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Missouri Sierra Club Comments for Truck Only Lanes on I-70
June 29, 2009
Ms. Peggy Casey
Federal Highway Administration
3220 W Edgewood, Ste H
Jefferson City, Missouri 65109
Mr. Kevin Keith
Missouri Department of Transportation
PO Box 270
Jefferson City, Missouri 65102
Executive Summary: Based on our review of the Final SEIS, a Record of
Decision supporting TOLs as the preferred alternative for I-70 is not
justified.
The Sierra Club is pleased to submit these comments on the Final
Supplemental Environmental Statement (SEIS) for reconstruction of
approximately 200 miles of I-70 in Missouri. We have been involved in
this study almost from the beginning, and that involvement included a
special meeting of Mr. Kenny Voss of MoDOT and Mr. Steve Wells of the
consultant team with the Sierra Club’s Missouri Chapter Conservation
Committee in Parkville, Missouri, on July 12, 2008.
We note that our comments on the Draft SEIS, dated March 16, 2009,
have been incorporated into Technical Memorandum 4 of the Final SEIS,
pages 36-40. We also note that you have responded to some of the
concerns we expressed. While the Final SEIS is improved in some
respects in response to our earlier comments, we consider many of your
responses to be simply repetition of what was already in the document,
and thus still inadequate.
Here are our specific comments and ongoing concerns related to the Final SEIS.
1 - Our Comments on the FTEIS. These comments build on comments that
we submitted on September 25, 2001, in response to the First Tier
Environmental Impact Statement (FTEIS). We have reviewed those
comments, we consider them to be still valid and relevant, and thus we
ask that you consider them here as well.
http://www.improvei70.org/downloads/ROD%20Appendix%20ltr7.pdf
2 - Existing Record of Decision. In response to the FTEIS, USDOT
issued a Record of Decision (ROD) on December 18, 2001, identifying
the preferred alternative as a six-lane highway with a wide median.
At the time we opposed that alternative on the grounds that it would
constitute excess capacity for several sections of the route, because
we believed the study had not given adequate consideration to
non-highway alternatives for moving people and goods, and because we
believed the study had ignored emerging major issues related to rising
energy prices (and consequent implications for mode choice for moving
both people and goods) and global warming.
Our response to the Final SEIS is much the same. The truck-only lanes
(TOL) concept is not compatible with a strategic view of future
transportation needs in an age of global warming and rising energy
prices. It is especially not compatible with the era of severe fiscal
challenges – e.g., budget deficits and national indebtedness – that we
have entered.
3 - A Major Disconnect. The Final SEIS recommends truck-only lanes
(page 6-2): “The study team recommends implementing the Truck-Only
Lanes Strategy as the Preferred Alternative.” However, the Final SEIS
also states (page 6-4) that, “…there is no empirical data available to
know how effectively this type of facility [i.e., the TOL concept]
will function.”
How can these two statements be reconciled? How can the TOL concept
be the new preferred alternative if there is no empirical evidence
that it will even work?
Consequently, we believe that a ROD identifying the TOL concept as the
preferred alternative is not justified.
4 - The Four-State Context. The current SEIS has been funded by a
special grant to Missouri under the USDOT “Corridors of the Future
Program.” The Missouri segment of I-70 is part of a 789-mile stretch
of I-70 across Missouri, Illinois, Indiana, and Ohio that is the
subject of a study to be led the Indiana DOT. We understand that the
four states finally reached agreement on how to proceed with that
study in January, 2009, less than five months ago. The TOL concept in
Missouri would have significantly less utility in the nation’s
transportation system if it is not part of a longer corridor. Thus,
we submit that a ROD in support of the TOL concept in Missouri would
be premature until the four-state study is completed.
5 - A Global Context of Profound Change. The world has changed
profoundly since the FTEIS was initiated in 1999, and it is likely to
change even more profoundly in the years ahead.
5a - There is vastly increased awareness of global warming and the
consequent need to reduce greenhouse gas emissions by reducing
consumption of carbon-based fuels, in part by using more
energy-efficient modes of transportation. This will be further
affected by fees or taxes on carbon-based fuels in the near future.
5b - There is increased awareness of the fossil fuel supply challenges
that lie ahead as easily recoverable petroleum reserves are depleted,
and increased awareness of the long-term upward trend in energy
prices.
5c - There is a global financial crisis that affects everything.
(It’s useful to note that MoDOT Director Pete Rahn quotes Microsoft
CEO Steve Ballmer in describing the current recession as a time of
“resetting.” We agree, and believe this resetting must include a
re-examination of all previous assumptions about the future, including
how the nation meets its transportation needs.)
5d - In brief, never has the past been such an inadequate and
unreliable predictor of the future.
Given these factors, it is reasonable to expect that future movement
of people, and especially goods, will be significantly less than past
projections have indicated. As transportation energy costs rise, one
natural response will be to shift manufacturing closer to markets.
That’s not to say that fewer tons of freight will be moved – even
though that might also be anticipated due to changes in social norms
and expectations regarding what constitutes a good quality of life –
but rather to suggest that ton-miles of freight movement will
decrease. It is also reasonable to expect that more long-distance
freight will move by more energy-efficient modes such as rail, and
less by truck. Trucks may continue to move products the final few
miles, but more of the total miles will likely be by other modes.
Thus, it is reasonable to anticipate a national commitment to a
public-private partnership with the nation’s railroads to remove rail
bottlenecks and add capacity in order to improve the reliability of
freight rail as part of the next Federal transportation authorization
bill.
The point is, conclusions reached in the FTEIS based on then-current
expectations and projections – from the late 1990s – are no longer
valid. It is not prudent to recommend a TOL facility that has the
effect of making marginal improvements in the performance of an
inherently less efficient mode of transportation (i.e., trucks) rather
than investment to improve the reliability and speed of an inherently
more energy-efficient mode (e.g., rail).
6 - The Range of Alternatives Is Deficient. The FTEIS considered
seven alternative strategies:
1 – No Build
2 – TSM/TDM
3 – Widen Existing I-70
4 – New Parallel Facility
5 – New Parallel Toll Road
6 – High-Occupancy Vehicle Lanes
7 – High-Speed Passenger Rail
Note that passenger rail was considered, but that freight rail was
not. Note also that a parallel roadway facility was considered. By
now considering a separate facility for trucks, the SEIS shifts the
focus toward freight movement, but it does not give renewed
consideration to other strategies for accommodating freight movement
in the broader Kansas City to St. Louis corridor, specifically,
strategies for diverting freight from I-70 to other modes on
facilities in the corridor. Such strategies should include, at
minimum, increased rail capacity in the corridor, as well as highway
capacity management strategies (e.g., differential speed limits and
lane restrictions). Thus, the range of alternatives considered by the
SEIS is deficient.
7 - Opportunity Costs. We are concerned about two major kinds of
opportunity costs – land and financial.
7a - Opportunity Costs – The Median as a Resource. If truck lanes are
built in the extra wide median of a reconstructed I-70, that median
would no longer be available for freight or passenger rail, or for any
another mode of transportation. (MoDOT's Chief Highway Engineer told
us with optimism some ten years ago that the wide median would be
available for some yet-to-be identified mode of transportation.)
Truck lanes don't measure up. High-speed passenger rail may or may
not be feasible in the near term, but it should not be ruled out. The
need for added capacity for freight rail across Missouri is certainly
evident, and even if it’s not built entirely within the 200 miles of
the median, there is potential for combining sections of the median
with existing rail lines to create a new high-capacity cross-state
rail corridor. That option needs to be considered.
7b - Opportunity costs – The money. With the Congressional “bailout”
of the Highway Trust Fund last year, and with the inclusion of highway
spending in the American Recovery and Reinvestment Act, it should be
evident that highway users no longer pay the full cost of the nation’s
highway system: a highly symbolic line has been crossed when general
revenues are allocated to highways. When highways become even partly
dependent on general revenues, they must compete with every other
governmental purpose. This is especially significant in a time of
unprecedented budget deficits, a national debt that now far exceeds
$10 trillion dollars, and a global warming crisis on the horizon that
will require very significant investment in money and resources – or,
more precisely, a very different investment of money and resources.
The added $500 million it would likely cost to build the TOL concept
for I-70, compared with the six-lane concept, has to be considered in
the context of the following question: What other use of half a
billion dollars might make Missouri / the United States more
energy-efficient, less reliant on foreign petroleum, and better
prepared to mitigate or adapt to climate change?
8 - SEIS Scope is Too Narrow. The SEIS has the same deficiency as the
earlier FTEIS in that it construes “environment” too narrowly. These
studies have treated “the environment” as the footprint of the
project, plus adjacent residents, businesses, and land. The studies
do not consider the incremental impact of the proposed project on the
broader regional environment – such as residents living within earshot
of the highway and thereby subject to increased noise, along with air
emissions from the higher levels of traffic that would carried. Nor
do they consider the impacts of energy use and greenhouse gas emission
on the global environment. (There is a discussion of energy and
related issues on pages 4-19 thru 4-20, but it is superficial and
speculative in nature – a pro forma consideration that is subsequently
ignored.) Reasonable consideration of these latter factors would
indicate a much more rigorous study of the modal alternatives that the
FTEIS summarily dismissed as inadequate.
9 - Safety – Benefits of Separation are Over-stated. Separating
trucks from cars is a very appealing feature of the TOL concept to
motorists, many of whom have felt intimidated by trucks. While the
overwhelming majority of truckers observe the speed limit, a few drive
well over the posted speed. The SEIS claims that separation will
improve traffic safety (page 2-10): “(The TOL concept provides a
greater improvement in safety) due mostly to the separation of trucks
from general-purpose traffic that in turn reduces the frequency of
crashes resulting from truck-car conflict points.” We submit that
this is a serious flaw in reasoning. The SEIS identifies only three
interchanges out of 56 that would have separate truck access ramps
initially, with such ramps potentially justified at six others.
Access to the 53 other exits would be via “slip ramps” whereby trucks
would cross general purpose lanes and use the general purpose access
ramps. The SEIS further indicates (page 3-7) that several exits might
be served by a single set of slip ramps. The SEIS also appears to
underestimate the level of use of such slip ramps as trucks make stops
for refueling, food, and driver rest periods. Trucks would make
dangerous moves across general purpose lanes during which cars would
be in the truck driver’s “blind spot.” Thus, the actual separation of
trucks from cars will be significantly less than indicated in
promotional material. In effect, trucks will have a separate facility
and cars will still be in mixed traffic.
10 - Safety – Truck Speed Differentials. Furthermore, the SEIS gives
no apparent consideration to the speed differential between trucks and
cars, or between trucks operated by different companies. Several
major trucking companies – YRC and Schneider National, to name just
two – limit their trucks to 60 or 62 mph by company policy as a fuel
conservation measure. Conflicts between 60 mph trucks crossing a
stream of 70+ mph cars to reach an exit constitute a serious danger
that cannot be denied.
11 - Safety – Strategies Not Considered. Reducing truck-car conflicts
is a desirable goal, but the SEIS considered only a separate facility
alternative. The SEIS is seriously deficient in that it did not
consider strategies for achieving that end as part of the six-lane
alternative, such as a mandated lower speed limit for trucks, vigorous
enforcement of truck speed limits, and restricting trucks to the outer
lane except when passing. This strategy is used in Illinois and other
states.
12 - Operating Costs. The SEIS estimates the annual operation and
maintenance cost of the TOL concept at $12 million, compared with $10
million for the six-lane concept (Figure 2-5, page 2-9). O&M includes
factors such as pavement maintenance, snow renewal, and pavement
sweeping – costs that are directly related to pavement surface. We
estimate total pavement surface to be at least 50 percent greater for
the TOL concept (considering that there will be additional shoulder
width as well as the slip ramps) than for the six-lane concept, and
thus the difference in O&M costs would likely be greater.
13 - Natural Environment -- Wildlife. Unlike the Draft, the Final
SEIS acknowledges a concern about wildlife (page 4-21): “There is
concern about the increasing animal mortality rates (e.g. white-tailed
deer) due to vehicular traffic, and the resulting property damage and
potential animal and human injury that can occur. The median barrier
separation between opposing directions of truck traffic proposed
within the Truck-Only Lanes Alternative results in a barrier to
wildlife crossings.” We consider the revised discussion to still be
inadequate as it downplays the human consequences of increased crashes
involving deer or other animals colliding with vehicles. As we stated
in our March 16 comment, some percent of such collisions result in
human injury or fatality, and additional crashes occur as vehicles
swerve to avoid hitting wildlife.
14 - Natural Environment – Water quality. The SEIS identifies no
additional impacts on water quality, even though runoff will be
increased owing to the 50 percent or more increase in pavement surface
for the TOL concept compared with the six-lane concept: eight travel
lanes plus four sets of left and right shoulders compared with six
travel lanes plus two sets of left and right shoulders.
15 - Indirect and Cumulative Impacts. The SEIS discusses indirect and
cumulative impacts (pages 4-23 thru 4-26) in a superficial and
speculative manner. The discussion might be characterized as, “Yes,
there probably are some indirect and cumulative impacts.” That
discussion is inadequate.
16 - Format of the SEIS. The format of the SEIS biases the reader to
favor the TOL concept being studied. The SEIS is presented in an
attractive format – perhaps overly attractive. When such a study is
presented in this manner it’s easy to conclude that its purpose is to
promote the TOL concept as much as to evaluate it. There are
illustrations of how slip ramps are intended to function, for example,
but there are no illustrations of the truck-car conflicts that will
occur during actual operation as slower-moving trucks merge across
general purpose lanes to get to and from on/off ramps. The
appendices, including a promotional video, are included on a CD
included with the study document. This presents accessibility
problems to anyone not having access to a computer. In addition,
there is no table of contents (other than the one-line titles on SEIS
TOC) for the various technical memoranda on the CD. Thus, it’s
necessary to scroll through each of the TMs in search of detail that
might or might not be there.
17 - Public Comments. We note that the SEIS employed several
strategies for getting public comments during the study, and that it
is significantly better than the FTEIS in making public comments a
part of the record. We appreciate that because we believe it is
essential that the public gets to learn what the rest of the public is
saying. An online comment period was provided during September, 2008,
and the Sierra Club cooperated by providing a link to that site from
our home page:
http://missouri.sierraclub.org/FrontPage2008/trucklanes.htm
18 - A Notable Public Comment. We call your attention to one very
thoughtful online comment (Draft SEIS TM4, pages 78-79). We don’t
know who submitted it, and we don’t know if it was submitted as a
formal comment on the SEIS, but we believe it deserves full
consideration as if it were submitted as such.
“Thank you for putting your I-70 Truck-Only-Lanes-across-Missouri
study on your website and thereby making it easier for the public to
comment on it. However, your Question #6 above doesn’t provide enough
options to choose from.
“A few years ago MoDOT received a Record of Decision approving its
recommendation in its First Tier Environmental Impact Statement"
(FTEIS) favoring rebuilding I-70 as a six-lane highway. Your new study
apparently rejects that ROD. However, I am not convinced that in spite
of the $2 million FHWA grant to study the feasibility of Truck-Only
Lanes across Missouri, that your Supplemental Environmental Impact
Statement has justified overturning your previous conclusion, nor that
this new SEIS is an adequate procedure for doing so. For one thing,
you have not addressed the impact of the more extensive amount of
pavement, nor the impacts of encouraging proportionately more
big-truck traffic on Missouri’s highways, bridges and roads. Although
most folks would rather not have to share the highway with huge
trucks, they may agree with me on the following reservations about
your proposed Truck-Only Lanes:
-- Your proposal doesn’t really separate trucks from cars at the most
dangerous points, where trucks are changing lanes in order to enter or
exit the highway. The same problem would occur if you put the car
lanes in the middle rather than the outside lanes unless you provided
entirely separate entrance and exit ramps for cars and trucks. But
this would be even more expensive than what you are proposing, which
itself is extremely expensive ($3.4 billion).
-- That brings up my next question: Who is going to pay for this? At a
time when taxpayers are being asked to go into another $10,000 of debt
per family to bail out the consequences of stock and bond
mismanagement, on top of the debt we have already assumed during the
last 5 years of war, it is asking a lot from taxpayers to also pay
(and/or go further into debt) to bail out the mistakes of highway
planners who willy-nilly built and expanded highways at the behest of
suburban and ex-urban land-development interests rather than putting
aside funds for maintaining the bridges and highways we already had,
and rather than implementing strategies that would encourage smart
growth. Even though tens of millions of dollars per year were moved
from Missouri’s general revenue to its highway building fund starting
in 2005, we are again at a point where Missouri legislators are
proposing an increase of 1% in the sales tax to pay for rebuilding
I-70 and I-44. Such a sales tax would be collected statewide, but the
“benefits” would be much more narrowly focused. Truckers already do
not pay their fair share, based on the damage they do to the roads.
They should be asked to pay for separate Truck-Only Lanes, by
increasing weight fees and paying tolls for all or most of the cost.
-- Your original FTEIS gave short shrift to including rail in the I-70
corridor. Now, incredibly, even though the focus of your replacement
plan is on moving freight, and even though the cost of truck fuel has
doubled or tripled, your new SEIS still gives short shrift to rail.
Rail is widely acknowledged to be far more energy- and
resource-efficient than trucks. Given the challenge of “Climate
Chaos,” which is linked to increasing levels of carbon dioxide in the
atmosphere (a direct result of burning fossil fuels for transportation
and other purposes), I urge you to re-do your study to give adequate
attention and priority to increasing freight rail across Missouri. I
also urge you to revisit your projections of demand for long-distance
freight. Future public policies that address Climate Chaos may
encourage more local production of goods and thus less demand for
long-distance freight.”
19 - Closing Note. At the eastern edge of Pulaski County, just south
of Interstate 44 and near the ghost town of Hooker, there’s a
three-mile segment of Historic Route 66. It’s a four-lane divided
highway built in the pre-interstate years, and has since been
downgraded to a supplemental highway identified as Route Z. It’s
essentially a highway to nowhere. If Missouri embarks on building
TOLs on I-70, it will likely have fragments of “truck-only lanes to
nowhere” because it’s unlikely that the entire 200 miles will ever be
completed.
Thank for this opportunity to submit comments on the Final SEIS for
I-70. We ask that these comments be incorporated into the Record of
Decision.
Sincerely,
Virginia Harris, Chair
Missouri Chapter, Sierra Club
7164 Manchester Road
St. Louis, Missouri 63143
cc: Great Rivers Environmental Law Center
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