTRODUCTION A Trip Assignment Model for the roadway system takes the number of trips from each zone to every other zone, and assigns the trips to the roadway system as represented by links and nodes. Attachments C1 to C3 are three of the traffic assignment results received from MDOT under a Freedom of Information Act request. Note that Intertown Road shows zero average daily traffic (ADT), which means the model predicts no traffic during an average 24-hour day in the Year 2020, a highly unlikely scenario. Intertown Road is one of the few through east-west streets in Resort Township and it extends into Bear Creek Township as well. There are more than 40 houses on Intertown Road. An average day in the Year 2020 with literally no traffic on Intertown Road is implausible. MDOT reaches a conclusion based on the models, but then does not recommend alternatives based on this conclusion. In Chapter 3 of the SDEIS on alternatives MDOT concludes: "All of MDOT’s previous modeling has indicated a relationship between closeness of a beltway location to the downtown area, and the amount of traffic that it would divert." Neither the Far-South or the Intertown-South Alternatives are near downtown and both are further away from downtown than previous alternatives that MDOT studied and rejected. The Near-South Alternative was recommended by MDOT early in the process, but Petoskey objected to this alignment so MDOT then developed Far-South and later Intertown-South. 1. MDOT is uncertain about whether the bypass can protect existing commerce centers. MDOT suggests that state and local planning tools are necessary to discourage new development from competing with existing centers of commerce but there is no analysis in the SDEIS of which tools, or combinations of tools, will be most effective. MDOT could have done an analysis of best practices in the United States or used the Growing Smart Legislative Guidebook developed by the American Planning Association. The last part of the second goal talks about controlling access to the bypass to help prevent undesired development. MDOT proposes to make this happen by prohibiting curb cuts (driveways) along the bypass right-of-way so that new development cannot happen. While this is helpful, access management techniques should be applied on the other major roads as well. 1. MDOT’s proposed Build Alternatives create landlocked parcels, which violates the part of the third Study Goal about not severing recognized cohesive property units. 2. The amount of cut and fill required by the MDOT designs is significant and it will change the rural character. 4. MDOT anticipates major changes in the development potential near proposed intersections with the Build Alternatives. Smart Roads: Petoskey also includes descriptions of 27 land use regulation techniques that will help land use and transportation work together in a more effective manner. The 27 techniques fall into five major categories: The Optimized Local Roads Alternative: 3. MDOT should not require engineering drawings from citizens before they will consider a different alternative. Webster’s Dictionary defines feasible as "1 : capable of being done or carried out (a ~ plan) 2: capable of being used or dealt with successfully: SUITABLE V. CONCLUSIONS 1.US-31 Petoskey Area Improvement Study, Supplemental Draft Environmental Impact Statement and Section 4(f)/6(f) Evaluation, Prepared by the U.S. Department of Transportation, Federal Highway Administration, Michigan Department of Transportation, August 2001 (SDEIS).
PETOSKEY AREA IMPROVEMENT STUDY SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT STATEMENT AND SECTION 4(f) / 6(f) EVALUATION
(dated August 2001)
Rick Kuner, AICP
President
New Alternatives, Inc.
February 26, 2002
At the request of the Michigan Land Use Institute, I reviewed the Supplemental Draft Environmental Impact Statement (SDEIS) for the US-31 Petoskey Area Improvement Study dated August 2001.
Starting in January 1999, I spent almost 18 months to develop the Smart Roads: Petoskey Plan, which is a comprehensive set of transportation and land use recommendations that constitute an alternative to the two major bypass proposals developed by the Michigan Department of Transportation (MDOT) – (1) Far-South Alternative and (2) Intertown-South Alternative. New Alternatives, Inc. prepared three reports for the Michigan Land Use Institute:
To develop Smart Roads: Petoskey and prepare the comments that follow, I read the SDEIS and the Draft Environmental Impact Statement of July 1994 as well as planning and transportation documents prepared for Emmet County, Bear Creek Township, Resort Township, and Petoskey. I also drove the Study Area many times; met with elected officials, citizens, and public agency staff members; conducted two community design workshops in the Petoskey Area ; and used my own professional expertise. At the request of the Michigan Land Use Institute, I presented Smart Roads: Petoskey to the township boards in Bear Creek and Resort, and to other interested groups.
To summarize my major conclusions:
II. PROFESSIONAL EXPERIENCE AND QUALIFICATIONS
I am a transportation and city planner who has been practicing for more than 35 years. I have a Masters degree in City Planning from the Massachusetts Institute of Technology and a Bachelor of Arts degree in Political Science (with honors) from the University of Pennsylvania. At the Kennedy School of Government at Harvard University, I completed a six-week intensive course called "Seminar on Quantitative Methods in the Social Sciences."
I am the President of New Alternatives, Inc., a private consulting firm founded in 1975 in Chicago. The firm practices in the areas of transportation and city planning. The firm also develops computer programs for transportation and planning professionals. Previously I worked for Barton-Aschman Associates as a Senior Associate and for the Boston Redevelopment Authority in Massachusetts in several positions including Chief Transportation Planner and Chief Planner.
As a practicing professional, I have worked in more than 70 communities in 23 states doing a variety of transportation and city planning projects. I have developed several computer programs (including the General Purpose Queueing Model, Better Decisions, and the Bus Transit Garage Space Requirements Model) that are sold around the world. I have published a number of articles on transportation, planning, and computer issues.
Currently I teach a Planning Course and a Policy Analysis and Evaluation Course at the Graduate Program in Public Administration at the Illinois Institute of Technology. In past years at IIT, I taught two other courses (1) Statistical Analysis for Public Managers and (2) Microcomputers and Public Management. As an Adjunct Professor, I taught in the graduate school of Urban Studies at Loyola University and the undergraduate School for New Learning at DePaul University. I was an elected Trustee in the Village of Oak Park, serving a four-year term (April 1997 to April 2001).
I have attached a resume to provide more detail.
III. PURPOSE AND NEED
MDOT’s designs for the Far-South and Intertown-South Alternatives do not meet the four Study Goals in the SDEIS.
A. MDOT does not demonstrate that either the Far-South Alternative or the Intertown-South Alternative will meet the first goal of Level of Service C on US-31, where possible.
MDOT’s first goal says: "1. Improve cross-town traffic circulation in and around Petoskey to achieve at least Level-of-Service ‘C’ on US-31, where possible."
Level of Service (LOS) measures the quality of the traffic flow. The measure takes into account speed and travel time, ability of drivers to maneuver, traffic delays, and comfort and convenience. Levels of Service range from A to F, where Level of Service A is the best possible and Level of Service F is the worst. One good analogy is the grading system used in colleges and universities, where a grade of "A" is the best possible and a grade of "F" is failing.
1. MDOT’s Build Alternatives do not achieve the Study Goal of Level of Service C for US-31 for most sections.
On Figure 3.2-8 in the SDEIS, MDOT shows the results of Level of Service calculations with and without the Build Alternative at seven locations along US-31 for the Year 2020.
With the Build Alternative, four of the seven locations are at Level of Service E or F and one location is at Level of Service D. Without the Build Alternative, six of the seven locations are at Level of Service E or F. By MDOT’s calculations, five of the seven sections of US-31 do not achieve Level of Service C or better.
2. MDOT identifies two different Level of Service goals.
Sometimes MDOT says Level of Service C. Sometimes MDOT says Level of Service D.
In the Study Goals for the SDEIS, MDOT sets the goal for US-31 at Level of Service C or better where possible. Later in the SDEIS, MDOT says: "The MDOT considers LOS "A" through "D" acceptable for Michigan roadways and LOS "E" and "F" undesirable." What Level of Service is MDOT trying to achieve? The Study Goal says LOS C where possible, but MDOT’s policy is LOS D or better. This confusion makes it difficult for people to understand MDOT’s intentions.
3. The models used to calculate Year 2020 traffic volumes are flawed, casting serious doubt on the conclusions drawn from them.
MDOT depends on a series of mathematical models to estimate future travel demand in the Year 2020 and then to calculate Level of Service. However, there are significant flaws in the modeling process that MDOT followed to project Year 2020 traffic volumes. MDOT then uses the models to conclude that the Far-South Alternative and the Intertown-South Alternative would cause traffic to be diverted away from US-31, thereby reducing traffic congestion and providing a better Level of Service on US-31.
The flaws in the models that I discovered are described below. MDOT did not provide either the Michigan Land Use Institute or New Alternatives, Inc. with sufficient documentation about the models to comment on them in a comprehensive manner. Therefore, my review was less that I would have liked and less than a peer review panel would have done. MDOT should prepare a report that describes the models in detail. Such a report would be valuable in Petoskey and throughout Michigan.
4. The Travel Analysis Zones are too large in some parts of the Study Area to satisfactorily project future traffic volumes and the amount of traffic that might be diverted from US-31.
The Study Area is divided into Travel Analysis Zones. In Petoskey, MDOT created 45 Travel Analysis Zones and later created a 46th zone in Resort Township.
In the Petoskey Study carried out by MDOT, the smaller zones are located in the City of Petoskey and the larger zones are located in the rural areas in Resort and Bear Creek Townships. The larger the zone, the more margin there is for errors. Bear in mind that the models assume that everyone in each zone lives and works at the centroid for the zone. Using a centroid for each zone is a simplifying assumption that makes the models easier to work with, but it also reduces the ability of the models to accurately represent real world conditions. The two beltway alignments proposed by MDOT (Far-South and Intertown-South) are located well south of Petoskey in rural areas where MDOT uses large travel analysis zones. Since MDOT wanted to estimate the diversion of traffic from US-31 that might be achieved with different alternatives, they should have designed more travel analysis zones.
Attachment A is a document prepared by MDOT that shows the location of the Travel Analysis Zones. I hand printed the words "Attachment A" on the document, but otherwise, it is unchanged. Notice the north-south length of Zones 13 to 17 and Zone 19. MDOT uses the zones to help analyze how traffic would be diverted from US-31 to the two Build Alternatives. The long north-south dimension of some zones reduces the ability of the models to accurately estimate diversion of traffic from US-31 to either Build Alternative.
5. MDOT’s calibration of the models shows some poor results.
The calibration step is intended to help determine the validity of the models. The basic idea is to use the models to predict a known year, so that the analyst can compare what the model predicts for a base year with the actual traffic volumes that were counted for that year. MDOT used 1990 as the base year. Attachment B is a copy of MDOT’s graphic that shows the ratio of 1990 equilibrium load (what the model predicted) with 1990 ADT (Average Daily Traffic based on actual counts). If this ratio is 1.0 (or close to 1.0), then the model predicted the actual traffic in 1990 with very good accuracy. If this ratio is well below 1.0, then the model under predicted actual traffic. If this ratio is well over 1.0, then the model over predicted actual traffic.
Attachment B shows some serious calibration issues. Intertown Road shows .08 for one link and 1.15 for the next link. MDOT’s Build Alternatives are located near Intertown Road. Having such poor calibration results on Intertown Road means the results from the models are questionable. There are other links with poor calibration numbers as well.
6. Trip Generation rates may be based on 30-year old data.
A Trip Generation Model is used to estimate the number of trips from each zone. After the Trip Generation Model is run, the analyst has an estimate of how many trips, but does not know where any of the trips are going, what mode of travel each trip will use, or what route each trip will take. Subsequent models answer these questions.
My understanding, based on a telephone call with the MDOT staff member who did the modeling, is that the trip generation rates are based on a 1978 National Cooperative Highway Research Program Report (NCHRP) called: "Quick-Response Urban Travel Estimation Techniques and Transferable Parameters." Trip generation is the first of four models used. If the trip generation numbers are wrong, then the results from the next three models will be wrong.
While NCHRP Reports are generally well regarded, the trip generation report apparently used by MDOT was published in 1978. The exact language in the report says: "The time period for the survey data is the period between 1965 and 1974 and can generally be thought of as representing an average 1970 condition." MDOT is asking us to believe that survey data that represents an average 1970 condition is valid over a 50-year time (1970 to 2020). Even though it is now 32 years into this 50-year time period, and we have real data from a variety of sources on trip generation rates, MDOT still uses data representing 1970 conditions. MDOT could have conducted surveys in Petoskey to determine trip generation rates or used much more current nationally available data.
In addition, there is a wide variation in trip generation rates that is not taken into account in the transportation modeling process. Trip generation rates are frequently reported as a range of values. Trip generation rates in one area may not be valid in another. Therefore, using trip generation rates from another part of the country may not be valid in Petoskey.
7. MDOT’s Trip Assignments models produced some unrealistic results.
MDOT used both an All-or-Nothing and an Equilibrium Model. An All-or-Nothing assignment model looks at the number of trips that want to go from Zone A to Zone B and assigns all (100 percent) of the trips to one route, usually the shortest or fastest path through the network. Zero trips are assigned to every other possible route. An Equilibrium Model goes through a series of rounds (iterations) to find the mix of assignments that results in the situation where no driver can decrease his or her travel time by changing routes without increasing the travel time for other drivers.
The well-regarded National Association of Regional Councils (NARC) manual on transportation models says: "All-or-nothing (AON) assignment – assigning all traffic between an OD pair to the minimum (shortest; fastest) path through the network – was once widely applied, but is now recognized as being unrealistic and is in declining use." The NARC Manual also says: "Moreover, of all the steps in the four-step travel forecasting process, traffic assignment probably has received the least critical scrutiny from modeling practitioners; default values and procedures typically have been utilized and validation typically has focused only on link volumes."
One good illustration of the problems experienced by MDOT in the Trip Assignment Model appears in the March 1999 Feasibility Analysis of the Intertown-South Alternative. The report states: "Preliminary traffic volume predictions indicate that projected traffic volumes on the Far-South Alternative are expected to be nearly 40 percent higher than the volumes anticipated on the Intertown-South Alternative. These numbers suggest that the commuter traffic that may use the beltway is more likely to use existing US-31 if the Intertown-South alignment is constructed than if the Far-South is constructed." At the time of the study, MDOT was still considering two different alignments in the eastern portion of the Study Area. The 1999 study concluded that the western segment of the Intertown-South Alternative from River Road to US-31 was feasible, but the eastern segment was not. A 40 percent difference between the two beltway alignments is extremely unlikely since the two alignments are relatively close to each other and both alignments run through rural farm areas.
8. MDOT concludes that a beltway close to downtown would divert more traffic than a beltway further away from downtown, but then develops two Build Alternatives that are not near downtown.
Are the models good enough to reach the conclusion that either of the Build Alternatives would meet the goal of Level of Service C or better where possible? I conclude that they are not because the models used to predict future traffic demand are flawed. The Level of Service calculations are then based on predicted future traffic demand.
9. Diversion estimates by MDOT are not likely to be accurate.
MDOT says: "Implementation of the Far-South or Intertown-South Alternative would reduce traffic along existing US-31. Compared to the No-Build Alternative, the Far-South and Intertown-South alternatives are projected to reduce traffic by a range of fifteen to forty percent along various segments of existing US-31."
Given the model problems described above, the estimates of the amount of traffic that would be diverted from US-31 are likely to be wrong. MDOT has not made the case that the Build Alternatives would divert significant amounts of traffic away from US-31.
B. MDOT does not meet the second Study Goal.
MDOT’s second goal is:
"2. Protect the economic viability of existing commerce centers with any new circulation plan that may be implemented, including:
The first part of this goal is to "protect the economic viability of existing commerce centers." Does MDOT think that the Build Alternatives will help achieve this goal?
By continuing to advance the two Build Alternatives, MDOT is asserting that both will meet the four Study Goals. But at other times, MDOT makes statements that cast serious doubt on whether the bypass can help achieve this goal. For example, MDOT says: "Without additional planning measures, development might spread south of Intertown Road" Later in the SDEIS, MDOT says: "To address concerns of secondary and cumulative impacts associated with the Build Alternatives, site-specific measures to control future development activities adjacent to the new road right-of-way would need to be developed with the assistance of local planners and other concerned citizens. Controlled access, proposed by MDOT, is one such measure. This technique would control access along the segments by restricting access to specific existing road intersections. This technique alone, however, would not fully address identified potential secondary and cumulative impacts."
MDOT says: "Communities are responsible for managing growth within their community; however, MDOT has been coordinating the study of the new roadway with local planning officials." If achieving this Study Goal requires land protection ordinances in MDOT’s view, then MDOT should be aggressively researching and promoting such ordinances, or combinations of ordinances so that their benefits and costs are clear.
MDOT notes "…Resort and Bear Creek Townships are directing residential growth to areas where adequate public services and transportation links can best be provided. Generally, this means accommodating development in areas of the townships that are close in to the City of Petoskey." However, MDOT proposed two alternatives for the bypass (Far-South and Intertown-South) that are not close in to Petoskey thereby encouraging leap-frog development — one of the major characteristics of sprawl.
The Office of Planning and Zoning in Emmet County states the concern very clearly: "Avoid conditions that can lead to economic erosion in one part of the area while encouraging new and duplicative economic development in another area."
2. MDOT acknowledges the need for state and local planning tools in the first bullet point of the Study Goal, but is willing to construct the bypass without such tools.
MDOT accepts land protection concepts but makes no commitments beyond promoting them. MDOT feels that land protection concepts are worthwhile, but beyond their control. If they are worthwhile, then the state should actively work to make sure they are in place before construction of the bypass.
Other states have growth management policies and programs in place and there is a growing body of literature on the impacts of these efforts.
3. MDOT’s prohibition on development will just encourage new development to locate on the cross streets.
MDOT plans to prohibit driveways along the right-of-way of the bypass to limit development, but this will not have much impact on developers. The bypass will add traffic and encourage real estate developers to build new projects. MDOT’s prohibition on driveways will simply shift new development onto the cross streets. Developers could easily build major projects along the bypass with the driveways located on the cross streets.
4. Access Management is essential on all arterial roads, not just the bypass.
In our second report prepared for the Michigan Land Use Institute, we defined Access Management as the "policies that control traffic flow between the roadway and adjacent land uses. Roadways provide access to land uses and this access helps the development to occur. Land uses generate the trips that occur on the roads. To be successful, both the roadways and the land uses must be managed. Managing one without the other can lead to more accidents, congestion, delays, and poor service to residents, businesses, and property owners." Pages 11 to 18 of our August 1999 report to the Michigan Land Use Institute describe the objectives of access management, policies to achieve good access management, the need for land use controls and roadway design standards to work together, and related information. We also included some drawings to indicate good and bad design practices.
Access Management in combination with land protection ordinances and other tools will be far more effective than access management alone.
C. MDOT’s Build Alternatives do not meet the third Study Goal of serving as a demonstration that circulation improvements need not create major shifts in land use patterns.
The third goal in Chapter 1 on Purpose and Need says:
"3. serve as a demonstration to other communities in the nation that circulation improvements need not disrupt the economic stability of a community or create major shifts in land use patterns that sever recognized cohesive property units."
MDOT sets a lofty goal of serving as a demonstration to the nation, but then does not provide any real evidence or documentation on how to achieve this goal. Major shifts in development occur when major roads like the proposed bypass are constructed. MDOT never answers the question about how to encourage desirable land use patterns or how to avoid major shifts in land use patterns.
In the third goal for the project, MDOT says: "… circulation improvements need not disrupt the economic stability of a community or create major shifts in land use patterns that sever recognized cohesive property units. (emphasis added) MDOT then defines landlocked parcels by saying: "Landlocked parcels are created when a roadway segment severs existing property lines and splits a parcel in a way that a portion of the parcel is no longer accessible (without crossing another property) from a public road."
MDOT’s Far-South Alternative creates 39 landlocked parcels with a total of about 361 acres. MDOT’s Intertown-South Alternative creates 51 parcels with a total of about 448.6 acres.
2. Transportation and land use are inherently linked. A change in the roadway network will cause a change in land use patterns. A change in land use patterns will cause a change in the roadway network. MDOT fails to adequately account for this link.
One of the fundamental concepts in city and transportation planning is that land use and transportation interact with each other.
The concept that a major change in the transportation network, such as MDOT’s proposed bypass, will cause a change in land use patterns is well known and widely discussed in the transportation planning literature.
Similarly, the concept that a major change in land use patterns, such as a new development, will cause a change in the transportation network is equally well known and widely discussed in the literature.
John D. Edwards, Jr., the editor of the Transportation Planning Handbook says: "Transportation planning is the functional area within transportation engineering that deals with the relationship of land use to travel patterns and travel demands;…" He goes on to say that: "The policies of the Institute of Transportation Engineers (ITE) define transportation planning practice as:
Improving coordination between land use and transportation system planning; providing cooperative interaction between planning, design, and operation of transportation services; maintaining a balance between transportation-related energy use and clean air and water, and encouraging alternative modes of transportation that will enhance energy efficiency while providing high levels of mobility and safety."
Damian J. Kulash, President and CEO of the Eno Transportation Foundation says: "Transportation has influenced each of our choices about where to live, spend vacations, shop, or work. So inescapable is the tie between transportation and society that, like gravity, we take it for granted and cannot imagine a world without it."
Marsha Dale Anderson, President, Street Smarts says: "There has always been a relationship between land use patterns and trip-making characteristics. From the beginning of time, cities were first located near bodies of water where travel and commerce were feasible."
The first sentence in the book by Vergil G. Stover and Frank J. Koepke says: "Throughout history, transportation and land development have been closely bound." The two authors also say: "The transportation system is the basic infrastructure element which influences the patterns of urban development."
According to Frederick Memmott and Charles Guinn, "Our cities are an accumulation of different urban patterns. Each of these patterns was influenced not only by the previous form of the city and by its site, but also by the contemporary economic, social, political, and technological systems of the inhabitants. Within all these patterns, travel has prevailed as a constant condition of urban life."
David Rusk, former Mayor of Albuquerque, New Mexico, makes the point in a short, clear manner. He said: "Transportation problems do not have transportation solutions. They have land use solutions." (italics are in the original)
The Emmet County Planning Commission in an attachment to a 1994 letter to MDOT said: "Place land use concerns on an equal level with transportation, recognizing that land use policy impacts highway capacity/efficiency, and vice versa."
D. MDOT does not meet the fourth Study Goal.
Goal #4 in Chapter 1 says: "4. Maintain compatibility with existing land use patterns and complement future land use master plan."
1. MDOT’s designs for the Far-South and Intertown-South Alternatives require extensive changes to local roads.
The drawings in Appendix A of the SDEIS vividly illustrate the extensive changes that MDOT’s wants to make in local roads. The changes listed below detract from the rural character, which is a widely held value among residents and visitors.
MDOT states: "The Far-South, Intertown-South and Eastern Segments are expected to have substantial localized adverse effects on surficial geology." Later in the same paragraph, MDOT says: "However, due to the northwest to southeast orientation of the drumlin field located predominately west of US-131, and the generally east-west orientation of both the Far-South and Intertown-South segments, construction of the road would require cuts into the drumlins and filing of the adjacent valleys." Webster’s Dictionary defines a drumlin as: "an elongate or oval hill of glacial drift."
MDOT estimates that 3.3 miles out of a total of 9.5 miles (35 percent) in the Far-South Alternative would require "moderate to substantial cut and fill." For the Intertown-South Alternative, 3.1 miles out of a total of 10.0 miles (31 percent) would require "moderate to substantial cut and fill."
3. The length of cleared woodland is significant and it will change the rural character.
MDOT estimates that 2.8 miles out of a total of 9.5 miles (29 percent) in the Far-South Alternative would require cleared woodland. For the Intertown-South Alternative, 2.8 miles out of a total of 10.0 miles (28 percent) would require cleared woodland.
MDOT says: "The Far-South Segment, however, is not consistent with the Resort Township Comprehensive Plan, prepared in 1996, which does not favor construction of a "beltway."
Table 5.10-1 in the SDEIS makes it clear that MDOT expects that the Build Alternatives will create major changes to the development potential around intersections with the Build Alternatives. The table summarizes the residential and commercial development potential using scores of high, medium, or low for each segment of the proposed Build Alternatives.
For the Far-South and Eastern Segments, the table lists 17 intersections. Of the total of 17 intersections:
For the Intertown-South and Eastern Segments, the table lists 15 intersections. Of the total of 15 intersections:
It is well known that increasing accessibility increases development potential. By providing greatly increased accessibility in a rural area, MDOT is greatly increasing the development potential, especially around intersections. This is contradictory to both the long-range plans prepared by Resort and Bear Creek Townships. MDOT itself says: "… Resort and Bear Creek Townships are directing residential growth to areas where adequate public services and transportation links can best be provided. Generally, this means accommodating development in areas of the townships that are close in to the City of Petoskey." Neither Build Alternative meets the criterion of being close in to the City of Petoskey.
IV. ALTERNATIVES
A. MDOT unfairly rejects the Smart Roads: Petoskey proposal.
Smart Roads: Petoskey is a viable alternative. It responds to the problems in the area with transportation and land use recommendations. It provides roadway capacity that is similar to the capacity that MDOT provides with its Build Alternatives. The recommendations in Smart Roads: Petoskey are much less disruptive to the rural community and the environment than MDOT’s Build Alternatives. The construction costs and time are much less for Smart Roads: Petoskey. Smart Roads: Petoskey also includes land use elements.
MDOT rejected the Smart Roads: Petoskey proposal for several reasons.
1. Smart Roads: Petoskey is substantively different from the Optimized Local Road Improvement Alternative.
Smart Roads: Petoskey includes both transportation and land use elements. By including land use elements, Smart Roads: Petoskey is substantively different than the MDOT Build Alternatives.
The transportation elements are:
The importance of working with both transportation and land use is documented earlier in these comments with quotes from several experts.
MDOT’s list of elements in the Optimized Local Road Improvement Alternative are:
There are significant differences between the Optimized Local Roads Alternative and Smart Roads: Petoskey.
Because of these differences, I conclude that MDOT was wrong to conclude that the Optimized Local Road Alternative and Smart Roads: Petoskey have "many similarities" and therefore, "MDOT deemed that the alternatives were not substantively different to merit further traffic modeling and detailed analysis."
2. Smart Roads: Petoskey can provide congestion relief to US-31.
Smart Roads: Petoskey has an Express Route and an arterial grid to help diffuse traffic across the roadway network. It provides a roadway capacity that is similar to the capacity of the Build Alternatives. It also has upgraded intersections along US-31, computer-controlled signals along US-31 to change signal timing in real time, a Summer Truck Route, a Summer Bus Shuttle Service, access management, and land protection provisions, all of which will help to reduce congestion along US-31. The transportation and land use recommendations in Smart Roads: Petoskey are not radical or unusual. They have been used in other areas in the United States with success.
MDOT expresses concern that New Alternatives, Inc. did not develop engineering drawings for the Express Route part of the Smart Roads: Petoskey plan.
My understanding of the intent of federal law on environmental impact statements is to encourage widespread public dialogue and a full and comprehensive consideration of viable alternatives and their potential environmental impacts. If MDOT requires engineering drawings before they will consider any alternative other than the ones that they develop, then they are setting such a high standard that few citizens will be able to offer suggestions. Requiring engineering drawings from citizens seriously undermines the intent of the law in terms of public dialogue, and a careful analysis of all viable alternatives. Expecting a citizen to be an engineer or to obtain engineering assistance before seriously considering an outside alternative is an unrealistic expectation by MDOT.
The best solutions come from a free exchange of ideas and in a process where people with different experiences and skills can contribute to the final design. No one person or agency has all the good ideas. Reworking alternatives to account for new ideas is healthy and leads to a much better final recommendation.
Although I am the person primarily responsible for developing the Smart Roads: Petoskey alternative, I accepted input from many people in a variety of forms. I know that Smart Roads: Petoskey contains ideas from many sources and is better because of it. We have incorporated ideas that work successfully in other areas dealing with similar problems.
The Express Route in the Smart Roads: Petoskey alternative uses a 66-foot right-of-way width. There are thousands of rural roads that use the same roadway width.
4. Smart Roads: Petoskey is a prudent and feasible alternative.
Webster’s Dictionary defines prudent as "characterized by, arising from, or showing prudence; as a: marked by wisdom or judiciousness b: shrewd in management of practical affairs c: marked by circumspection : discreet d: provident, frugal"
Smart Roads: Petoskey is prudent because it creates an arterial grid of roads to handle both north-south and east-west traffic. Unlike MDOT’s Build Alternatives, it does not create landlocked parcels. It includes a Summer Truck Route and a Summer Shuttle Bus Service to reduce tourist traffic during the peak months. It respects the rural character of the area to a much better degree than the MDOT Build Alternatives. It includes land protection provisions. It can be implemented more quickly and at a much lower cost than the MDOT Build Alternatives.
3: REASONABLE, LIKELY"
Smart Roads: Petoskey is feasible because similar rural roads exist throughout the United States and there are thousands of miles of similar roads. Smart Roads: Petoskey provides similar roadway capacity to the MDOT Build Alternatives for less cost. Smart Roads: Petoskey can be constructed in phases.
B. Smart Roads: Petoskey is substantively different from the MDOT’s Build Alternatives.
The Comparison of Alternative Proposals and Land Use Regulations report that we prepared for the Michigan Land Use Institute documents the differences between Smart Roads: Petoskey and MDOT’s Far-South and Intertown-South Alternatives. After we completed our report, MDOT determined that the Click and Cedar Valley segments of Intertown-South are not feasible and developed the Eastern Segment Alternative, which is common to both of MDOT’s Build Alternatives.
There are five especially significant differences between the MDOT and Smart Roads: Petoskey alternatives.
MDOT’s Build Alternatives do not meet the four Study Goals developed for the Petoskey Area Improvement Study.
MDOT did not conduct a full and fair comparison of Smart Roads: Petoskey even though it is a prudent and feasible alternative.
As described above, there are serious flaws in the SDEIS. These flaws should be corrected. The proposed bypass represents a major investment, so MDOT has the obligation to demonstrate to the public that such an investment is a good one.
2 US-31 Petoskey Area Improvement Project, Draft Environmental Impact Statement and Section 4(f) Evaluation, July 1994.
3 The Community Design Work on Transportation Issues was held on May 15, 1999 and the Community Design Workshop on Land Use and Environmental Issues was held on June 5, 1999.
4 SDEIS, Page 2-4.
5 SDEIS, Figure 3.2-8 on Page 3-14.
6 SDEIS, Page 2-4.
7 SDEIS, Page 2-7.
8 Arthur B. Sosslau, Amin B. Hassam, Maurice M. Carter, and George V. Wickstrom, Comsis Corporation, "Quick-Response Urban Travel Estimation Techniques and Transferable Parameters – User’s Guide," National Cooperative Highway Research Program Report 187, Transportation Research Board, National Research Council, 1978.
9 The other three are trip distribution, mode split, and traffic assignment.
10 Arthur B. Sosslau, Amin B. Hassam, Maurice M. Carter, and George V. Wickstrom, Comsis Corporation, "Quick-Response Urban Travel Estimation Techniques and Transferable Parameters – User’s Guide," National Cooperative Highway Research Program Report 187, Transportation Research Board, National Research Council, 1978, Page 9.
11 Greig Harvey and Elizabeth Deakin from Deakin Harvey Skabordonis with Cambridge Systematics, COMSIS, Dowling Associates, Gary Hawthorn Associates, Parson Brinckerhoff Quade & Douglas, and Ann Stevens Associates, "A Manual of Regional Transportation Modeling Practice for Air Quality Analysis, National Association of Regional Councils, Version 1.0, July 1993, Page 3-66. Note that OD stands for origin-destination, i.e., the origin travel analysis zone and the destination travel analysis zone.
12 Ibid., Page 3-63.
13 US-31 Petoskey Area Improvement Project, Feasibility Analysis of the Intertown-South Alternative, Prepared for Michigan Department of Transportation, Prepared by JJR Incorporated, March 1999.
14 Ibid., Page 2-10.
15 SDEIS, Page 3-23.
16 SDEIS. Page 3-11.
17 SDEIS, Page 2-4.
18 SDEIS, Page 6-11.
19 SDEIS, Page 5-75.
20 American Planning Association, Growing Smart Legislative Guidebook – Model Statutes for Planning and the Management of Change, Phase I and II – Interim Edition, September 1998.
21 SDEIS, Page 7-21.
22 SDEIS, Page 5-67.
23 SDEIS, Appendix H Page 3 in a letter from Max R. Putters, Office of Planning and Zoning to Mr. Andrew Zeigler of the Michigan Department of Transportation, dated September 22, 1994.
24 New Alternatives, Inc. "Transportation and Land Use Proposal," Petoskey Alternative Transportation and Land Use Project, Prepared for the Michigan Land Use Institute, August 1999, Page 11.
25 SDEIS, Page 1-2 and Page 2-4.
26 SDEIS, Page 1-2 and Page 2-4.
27 SDEIS, Page 5-69.
28 SDEIS, Pages 5-69 and 5-71. There are 19 landlocked parcels containing 114 acres for the Far-South Segment plus 20 parcels containing 246.6 acres for the Eastern Segment. There are 31 landlocked parcels with 202 acres for the Intertown-South Segment plus 20 parcels containing 246.6 acres for the Eastern Segment.
29 John E. Edwards, Jr., Editor, "Introduction to Planning," Transportation Planning Handbook – Second Edition, Institute of Transportation Engineers, 1999, Page 1.
30 Damian J. Kulash, "Transportation and Society." Transportation Planning Handbook – Second Edition, John E. Edwards, Jr. Editor, Institute of Transportation Engineers, 1999, Page 4.
31 Marsha Dale Anderson, "Urban Travel Characteristics." Transportation Planning Handbook – Second Edition, John E. Edwards, Jr. Editor, Institute of Transportation Engineers, 1999, Page 58.
32 Vergil G. Stover and Frank J. Koeopke, Transportation and Land Development," Institute of Transportation Engineers, Prentice Hall, 1988, Page 1.
33 Ibid., Page 3.
34 Frederick W. Memmott and Charles Guinn, "Transportation Planning – Streets, Highways, and Mass Transportation," William I. Goodman and Eric C. Freund, Editors, Principles and Practice of Urban Planning, Published for the Institute for Training in Municipal Administration by the International City Managers’ Association, 1968, Page 137.
35 David Rusk, "Inside Game Outside Game – Winning Strategies for Saving Urban America," Brookings Institute Press, 1999, Page 289 (italics are in the original)
36 SDEIS, Appendix H, Attachment to a letter from Mr. Max R. Putters, Office of Planning and Zoning, County of Emmet, to Mr. Andrew Zeigler, Michigan Department of Transportation, Project Planning Division, September 22, 1994. The attachment is entitled: "Petoskey Area Beltway Project – Response to the Preliminary E.I.S. – A Modified Plan Approach," September 12, 1994, Page 1.
37 SDEIS, Page 1-2 and Page 2-4.
38 US-31 Petoskey Area Improvement Study, Supplemental Draft Environmental Impact Statement and Section 4(f)/6(f) Evaluation, Prepared by the U.S. Department of Transportation, Federal Highway Administration, Michigan Department of Transportation, August 2001 (SDEIS). Page 5-1.
39 Ibid., Page 5-1.
40 Merriam Webster’s Collegiate Dictionary, Tenth Edition, 1995.
41 Ibid., Page 5-53.
42 Ibid, Page 5-53.
43 SDEIS, Page 5-45.
44 SEDIS, Page 5-70.
45 SDEIS, Table 5.10-1, Page 5-70.
46 SDEIS, Page 5-67.
47 SDEIS, Page 3-23.
48 SDEIS, Page 7-20. LRIA is the Optimized Local Roads Improvement Alternative.
49 SDEIS, Page 3-24.
50 SDEIS, Page 7-20.
51 SDEIS, Page 3-21.
52 SDEIS, Page 3-23.
53 Merriam Webster’s Collegiate Dictionary, Tenth Edition, 1995.
54 Merriam Webster’s Collegiate Dictionary, Tenth Edition, 1995.
55 New Alternatives, Inc. "Comparison of Alternative Proposals and Land Use Regulations," Prepared for the Michigan Land Use Institute, May 2000, Transmittal Letter, Pages I and II.
