Monday, February 4, 2013

February 2013

This week, WSDOT is unveiling a new plan for adding  westbound lanes as 520 comes from the east into Montlake, without providing any mitigation to nearby communities.  This plan is worse than we expected. 

What is WABN?

Because WSDOT does not have funding to complete the full expansion of 520 to I-5, they now plan to build a new bridge across Union Bay and into Seattle.  This bridge is  called WABN, or West Approach Bridge North.  It will be much wider and higher than the existing bridge, and will carry 520 westbound traffic into Montlake.   The existing bridge will remain in place, and will carry eastbound traffic.  So there will be two bridges, one much higher than the other, across the water near the delicate wetlands, until funding is found to complete the project.   Funding will probably require taxpayer approval, and may not come for decades.

WABN doubles the number of lanes coming into the Montlake-520 intersection without providing any relief to the city streets.  It has a very complicated pattern of stopsigns and stoplights, and we expect that the intersection simply won't be able to carry the volumes that are coming into it.


Here are the only two drawings so far available of WABN.





  Our analysis
-  WABN will last until funding is found to expand 520 from Montlake to Seattle.  This will be at least a few years, and could be 10  years or 20 years.  

- WABN puts all the 520 traffic on Montlake Blvd, without providing Seattle any funds to improve or expand the boulevard.  The intersection of 520 and Montlake  Blvd is already so congested that it is defined as a "failed" intersection (one that can't handle the traffic going through it), and WABN will make it much worse.
    (WSDOT says that the intersection won't get more traffic; but why is the state spending hundreds of millions of dollars if the expansion here is not needed?   It is impossible to believe that the proposed changes will not lead to more congestion.)

- It is already very difficult to walk or bike through this intersection, and no plans are shown to make it better, so the additional lanes will make it worse.  WSDOT admitted today that bike and pedestrian movement "needs work".  But such work is not planned or funded. 

- It will be very difficult  to get into the Shelby- Hamlin area and the neighborhood near East Lake Washington Blvd.

- Expanding East Lake Washington Blvd to carry more lanes of traffic turns a residential area into a freeway on/off ramp directly in front of residences, while removing trees that currently protect them.

- We believe that the new traffic flows and the additional stoplights will increase the backups on eastbound 520 all the way from Montlake  to I-5, and that Montlake Blvd will be so congested that the traffic snarls will back up onto Capitol HIll, Eastlake, the University DIstrict, Wedgewood, and Laurelhurst.... thus making walking and biking more difficult.    A large segment of dense neighborhoods will be harmed.

- WABN is quite different from what was shown in the EIS, which is supposed to be the controlling document.  There are big changes.  Among other things, the EIS promises that mitigation will be an integral part of constructing each area, but all mitigation is removed here.   There is no lid at Montlake and no noise reduction is promised.   

Our comments to elected officials
- WABN does all the damage to the communities nearby without any of the promised mitigation.  There is no lid at Montlake, and no noise abatement is promised except on the WABN bridge itself.
WABN should not be built until there is a full design and full funding from the highrise to I-5, and that the full design must include  bike/ped/greenway travel as well as funding for improving the Seattle surface street traffic flow.

- If WABN is built in spite of its flaws, the Coalition strongly urges that there be immediate noise abatement on the whole west side.  This noise reduction should take place immediately,  without waiting for funding the rest of the 520 expansion.  It should include enforcement of the 45 mph speed limit starting at the highrise all the way to I5, as  promised in the EIS, noise buffering on the sides of and under the highway,  new pavement, and other techniques recommended by the expert panel on noise.

- WSDOT must fund all the work to un-do the damages it is causing: restore and improve bike/ped connections and greenways, improve traffic flow, and above all, reduce noise.

- WABN is  WSDOT creating problems for the city and taking no responsibility for them; reducing livability of healthy communities; and dstroying the environment, to no advantage.   

Tuesday, February 14, 2012

August 2012

August 2012: Lawsuit lost, efforts renewed
A message to our supporters:
Judge Ricardo has ruled in favor of WSDOT.  He pretty much dismissed our claims.  We lost.

We lost that lawsuit, but the cause is still worth our efforts.  We are working to prevent huge harm to our communities and to the waterways and shorelines which attracted us here and which support so many outdoor activities.   We are working to have neighborhoods where everyone can walk without danger and breathe without more pollutants, and can navigate local traffic without constant congestion. We are working to prevent the state from squandering money on an expansion which will only move the traffic jams.  

The support from the communities has been fantastic.  Literally hundreds of people have given money and time to get us this far.  Huge thank-you’s to each of you! We will need your continuing support to counteract the falsehoods and foolishness that are coming at us.

520 is still far from a done deal, and the state is changing what was presented to us.  The state still has no way to get the $2 billion necessary to build the west side.  We expect the state to announce shortly that they have received a stimulus grant to do the Lake to Land project…putting through more lanes into Montlake without planning for local traffic, without the lid and without mitigation.  This is very different from the plan described in the environmental documents.   Putting the Portage Bay bridge north of its current location is also a big change from what was disclosed.  So we have urgent issues to work on.    

Back to the federal lawsuit: you can find the judge’s decision here.  I am personally surprised by it.  It puts great weight on the number of documents and the number of pages which WSDOT submitted.   It repeats WSDOT’s arguments at length.  And it does not address our claims except in a few dismissive sentences.   It’s a disappointing document. 
We now have to decide whether to appeal that ruling to the 9th circuit.  I’d be interested in your thoughts… and if we appeal, we will need considerably more money.   We will also need to oppose changes which make the 520 plans even worse.   So we will continue to be in touch!

Fran Conley

July 2012: Legal briefs are exchanged
The process used for the Coalition's federal lawsuit is several exchanges of briefs, then oral arguments in front of the judge on July 10, then the judge's decision.  The facts are derived from the written record, with no experts or verbal testimony.  Here are the briefs so far; just click on them to read them. 

Here we outline the ways in which WSDOT and FHWA violated federal 
and state law, and ask the judge to stop the project.  
Here WSDOT outlines the process it has gone through,
 and maintains that it was adequate. 
Here the FHWA outlines the process and says why it thinks it was adequate. 

Coalition's Reply Brief, June 16 
 Here we go into more detail on ways in which WSDOT and FHWA 
ignored the law, misinstrepreted data, and and went through formalities without the required intent to assess alternatives.  

WSDOT's reply brief, June 26
Here WSDOT denies our assertions. 

FHWA reply brief, June 26
Here the FHWA rebuts our assertions. 

Here we show why the agencies did not prove that a transit-optimized 4 lanes would not work.



June: WSDOT continues to show major changes to the designs

 WSDOT is getting more public about its intent to force 6 lanes through to Montlake, with no lids, no noise mitigation, and no traffic mitigation. See below "April: WSDOT changes plans" and the Seattle Times article here 

We believe that this big change should receive full public discussion, but we have not seen any drawings that show relevant specifics, like how traffic will get from 520 to Montlake Blvd. and to Madison Park. 

WSDOT is also showing totally different types of bridge over Portage Bay.  See here

April 23: our opening brief is filed
 A major milestone for the coalition, made possible by all our supporters: on April 23, we filed our opening brief in the federal lawsuit.  This is the basis for the hearing in Judge Martinez' court on July 10.   Now that this brief is filed, we await responses from WSDOT and from FHWA.  These responses will be filed in mid May.  After that, there is another exchange of briefs, and then the hearing.  The judge has discretion on how soon after the hearing he will make his decision. 

The opening brief is very readable, and you can see it here. It points out that federal and state laws require the agencies to evaluate reasonable alternatives, and that this was not done... for instance, adequate review was not done on a tolled, transit-optimized 4 lanes.  It points out that federal and state law require avoidance of taking public land, and that adequate analysis of alternatives to taking our beautiful waterways and natural areas was not done.  It points out that the state did not do a cost-benefit analysis that is required by state law and that is supposed to inform the decision-makers.  It points out that the state did not analyze air quality hot spots such as the proposed Montlake lid, where hundreds of buses and carpools will exhaust their fumes every day.  It points out that there is no analysis of the conflict between building this additional capacity, and the state's law specifying reduction of greenhouse gases. 

And much more...it's worth reading.  Here's one excerpt: "Various federal and state laws require careful considerations before agencies decide to spend taxpayer money on expensive projects.  These laws generally seek to assure that the agencies approach their decision with minds open to more than pre-conceived proposals... Too often, the extensive and expensive studies commissioned to analyze options end up being so many pages of documentation justifying a previously developed proposal."  

Separately, the coalition has filed an appeal to the Shoreline Hearings Board.  We are saying that the proposed bridge is higher than allowed, and would require a variance... that the state must follow the same process that anyone else would follow.  WSDOT has asked for summary judgment on this. Our response to that request is also worth reading, and you can see it  here.

 April: WSDOT changes plans
WSDOT now wants to make some big changes in its plans!  Here we clarify the differences between what WSDOT's final environmental documents said they planned for Montlake, and their new, unpublished plan.  I'll call the first plan the "EIS" because it is in the environmental impact statements.  I'll call the second plan " Lake to Land" because that is what WSDOT calls it.  (They also call it WABN)

WSDOT is still showing us the EIS plan, but they are planning on building the Lake to Land plan. They have strong indications that they will be given a federal stimulus loan for about $300 million to do the Lake to Land.  Paula Hammond confirmed to the Seattle Times recently that they plan Lake to Land.  Our legislators from the 43rd district fought the Lake to Land, but only gained assurance that it will not be constructed until June 2014.

In theory, either the EIS plan or the L to L plan is temporary, and eventually the state will come up with more than $2.5 billion to finish the project.  In practice, the state has no foreseeable way to get the $2 billion for at least 10 years, so we will be left with the partial project for at least that long.

So a key difference is that the EIS says that the whole project will be done  by 2017.  The Lake to Lands project is a tacit admission that the rest of the project will not be done for a long time, if ever.  This means that between the highrise and Montlake the eastbound lanes will remain at their current, low level.  The westbound lanes will be much higher, so there will be low bridge beside a high one, blocking views and water access.  

The L to L project appears to do nothing at all west of Montlake Blvd.

Another key difference is that the EIS plan has required mitigation: quiet pavement, sound deadening, the lids at Montlake  and at 10th and Delmar, removal of the ramps to nowhere, etc., and the L to L plan does not appear to contain any of these.   This is a HUGE concern for all who use the area or live in it. 

The EIS plan has plans for bike and pedestrian mobility.  The L to L plan does bring the bike/ped path from the bridge into Montlake, but we haven't seen any plans for what happens then.  There is no current plan to connect that path with anything.

The EIS plan says that the state will build a "west transition bridge" and then run out of money.   The west transition bridge goes from the highrise to near Foster Island, and it is where the 6 lanes would merge back into 4 lanes.   The Lake to Land plan continues the extra lanes west to Montlake Bloulevard.   There all the traffic gets dumped,  without any measures to take care of it.  It could be extremely expensive to re-do this configuration into a Montlake interchange in years to come.

The EIS plan adds offramps and other lanes between Foster Island and Montlake, covering much of the water and impacting the wildlife as well as the experience of nature.  It looks as though the L to L plan is a bit worse, even, than the EIS plan.

The EIS plan uses 24th above the freeway to enable cars to get to and from Madison Park and points south.  The L to L plan is unclear; all the traffic may have to go into Montlake Blvd, or the on-bound east ramp may continue.  Still being developed...  but a critical issue!

The EIS plan removes the ramps to nowhere.  The L to L plan seems not to do so.

Because the L to L plan is a desperate attempt to get the extra lanes into Montlake and needs to be done on a very strict budget, there will be a strong tendency to leave out all the mitigation we have been promised.  We need to get this plan out in the open, and fleshed out, and insist that WSDOT adhere to what we have been promised all along.  We should get ALL the offsets and mitigations that were in the EIS... and others that will make the area livable.

And we should not be asked to waste our time commenting on a plan that WSDOT does not plan to implement.

Here is WSDOT's image of the Lake to Land proposal.


March 10: What just happened in Olympia? 
In recent days, WSDOT has launched a new assault against our objective of getting a 520 solution that does less harm to the area.  For the sake of simplicity, references here to "WSDOT " include a few legislators close to WSDOT, and the governor, who is also determined to expand SR 520 without appropriate care for the environment and the communities.   Their latest attack has been three pronged.
1) WSDOT has pressured the City of Seattle to exempt the 520 expansion and other "essential public facilities" projects from the city's normal permitting safeguards and procedures.  Our neighbors are challenging this in a proceeding pending before a city hearing examiner.

2) WSDOT tried to exempt the 520 expansion from a portion of the shoreline management act. This portion normally prohibits construction work until appeals challenging the project's shoreline permits are decided. (We have such an appeal on file.)  Despite strong opposition from our representatives and the environmental community, WSDOT did obtain a partial exemption.  Fortunately, the exemption granted allows only work that can be used for either a four- or a six-lane solution.  This language demonstrates that the decision makers in Olympia recognize that a four-lane project is still a realistic option.


3) WSDOT tried to get funding for a new 520 plan, one not disclosed in the final environmental documents.  This new plan extends construction all the way to Montlake with
no  lids- a proposal as bad as any design could be:
- It thrusts many more lanes into Montlake, with no new interchange, dumping all the traffic onto local streets with no offsets;

- It adds lanes covering much of the water near the Arboretum, permanently ruining a much-used, unique in-city natural area.


- It puts a larger, wider "west transition"bridge offshore of Madison Park
and leaves the old bridge, so that people living or boating nearby will see a wall of bridges.
Here is WSDOT's image of this proposal. Double click on it to make it larger and see details...

In response to the above plan, legislative representatives Jamie Pedersen and Frank Chopp answered our call for help.  Meanwhile, WSDOT rallied the Chamber of Commerce and other business interests, and the unions, to position the plan's acceptance as a jobs issue.  These groups roused their members with bulletins that were not very accurate, for instance claiming that without this plan existing pontoon jobs would be lost.  And some legislators refused to vote on the general budget unless the 520 bill was passed.

Where are we now?

- The 520 projected is exempted, as described above, from the Shoreline Management Act's automatic injunction, but only for work that can be used for either a four-or-six lane project. WSDOT's request to exempt 520 from Seattle's normal permitting safeguards is being challenged before a city hearing examiner.

- New legislation states that until June 30, 2014, WSDOT may not build west of the shortest possible connection between the new floating bridge and the old bridge and can't contract for the approach to Montlake shown in the image above.  It is likely, however, that WSDOT will say that the west approach (the right side of the image) can be built.

- Also until June 30, 2014, WSDOT may not contract for the approach to Montlake unless the legislature has authorized tolls on I-90 and/or other funding sufficient to complete 520 with mitigation all the way to I-5.

The danger of an immediately worse 520 result has been avoided at least in part.  But longer term all our problems are still there.  You can see why expert action in the courts, independent of the political brawl, is so necessary.
March 2: Recent Progress: Lawsuit and design
Your backing has enabled us to file the lawsuit in Federal Court. Our hearing is scheduled for July 13 in the court of Judge Ricardo Martinez.  Our amended complaint, which you can read here, asserts that the state violated that National and State Environmental Protection laws, the Clean Air Act, the state law requiring reductions in greenhouse gas emissions, and the state law requiring a cost-benefit analysis of project like this one.    

We have already won some design concessions. And already the State has promised to limit any 520 construction before the hearing to work that could accommodate either its current six-lane plan or an alternative four-lane 520 design.

But unless it is forced to further revise its current design, the State will begin building its six-lane, double-deck bridge from the east across Lake Washington later this year. Amazing—because before the project reaches the Seattle shoreline, it will run out of money! (The State expects no additional 520 funding for the next ten years.) We will be left with six lanes merging into today’s four lanes just off-shore of Madison Park, well before west-bound vehicles will have the chance to exit. Meanwhile, the concrete pillars supporting today’s 520 through Seattle will remain, still vulnerable to earthquake.  

Here is an overview of the plan.  On the right side, 6 lanes are high and massive.  Then  a "transition bridge" swoops down from the highrise to today's bridge, which will remain in place until the state finds another $2 billion.  That $2 billion is not in the state's 10 year plan.  Tourists, boaters, and residents will find their views blocked by two bridges, one higher than the other. 

The west transition bridge will be much higher and bulkier than the current bridge.  Here is a WSDOT diagram of the old and new bridges at a point near Madison Park. 


It will probably be many years before the state finds money to go from the transition bridge to I-5, so for those many years people will be looking at two bridges: the old, lower structure and the new massive "transition" bridge.

If somehow the State were to find the additional $2 billion it needs to build the road it currently plans through Seattle, the results will be even worse: permanent harm to our communities, our bays and wetlands and our ability to get around our city. The green tab above "What is the Plan for 520" shows a few of the gruesome details. 

Our best hope of stopping the ill-conceived State plan depends on your further support.

Why waste all this money?

Washington state is short of funds for basic services, and for basic maintenance of highways.  For instance, there is no plan to re-surface I-5, which is an urgent need and which is expected to cost several billion.
This monster 520 project is not needed. Now that tolls have been imposed on the floating bridge, it's obvious that the current four lanes will be adequate for many years.  This is confirmed by an independent study which you can read here , where the Wilbur Smith Associates firm says that it may take 20 years to re-build traffic to its former levels.

Why not simply fix the safety problems?  You can read the coalition's ideas and see the initial cost estimates here. Our economists estimate that simply fixing the safety problems could save the state $2,000,000,000 to $3,000,00,000.  


When the state has money, a less-harmful 6 lanes can be built. Here you can read the Coalition's proposal for such a bridge.
 
Other recent activity

 After the State Department of Transportation (WSDOT) asked for shoreline permits for the whole project, even though the west side is only 5% designed, we worked with the city. City officials walked the shoreline with us, and we are pleased that we obtained assurances that if the Seattle side is built, we will get specific local mitigations, designed to keep the shorelines and bays as healthy as possible.    We are also pleased that the city won the right to review the plans for the west side when they are nearing completion, and that any changes then demanded by the city will be paid by WSDOT.

WSDOT is now working to exempt the 520 floating bridge project from the requirements of the shoreline management act!  This is a terrible precedent.  Even though WSDOT says it will not build anything that would preclude a 4 lane solution, exempting any project from basic shoreline regulations is a terrible idea.

We learned also that WSDOT is behind a recent effort to change the city's requirements for siting Essential Public Facilities -- including 520 -- to eliminate citizen protections.  Several communities are working to prevent this change.   

It is sad to think that a state agency simply tries to change laws if it feels inconvenienced.

Friday, January 7, 2011

2011 and previous





September 2011:   to get a better plan, 520 Coalition files Lawsuit

The Coalition has filed a lawsuit in federal court, saying that the state's environmental analysis does not meet the requirements of the federal or state Environmental Protection Acts.  The inadequacies include a failure to consider all reasonable alternatives in detail, a failure to adequately describe the existing environment, a failure to adequately analyze measures to mitigate the project's significant adverse environmental impacts, and a failure to describe the project's unavoidable significant impacts.    We ask the court to require additional  analysis, and to stay and issuance of permits.

The initial complaint is here
We later filed a more complete, amended complaint, which is here

 


 

July 2011: Final environmental analysis published.  The public had less than a month to analyze the 11,000 pages of the analysis and to respond.
The Coalition's response here lays out concerns about funding, risk to the state's general fund, and risk of not receiving enough tolls. 


We also comment that the state has not acknowledged the importance of the open space here for recreation and wildlife, or the fact that it is one integrated resource. 


Our response also challenges some of WSDOT's assumptions and some of its conclusions.   It's only 8 pages... read it yourself!

Mayor Mike McGInn also submitted a comment that is well worth reading. He shows that WSDOT's own data indicates that an improved 4 lanes could function well for traffic, and much better for the environment than the state's preferred alternative.



May 2011:  Coalition tells city council  "It's time to represent Seattle".  In an open letter the coalition asked the city council how it could benefit the city to take away a lane from I-5? Or to leave the safety problems on the west side for 10 years or more? Or to start a project with no reasonable prospect of funding to finish it?  Or to start the project before understanding how it will impact Seattle's traffic?


 You can see the Stranger's reporting and reader  comments here and the PI's reporting here
 

  
May 2011:  The vote, after city officials received our letter.    After receiving our request to vote "no" at the Puget Sound Regional Council, (see next entry below),   Mayor McGinn voted NO, don't go ahead: He explained that the state had not answered important questions about I-5, about Seattle traffic, about protecting our open space, about how the state would find the money to build.Please give him your thanks at mike.mcginn@seattle.gov  

The three city council members voted YES, go ahead with constructing 520.   They approved going ahead even after they were told that the analysis of effects on the people of the city was not complete and that great harm to the city was likely. Who were they representing?  Certainly not the people of Seattle.  Please tell them what you think of this vote: 

Tom Rasmussen, who chairs the city council 
transportation committee,up for election this year:
Tom.Rasmussen@seattle.gov

                                

Tim Burgess,city council member 
up for election this year: 


Bruce Harrell, city council member,
up for election this year:
Bruce.Harrell@seattle.gov
 



April 2011: Coalition asks Mayor, City Council members to vote "No" as Puget Sound Regional Council votes on whether to approve construction of the "preferred alternative" expansion of 520.
  
The coalition pointed out that the state can not fund the plan, and is really planning a "partial bridge".  We also pointed out that the safety problems are not being addressed, and that the plan will cause trips to be longer rather than shorter. See our letter here

 

April 2011: Seattle Director of Transportation asks state to analyze traffic effects and provide mitigation. 

After listening to the coalition, his staff, and others, Peter Hahn wrote an important letter insisting that the impacts on Seattle mobility and congestion be studied before the final environmental review is published.  You can read his letter here


February 2011:
What are the implications if the state's"Preferred Alternative" is built?

The state plans to spend money it doesn't have to expand 520 in a way that doesn't solve traffic problems and that blights historic neighborhoods.  The Coalition publishes an overview of the design and its impacts here


January 2011:
Expanding 520 will cause more congestion and slowdowns on I-5.

The state plans to take away an express lane from I-5. In its place, a reversible one-lane ramp will lead to 520.  Traffic will slow as cars deal with three lanes instead of the four we now have.

The new ramp will also cause slowdowns by adding weaves, where cars coming to or from I-5 will have to cross several lanes quickly to get to their off-ramps.


For more information see our new report here




 
Photo Scott Schuldt
December 2010
Coalition responds to state's plan to take open space and substitute a decrepit building site.
 
The Bryant building site, in the commercial area at the University of Washington, is not a reasonable substitute for the natural areas being taken south of the Montlake Cut. 
 
You can read our full response here

                                      You can read Mayor McGinn's response here


  
 December 2010
State Treasurer responds to our report on the state's inability to finance the proposed expansion of 520.  He presents a draft analysis of state debt levels, confirming "The results are sobering. By every measure, Washington is a high debt state."

Treasurer McIntire also said that floating the bonds currently authorized by the legislature for 520 would not cause the state to exceed its debt limit. However, he did not address the issue of the unauthorized $2 billion to $3 billion.... which would put the state way over its limit.  

Treasurer McIntire's draft debt affordability study is here. His response letter to the coalition is here.

The Coalition's letter to Treasurer McIntire is here. The Coalition's major report on Washington State bonds limits and its inability to fund the proposed expansion of 520 is here.


December 2010
Coalition proposes improvements to city legislative priorities for 2011. 
In December, the mayor and the city council each proposed the city's agenda for the state legislature for 2011.  We proposed improvements here.  The final resolution here is an improvement over the draft.  




September 2010
Coalition issues summary of current issues

For a one-page summary of current issues, look here





July 2010
Coalition issues report on state financing

- Washington is dangerously close to its constitutional debt limit.
- The state has already committed all the gas taxes that will be collected for many years.  It issues bonds... debt.. in anticipation  of these taxes.

- The state doesn't have the ability to issue enough bonds to finance the 520 expansion without violating its constitutional debt limit. 


- To complete this project would require large new taxes as well as tolls on I-90 used to expand 520. 
- It’s time to get real – to create a plan for SR 520 that is within the state’s  financial ability.  Use funds for safety, and defer expansion until  additional funding is available. 
For detailed analysis of the state's recent increase in debt, the costs of expanding 520, the available funding, and the debt limit, go to our report here.




April 2010
Coalition asks Governor to read their responses to environmental statement.


Our open letter to the Governor is here.  We hoped that the governor would not support a design so harmful to the environment, to mobility, and to the communities, if she had the facts.
The governor has never responded to our request.





April 2010
Coalition submits detailed responses to environmental statement.


 The SDEIS, or Supplemental Draft Environmental Impact Statement, was published by WSDOT.  The process allows comments, and many in our communities worked for weeks to create our detailed, specific responses. 



Summary: There are nine basic problems with the state’s analysis  (SDEIS) for the 520 corridor from I-5 to Medina:                                  

I)      The state has improperly separated the evaluation of the I-5 to Medina segment from the pontoons segment and from the east side segment.  In fact, these are interdependent parts of one project.

II)    The state appears to have made a decision already, and to be going through a paper environmental review  process while subverting the intent of the laws.  

III)   The SDEIS does not demonstrate that people and goods would move better after the construction.  The methodology for estimating demand and assessing congestion is fundamentally flawed.

IV)   The state is planning to take protected parkland for most of the length of 520 on the west side, destroying a unique chain of linked parks and bays.  Federal law requires seeking alternatives rather than taking parkland or harming historic areas.

V)  The state has not analyzed obvious alternatives which might have better results and do less damage,  including a tolled, transit-priority 4 lanes which might be adequate for some years until additional funding is available, and a 6 lane alternative with 2 lanes used for light rail.

VI) The SDEIS does not correctly describe the Current Proposals . The SDEIS also does not adequately describe the current congestion in Seattle, the planned projects will increase that congestion, and the lack of space for additional cars.

VII) The SDEIS does not adequately describe the effects of this highway expansion on air pollution and human health.  The state has an obligation to seek alternatives which will do less damage.

VIII) The state plans to start expanding the east side of 520 this year.  The whole program is at least  $2 billion short on funding, and the state is choosing to use the available funds for an area which has no safety problems, rather than to do a safety project for which  funding is available.

IX) The costs to businesses, families, and travelers are not fairly portrayed. Almost no mitigation of damages is promised. Noise reduction levels, limits on air pollution,  offsets for construction damages, and lids are either ignored or presented as optional. 



Here is the coalition's 46-page report on the SDEIS: 

Here are detailed appendices to our comments:
Appendix A: Letter from our lawyer David Bricklin
Appendix B: Impact on Parks and Recreation Areas
Appendix B1: Map of Affected Parks and Recreation Areas
Appendix C: Tiglman Group Comments on Traffic Analysis 
Appendix D: JGL Acoustics Inc on Noise impacts analysis   
Appendix E: Table of Potential Funding Sources
Appendix F: WSDOT letter on timing of Pontoon Project
Appendix G; 1954 map of proposed design 
Appendix H: Governor letter says too late for alternatives 
Appendix J: Comments on Second Montlake Bridge
Appendix K: Report of Legislative Workgroup on SR 520 
Appendix L: Seattle Times on Gregoire's opposition to Studying Alternatives
Appendix M: Methodological Flaws in Transportation Analysis
Appendix N: Flaws in Traffic Simulation 
Appendix O: References used in our traffic analyses
Appendix P: Generated Traffic 
Appendix Q: How to get more capacity on 4 lanes   
Appendix R: view from Capitol Hill of proposed new ramp
Appendix S: References on Air, traffic, health 
Appendix T: Analysis of SDEIS assertions on air quality 
Appendix U: Comments on Health Impact Study
Appendix V: Federal Ruling on uses of Tolls 
Appendix W: Comments on Analysis of Impacts on Fish 
Appendix X: Comments of Parks Commissioners 
Appendix Y: RFP for Pontoon Bids 
Appendix Z: Errors and Omissions in analysis of Cultural Resources 


    February 2010, three days after our press conference  Five Seattle city council members went to Bellevue to oppose our position and to support the preferred alternative design.

     These council members are Richard Conlin, Tom Rasmussen, Sally Clark, Tim Burgess, and Jean Godden.You can see the story here in the Bellevue Reporter and here in the Seattle Times.




     February 2010


     Press Conference:elected officials and other leaders join us to say that 520 design harms too much; fix the current 4 lanes and later create 5 and 6 for transit-only. Seattle Channel video of press conference is here.

Leaders speaking at the conference included Speaker of the House Frank Chopp. Mayor Mike McGinn, Senator Ed Murray, Rep. Jamie Pedersen,City Council members Mike O'Brien and Nick Licata, David Hillyer of the Cascade Bicycle CLub, Morgan Ahouse of the Sierra Club.