HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 09/13/2011 - REVIEW OF COLORADO DEPARTMENT OF TRANSPORTATION NODATE: September 13, 2011
STAFF: Kathleen Bracke
Pre-taped staff presentation: none
WORK SESSION ITEM
FORT COLLINS CITY COUNCIL
SUBJECT FOR DISCUSSION
Review of Colorado Department of Transportation North I-25 Final Environmental Impact
Statement Document.
EXECUTIVE SUMMARY
The Colorado Department of Transportation (CDOT) Region 4 staff has been developing the North
I-25 Environmental Impact Statement (EIS) for several years. Work on the EIS began in 2001. The
purpose of the North I-25 EIS is to plan for long-range transportation needs to connect Northern
Colorado with the Denver metropolitan area. The study area focuses on highway and transit plans
for the Interstate 25 corridor, US287 corridor, and the US85 corridor.
CDOT published the Final EIS document on August 19 and is seeking agency and public comments
through October 3. Staff has reviewed the Final EIS document and provided technical comments
to share with City Council and CDOT as part of this public review period. The work session
discussion and September 20 regular session action represents the City’s opportunity to share staff,
Council, and other potential community concerns with CDOT as part of the formal comment period
on the Final EIS document.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
The purpose of this work session is to share staff comments to-date on CDOT’s North I-25
Environmental Impact Statement (EIS) final document and seek input from City Council regarding
additional comments and questions.
1. Does City Council have any questions or concerns with CDOT’s Final EIS document,
including the preferred alternative, phasing plan, and environmental considerations?
2. Does City Council have any questions or concerns regarding City staff comments to-date on
the Final EIS document?
Please note that in addition to this briefing at the September 13th Work Session, City staff and
representatives from CDOT will provide a presentation of the Final EIS document to the City
Council at the regular City Council meeting on September 20th. Staff will seek formal action from
City Council regarding comments on the North I-25 EIS on September 20th. This will be the City’s
opportunity to share staff, Council, and other potential community concerns with CDOT as part of
the formal comment period on the Final EIS document.
September 13, 2011 Page 2
BACKGROUND / DISCUSSION
The purpose of the North I-25 EIS is to plan for long-range transportation needs to connect Northern
Colorado with the Denver metropolitan area. The study area focuses on highway and transit plans
for the Interstate 25 corridor, US287 corridor, and the US85 corridor. (Please see Attachment 1 for
a copy of the Final EIS Executive Summary, including a copy of the study area map shown on page
ES-2).
City Councilmember Ben Manvel and staff from Advance Planning/Transportation Planning have
been participants on CDOT’s Regional Coordination Committee (RCC) and Technical Advisory
Committee (TAC) throughout the EIS process. The TAC members are comprised of technical staff
from the various local municipalities, plus regional, state, and federal agencies. The RCC includes
elected officials from communities throughout the North I-25 EIS project area. The RCC and TAC
members have provided comments and feedback to CDOT’s EIS project team throughout the multi-
year planning process.
The Colorado Department of Transportation (CDOT) released the Final North I-25 Final
Environmental Impact Statement (FEIS) document for a public review period on August 19 and is
seeking agency and public comments through October 3.
CDOT has an electronic version of the FEIS document available for public review via its website:
(http://www.coloradodot.info/projects/north-i-25-eis) and hard copies are available at the City’s
Transportation Planning office located at 281 North College Avenue and at the main Library on
Peterson Street.
In addition to reviewing the FEIS document via CDOT’s website, the City has an electronic copy
available for review/download. The following are directions for staff and City Council to access the
electronic FEIS documents (please note that the FEIS document is very large so we do not
recommend printing it):
Click on your computer’s “start menu” and select the “run” option
• Copy the following text:
explorer.exe ftp://gw-download:ven53dor@ns2.fcgov.com/North_I_25_EIS/
• Paste this text into the "Run" window's text box
• Click the "OK" button
• View or copy the files in this folder
It is important for the City of Fort Collins staff and City Council to provide formal comments on the
FEIS document so that the City’s concerns, questions, and issues are part of the formal record for
the Colorado Department of Transportation and Federal Highways Administration to consider when
finalizing the document and completing the environmental clearance process for these identified
highway and transit improvements.
There may be instances where the City’s comments do not directly result in a change to the final EIS
document at this time, however this information will be useful input as the local, state, and federal
agencies move forward with implementing these important transportation improvements in the
September 13, 2011 Page 3
future. Some of our concerns may be more applicable at the more detailed design, engineering,
and/or construction phases of these transportation projects.
OVERVIEW OF THE FINAL ENVIRONMENTAL IMPACT STATEMENT
PREFERRED ALTERNATIVE
CDOT has provided the following information regarding the Preferred Alternative. The Preferred
Alternative is a combination of previous highway and transit alternatives developed by CDOT
during the earlier draft phases of the EIS process. It is based upon technical data analysis as well
as upon input from the various local, state, and federal agencies and the general public.
The Preferred Alternative includes:
• Multimodal improvements on several regional corridors, including highway and transit
improvements along I-25, US287, and SH85. Based on the proposed Preferred Alternative,
I-25 would be widened with general purpose lanes and Tolled Express Lanes (TELs).
Substandard interchanges would be reconstructed or upgraded to accommodate future travel
needs and replace aging infrastructure.
• Commuter rail transit service using the Burlington Northern Santa Fe rail corridor from Fort
Collins to the planned FasTracks North Metro end-of-line station in Longmont. The
commuter rail service is planned to continue to Downtown Denver’s Union Station via the
North Metro route. A connection to Boulder would also be made with a transfer to the
Northwest Rail line at the Sugar Mill Station in Longmont. The commuter rail line would
consist of a single track with occasional passing tracks.
• Express bus service would operate in the TELs along I-25 to connect northern Colorado
communities to downtown Denver and Denver International Airport (DIA). The express bus
service would utilize existing, expanded and new park & rides along I-25.
• Commuter bus service along US85 would connect Greeley with downtown Denver with
stops at the communities along the route.
Please see Attachment 1 (Final EIS Executive Summary, page ES-8) for a map illustrating the
recommended transportation improvements included in the Preferred Alternative.
PHASING
To accommodate current funding limitations, the Preferred Alternative has been separated into
phases. The first phase is estimated to cost approximately $670 million (in 2009 dollars) and would
be constructed with funding projected to be available in the amended 2035 Regional Transportation
Plan (RTP). Total cost for all of the improvements shown in the Preferred Alternative is
approximately $2.178 billion. Future phases would be constructed over time as funding is available.
September 13, 2011 Page 4
Phase 1 of the Preferred Alternative is shown in Attachment 1 (Final EIS Executive Summary, page
ES-18) and includes the following elements within the Fort Collins area:
• Widening I-25 between SH392/Carpenter Road and SH14/Mulberry Street - would initially
be used as continuous acceleration/deceleration lanes but would ultimately become part of
the general purpose lanes. The widening of I-25 between SH392 and SH14 would
eventually accommodate TELs. Widening would include water quality ponds, and median
barrier features necessary to accommodate this improvement. Right-of-way purchase
associated with the ultimate Preferred Alternative cross section is also included.
• Interchange replacement and upgrades – SH14/Mulberry and Prospect interchanges would
be constructed to their ultimate configurations. The interchange improvements at I-25 and
SH392 will be completed as part of the separate joint agency project already underway.
• Park & ride improvements at I-25 interchanges.
• Commuter Rail Right-of-Way (ROW) preservation – All ROW necessary to construct the
ultimate commuter rail configuration would be purchased as part of Phase 1.
• Initial I-25 Bus – Regional bus service connecting from Fort Collins to downtown Denver
and DIA would be initiated. Transit stations would be constructed as part of Phase 1 and
buses would be purchased.
The culmination of the EIS process is for CDOT to seek a Record of Decision (ROD) from the
Federal Highway Administration (FHWA) and the Federal Transit Administration (FTA). The ROD
will signify federal agency approval for the highway and transit improvements identified in Phase
I of the Final EIS (FEIS) document.
The ROD will identify funding for Phase 1 consistent with regional transportation plans included
in the Metropolitan Planning Organization’s planning documents. The ROD will be prepared only
for Phase 1 of the Preferred Alternative.
For the remaining phases, the rest of the project elements would then be implemented to complete
the ultimate Preferred Alternative over time, depending upon safety factors, transportation needs,
and available resources/funding.
Phase 2 is anticipated to include constructing the commuter rail from Loveland to Longmont,
constructing TELs and associated interchange upgrades between SH14/Mulberry and SH56 and
between E-470 and 120th Avenue.
Phase 3 is anticipated to include the completion of the commuter rail from Loveland to Fort Collins,
constructing the general purpose lanes from SH14/Mulberry to SH66, and constructing TELs from
SH66 to E-470. Subsequent RODs will be prepared for these future phases, as funding becomes
available.
September 13, 2011 Page 5
CITY OF FORT COLLINS COMMENTS ON THE EIS
City Council and staff have previously commented on the EIS process and draft documents over the
years, with the most recent being two City Council work sessions in 2009 (February and October)
as well as formal comments provided by the City on the Draft EIS document in 2008.
Prior Fort Collins City Council and staff comments/concerns expressed to CDOT to-date include
phasing and details of proposed commuter rail and highway improvements; impacts to wildlife
habitat areas, air quality, water quality, and stormwater contaminants; as well as the need for bigger
picture cost/benefit analysis considering long-term sustainability objectives.
Attachment 2 is a copy of the City of Fort Collins comments on the Draft Environmental Impact
Statement that were submitted to CDOT in 2008 and comments from the 2009 City Council
Worksessions. This information includes CDOT responses to prior City comments as well as
new/additional City staff comments that have been added based upon review of the Final EIS
document.
Staff comments on the 2011 FEIS document are consistent with the same themes of concerns shared
with CDOT as part of the City’s comments on the prior draft EIS document and proposed
alternatives in 2008-2009.
Staff is pleased that many of our prior comments, concerns, and suggestions shared with CDOT over
the years have been incorporated in to the FEIS document such as the inclusion and importance of
the multimodal options to provide express bus and commuter rail service in the core activity centers
and corridors of our community as well as the highway and interchange improvements needed to
improve safety and capacity for automobile and freight traffic.
CDOT has recognized Fort Collins’ land use and transportation planning visions as documented in
Plan Fort Collins (City Plan and Transportation Master Plan), and also integrated the multimodal
improvements included in the City’s Mason Corridor master plan into its commuter rail corridor
planning and station locations. For example, the three future commuter rails stations shown in the
FEIS Preferred Alternative are co-located with the City’s MAX Bus Rapid Transit (BRT) stations
at the South Transit Center, University station, and Downtown Transit Center to integrate regional
passenger rail service with our local transit plans. Similarly, CDOT’s regional express bus service
shown along Harmony Road will integrate regional and local transit service along this corridor from
the City’s South Transit Center to the transfer center currently located at Harmony/I-25. This
interface with the Mason/MAX and Harmony corridors will support local transit passengers wishing
to connect with regional service to downtown Denver and Boulder.
While many of the prior City comments/questions/concerns have been addressed by CDOT in the
FEIS, City staff continues to have concerns regarding several areas of the FEIS document.
Highlights of these continuing concerns include the following points:
• Implementation phasing for the various transportation improvements, specifically the
phasing plan shown for the future commuter rail service extending from Loveland to Fort
Collins is not shown until Phase 3 (CDOT expected timeframe of 2075+). Staff recommends
that CDOT revise the FEIS to only show two phases – Phase 1 as shown now, as the
“fiscally constrained plan” based on anticipated funding levels through 2035. Then, the new
September 13, 2011 Page 6
“Phase 2” would include all of the remaining elements of the Preferred Alternative and be
considered the “unfunded” items and not be tied to an artificial, 50-60+ year time horizon.
These transportation improvements – highway and transit – shown in Phase 2 and 3 need to
be implemented sooner rather than later to serve the regional travel demand forecast for
2035. Dividing them into two artificial phases does not solve the issue that the future
regional transportation needs significantly outpace our current funding sources. The EIS
Preferred Alternative should be a catalyst for convening regional discussions and
partnerships to work together toward accomplishing these needs within the 2035 timeframe.
• The transportation and air quality analysis included in the FEIS results in travel demand
projections that may not reflect changing fuel costs, use of alternative fuel vehicles, changing
lifestyle choices and long-term sustainability values, as well as other potentially significant
factors that would influence the demand for interstate and transit travel in the future. Our
cities, our region, and our country are facing a very different paradigm in the future. It seems
that traditional analysis tools based on the past 50 year trends may not be accurate for
predicting future demand and travel behavior. Staff recommends that CDOT consider using
a Triple Bottom Line method of analysis that factors in traditional transportation analysis
methods along with consideration of Environmental, Economic, and Human factors. While
staff recognizes the need for addressing pressing safety, capacity and ageing infrastructure
concerns along I-25, we also hope that roadway investments made in the near future will not
become stranded assets as mode shift occurs. Fortunately the transit system in the Preferred
Alternative can accommodate increases in transit mode share over time by adding additional
transit vehicles.
• Every effort to implement non-barrier methods of noise mitigation along I-25 (for example,
where it passes Arapaho Bend Natural Area) should be implemented. Staff does not support
construction of a barrier to mitigate noise in this area. In addition, potential
fencing/barriers/sound walls within other areas of Fort Collins, either along the highway
and/or commuter rail corridor, are not desirable from a community planning and
environmental perspective. Staff requests that CDOT consider deleting these elements
and/or include other options to maintain view sheds and wildlife movement corridors.
• Wetlands impacted in the Fort Collins regional area should be mitigated within the same Fort
Collins regional area. Local mitigation requirements per City of Fort Collins Land Use Code
should be considered for locally (Fort Collins) impacted wetlands. Staff supports the
mitigation of both federally jurisdictional and non-jurisdictional wetlands throughout the
project area.
• Regarding floodplains, the mitigation in the FEIS document for each creek, river, or other
drainage is vague, not site specific, and makes it impossible to evaluation for direct and
indirect impacts to wetlands and floodplains. The same four mitigation measures are
identified for separate drainages. Staff requests that revised, site specific mitigation plans
for each drainage should be conducted for the public and appropriate stakeholders to
comment on either as part of the EIS process and/or as part of the design process that moves
forward for implementation. In addition, staff requests that CDOT state that all regulations
will be followed including federal, state, and local requirements (not just the FEMA
regulations as noted in the FEIS).
September 13, 2011 Page 7
• Regarding the Floodplain Report, Cache La Poudre River section, the information should
be corrected to reflect that the City of Fort Collins staff highly supports removing the split
flow on the west side of I-25 if regulatory issues can be resolved through mitigation. The
split flow current heads south and crosses Harmony Road. Eliminating this split flow would
be an important life-safety issue since Harmony Road, a major arterial into Fort Collins, is
overtopped in less than a 100-year flood.
Attachment 2 is a summary of more detailed comments/concerns from City staff on the 2011 FEIS
document. The City comments are organized by topic area and include analysis of CDOT’s
responsiveness to the City’s prior comments as well as new staff comments/questions/concerns
based on the FEIS.
Comments that are submitted to CDOT as part of the public review period will be noted for CDOT
response and included for review by the Federal Highway Administration (FHWA) as part of its
formal review process of the EIS. As part of the Record of Decision (ROD) approval process,
FHWA will consider whether or not CDOT has adequately addressed the comments received during
the public review period. The EIS Phase 2 and 3 improvements will need to go through a
subsequent formal review process by FHWA before they can be implemented. CDOT will be
confirming the future process for Phase 2 and 3 improvements for the public and local agencies as
part of the upcoming public outreach process.
PUBLIC OUTREACH AND NEXT STEPS
CDOT is hosting a series of public meetings regarding the FEIS document from 4:30 – 7:30 p.m.
on the following dates:
• September 12– Southwest Weld County Building,4209 Weld County Road 24 ½ (I-25 exit
#240)
• September 13 - Longmont Public Library, 409 4th Avenue, Longmont
• September 15 – The Ranch (Budweiser Events Center), 5290 Arena Circle (I-25 exit #259)
The format for each of the public hearings will include an open house from 4:30 pm to 7:00 pm with
a brief presentation beginning at 5:30 pm followed with an opportunity to comment. City staff will
be attending the public meeting on September 15th to share comments with CDOT’s EIS project
team as well as to listen to community comments.
Once CDOT and FHWA have an approved ROD for the North I-25 EIS, they are planning to move
forward with the design phase of the I-25 highway improvements from SH14 south to SH392. City
staff will continue to work with CDOT throughout this design process to carry forward the issues,
comments, and suggestions discussed during the EIS process.
In addition, CDOT and the Army Corps of Engineers are currently working on the 404 permitting
requirements for wetland mitigation and have submitted a separate permit application to the City’s
Natural Resources department for review. City staff is reviewing this information concurrently with
the EIS review and will be providing consistent comments on both the FEIS and the 404 permit
application regarding the desire for wetland mitigation to be done locally if possible.
September 13, 2011 Page 8
City staff presented a brief update to the Transportation Board at its August 17, 2011 meeting and
Attachment 3 provides a summary of their discussion.
Please see the attachment 4 for a copy of the Fact Sheet provided by CDOT that explains the
highlights of the North I-25 EIS preferred alternative and provides some Frequently Asked
Questions/Answers.
For more information regarding the CDOT North I-25 EIS, please visit the project website:
http://www.coloradodot.info/projects/north-i-25-eis
ATTACHMENTS
1. Final EIS Executive Summary
2. City of Fort Collins Comments on CDOT EIS documents (This includes City Council and
Staff comments on Draft EIS in 2008-2009 as well as additional staff comments on FEIS in
August/September 2011)
3. Transportation Board meeting summary (August 17, 2011)
4. CDOT North I-25 EIS Fact Sheet (August 2011)
Executive Summary
ES-1
Final EIS
August 2011
1 EXECUTIVE SUMMARY
2 ES.1 SUMMARY OF THE ACTION
3 The Federal Highway Administration
4 (FHWA), in cooperation with the Colorado
5 Department of Transportation (CDOT), has
6 prepared this Final Environmental Impact
7 Statement (Final EIS) to identify and
8 evaluate multi-modal transportation
9 improvements along the 61-mile
10 I-25 transportation corridor extending from
11 the Fort Collins/Wellington area to Denver.
12 The improvements being considered in this
13 Final EIS would address regional and inter-
14 regional movement of people, goods, and
15 services in the I-25 corridor. The
16 improvements are needed to address
17 mobility, accessibility, safety, and aging infrastructure problems along I-25, as well as to provide
18 for a greater variety of transportation choices.
19 The regional study area (Figure ES-1) that encompasses these proposed improvements includes
20 38 incorporated communities. Major population centers in the regional study area include
21 Fort Collins, Greeley, Loveland and communities in the northern portion of the Denver
22 metropolitan area (Denver Metro Area).
23 Three multi-modal build packages (Package A, Package B, and the Preferred Alternative) are
24 being evaluated, as well as the No-Action Alternative in accordance with National Environmental
25 Policy Act (NEPA) requirements. Types of highway improvements being considered as a part of
26 the multi-modal packages include highway widening and interchange reconstruction. Transit
27 improvements being considered in the multi-modal packages include commuter rail, commuter
28 bus, and bus rapid transit (BRT) on three different alignments.
29 ES.2 OTHER ACTIONS IN THE REGIONAL STUDY AREA
30 Two other major actions are being proposed in the regional study area by other governmental
31 agencies. These are:
32 Glade Reservoir and the Relocation of US 287. The Northern Colorado Water Conservancy
33 District is proposing to build a new reservoir in the northwestern corner of the regional study
34 area. This would require relocation of a segment of US 287 north of Fort Collins.
35 FasTracks Corridors. The Regional Transportation District (RTD) is the existing agency
36 providing transit service in the Denver Metro Area. RTD will build commuter rail along two
37 corridors that will provide service to communities in the regional study area. The FasTracks
38 North Metro Corridor is located along the Union Pacific Railroad corridor just to the east of
39 I-25, terminating in Thornton. The FasTracks Northwest Rail Corridor is located along the
40 Burlington Northern Santa Fe Railway (BNSF) corridor (which is located adjacent to SH 119
41 between Boulder and Longmont) on the far western edge of the regional study area.
What’s In Executive Summary?
Executive Summary
ES.1 Summary of the Action
ES.2 Other Actions in the Regional Study Area
ES.3 Summary of Reasonable Alternatives
Considered
ES.4 Decision Making Process
ES.5 Summary of Major Environmental and
Other Impacts
ES.6 Other Federal Actions Required
ES.7 Next Steps in the NEPA Process
ES.8 Phased Project Implementation
ATTACHMENT 1
Executive Summary
ES-2
Final EIS
August 2011
1 Figure ES-1 North I-25 EIS Regional Study Area
2
Executive Summary
ES-3
Final EIS
August 2011
1 ES.3 SUMMARY OF REASONABLE ALTERNATIVES
2 CONSIDERED
3 An extensive process was undertaken to identify a range of alternatives that could be
4 developed to meet the purpose and need of the project. These alternatives were then
5 screened and combined to produce two build packages, Package A and Package B, which
6 were evaluated in the Draft EIS. The evaluation of these two packages, as well as input from
7 the project’s advisory committees and the public, was used to develop the Preferred
8 Alternative (which is evaluated in this Final EIS) from elements of Package A and Package B.
9 Package A, Package B, and the Preferred Alternative, together with the No-Action Alternative,
10 are considered the reasonable alternatives for this proposed action and all of these
11 alternatives have been fully evaluated in this Final EIS.
12 No-Action Alternative
13 The No-Action Alternative (Figure ES-2) would include those transportation projects that have
14 not been built, but for which funding has been committed, including the two FasTrack corridors.
15 The bridge over I-25 at 84th Avenue is currently being reconstructed as part of a separate project
16 expected to be completed in 2012. The SH 392/I-25 interchange will also be reconstructed as
17 part of a separate project starting in the middle of 2011 and expected to be completed in 2012.
18 The No-Action Alternative also would include replacement of pavement on I-25, installation of
19 signals at five interchange ramp termini, and widening of I-25 off-ramps at the Prospect/I-25
20 interchange.
21 Package A
22 Package A (Figure ES-3) would include adding one additional general purpose lane on I-25 in
23 each direction, for a total of six lanes from SH 66 to SH 14 (plus auxiliary lanes between
24 Harmony Road and SH 60) and a total of eight lanes from E-470 to SH 52. Interchange
25 reconstructions would be included. Package A also includes a double-tracked commuter rail
26 line using the existing BNSF railroad track plus one new track from Fort Collins to downtown
27 Longmont. The new second track was eliminated for a 500-foot segment of the corridor in
28 Loveland to avoid the historic Loveland Depot and in a second location – adjacent to a historic
29 residential property at 122 8th Avenue in Longmont. This would result in bi-directional service
30 along the existing single-track BNSF line near the proposed Loveland station and adjacent to
31 the residential property in Longmont.
32 Also included in Package A would be a new double-tracked commuter rail line that would
33 connect Longmont to the FasTracks North Metro end-of-line station in Thornton. Because
34 Package A commuter rail includes a double-tracked system, a parallel maintenance road
35 would not be needed. Maintenance access would be provided by the second track. Package A
36 also would include nine commuter rail stations and a commuter rail maintenance facility; a
37 commuter bus maintenance facility and feeder bus routes along five east-west routes; and
38 commuter bus service along US 85 between Greeley and downtown Denver and along E-470
39 from US 85 to Denver International Airport (DIA).
Executive Summary
ES-4
Final EIS
August 2011
1 Figure ES-2 No-Action Alternative
2
Executive Summary
ES-5
Final EIS
August 2011
1 Figure ES-3 Package A
2
Executive Summary
ES-6
Final EIS
August 2011
1 Package B
2 Package B (Figure ES-4) would include adding one buffer-separated tolled express lane (TEL)
3 to I-25 except for the section between SH 60 and Harmony Road, where two barrier-separated
4 lanes would be added. TELs would extend from SH 14 to 84th Avenue in Thornton. TELs
5 would be used by high-occupancy vehicles for free, by single-occupancy vehicles if they pay a
6 toll, and by buses. Interchange reconstructions would be included. Package B would also
7 provide a bus rapid transit system including 12 bus stations providing service along I-25, along
8 US 34 into Greeley, and along Harmony Road into Fort Collins. Along US 34 and Harmony
9 Road, the buses would travel in mixed traffic. Package B also would include a bus
10 maintenance facility and feeder bus routes along five east-west streets. In addition, bus
11 service would be provided along E-470 from I-25 to DIA.
12 Preferred Alternative
13 The Preferred Alternative (Figure ES-5) would combine elements presented in Packages A
14 and B and would include multimodal improvements on multiple corridors. Under the Preferred
15 Alternative, I-25 would be widened with general purpose lanes and TELs and substandard
16 interchanges would be reconstructed or upgraded to accommodate future travel needs.
17 The Preferred Alternative also includes commuter rail transit service from Fort Collins to the
18 anticipated FasTracks North Metro end-of-line. Service to Denver would travel through
19 Longmont and along the FasTracks North Metro Corridor. A connection to Boulder would also
20 be made with a transfer to Northwest Rail at the Sugar Mill Station in Longmont. Nine
21 commuter rail stations and a commuter transit maintenance facility are included in the
22 Preferred Alternative. The commuter rail would consist of a single track with occasional
23 passing tracks at four locations. The BNSF railroad is requiring that commuter rail utilizing
24 BNSF track upgrade BNSF facilities to include a maintenance road where maintenance access
25 is not available. The Preferred Alternative design includes a maintenance road parallel to the
26 BNSF line between Longmont and Fort Collins. Commuter rail track that is not within the BNSF
27 right-of-way does not include a maintenance road.
28 Express bus service would operate in the TEL to connect northern Colorado communities to
29 downtown Denver and DIA and serve 13 stations along Harmony Road, US 34, and I-25.
30 Commuter bus service along US 85 would connect Greeley with downtown Denver with five
31 stops at the communities along the route. A bus maintenance facility would be constructed to
32 accommodate both express buses and commuter buses.
33
Executive Summary
ES-7
Final EIS
August 2011
1 Figure ES-4 Package B
2
Executive Summary
ES-8
Final EIS
August 2011
1 Figure ES-5 Preferred Alternative
2
Executive Summary
ES-9
Final EIS
August 2011
1 ES.4 DECISION MAKING PROCESS
2 A collaborative decision making process was used to develop consensus among the
3 45 communities and agencies (including CDOT and FHWA) on the elements in the Preferred
4 Alternative and the phasing plan. A collaborative decision making process was used because
5 of the need for broad community support and limited financial resources available for
6 transportation improvements in the region. Broad community support sets the stage for local
7 agency participation, partnerships, and commitment to implementation through policies, zoning
8 and, adoption of complementary land use and transportation plans. Broad community support
9 is also more likely to attract funding. The collaborative decision making process is the
10 mechanism for achieving broad community support for a Preferred Alternative which
11 addresses Purpose and Need in a manner that allows FHWA and CDOT to take responsibility
12 for the decision and implementation. Through this process consensus was achieved on the
13 Preferred Alternative and its phasing plan.
14 ES.5 SUMMARY OF MAJOR ENVIRONMENTAL AND
15 TRANSPORTATION IMPACTS AND MITIGATION
16 Chapter 3 Environmental Consequences and Chapter 4 Transportation Impacts of this Final
17 EIS include information describing environmental and other impacts to all resources in the
18 affected area. Section 3.28 Summary of Direct and Indirect Impacts includes a summary of all
19 impacts and Section 3.29 Mitigation Summary includes a summary of all mitigation. This
20 section provides a summary of only the major impacts that would occur.
21 Environmental Impacts
22 Land Use
23 Implementation of Package A would support regional planning and municipal planning efforts
24 (including transit oriented development). Under Package B, anticipated development along
25 I-25 would continue in accordance with city and county plans. Bus rapid transit would support
26 this development. In the absence of transit or capacity improvements in Fort Collins, Loveland
27 and Longmont, development would most likely continue to spread outward from city centers.
28 The Preferred Alternative is a combination of components presented in Package A and
29 Package B, and includes multimodal improvements on multiple corridors. The Preferred
30 Alternative would be compatible with existing land uses, zoning, and comprehensive plans,
31 with impacts similar to those described for Package A. Conversion of agricultural and open
32 lands into urban uses will continue regardless of whether a build package is implemented or
33 not. Implementing Package A or the Preferred Alternative could minimize the conversion of
34 agricultural land in the outlying areas of communities along the BNSF rail line as development
35 shifts toward higher densities and urban centers in Fort Collins, Loveland, and Longmont.
36 Right-of-Way
37 Relocation impacts associated with the Preferred Alternative would include 51 residences and
38 23 businesses, compared with 59 residences and 33 businesses associated with Package A
39 and 24 residences and 16 businesses associated with Package B. All acquisition or relocation
40 needed for this project would fully comply with the Uniform Relocation Assistance and Real
41 Property Acquisition Policies Act of 1970, as amended.
Executive Summary
ES-10
Final EIS
August 2011
1 Air Quality
2 Air pollutant emissions associated with all three build packages would be slightly greater than
3 those anticipated under the No-Action Alternative because vehicle miles of travel would be
4 expected to increase. These emissions in 2035 would, however, be lower than existing levels
5 for all pollutants and in all alternatives.
6 Noise and Vibration
7 Traffic noise impacts would occur under all three build packages as well as the No-Action
8 Alternative. The No-Action Alternative would impact a few less sites (816 sites) than the
9 Preferred Alternative (840 sites), Package A (826 sites) or Package B (848 sites). Mitigation of
10 traffic noise is recommended for two areas under Package A and for seven areas under
11 Package B and the Preferred Alternative.
12 Noise impacts also would occur as a result of rail transit operations associated with Package A
13 and the Preferred Alternative, with severe impacts projected to occur at 697 residences,
14 6 schools, and 1 church along both the Package A and the Preferred Alternative commuter rail
15 corridors. Vibration impacts, affecting 40 residences, would be expected as a result of
16 commuter rail operations associated with Package A and the Preferred Alternative. Noise and
17 vibration mitigation would be installed. The identified mitigation actions for Package A and the
18 Preferred Alternative of quiet zones, noise barriers, special trackwork and tire-derived
19 aggregate would remove rail transit noise and vibration impacts such that no receivers would
20 be impacted by rail noise or rail vibration. The implementation of quiet zones for rail transit
21 noise will require the involvement of several local governments. Other mitigation measures
22 (such as noise barriers) have been identified in the event that one or more quiet zones cannot
23 be implemented.
24 Quiet zones are the best and preferred train horn mitigation because quiet zones would
25 eliminate the noise source. The direct involvement and sponsorship of local government
26 agencies is required for quiet zone implementation, and they must apply to the PUC for quiet
27 zone approval. CDOT and FHWA cannot guarantee such local government agency actions;
28 however, CDOT and FHWA anticipate that local government agencies will agree that quiet
29 zones will be beneficial and be willing to sponsor the required Public Utilities
30 Commission (PUC) applications. If for any reason, one or more quiet zones cannot be
31 implemented, the recommended mitigation would change to additional noise walls for those
32 locations along the rail corridor.
33 With the proposed mitigation:
34 Package A would impact 623 Category B and 153 Category C receivers from traffic noise,
35 while no receivers would be impacted by commuter rail.
36 Package B would impact 504 Category B and 163 Category C receivers from traffic noise.
37 Preferred Alternative would impact 498 Category B and 161 Category C receivers from
38 traffic noise, while no receivers would be impacted by commuter rail.
39
Executive Summary
ES-11
Final EIS
August 2011
1 Wetlands
2 Wetlands and waters of the U.S. would be impacted by all three build alternatives along
3 highway and transit corridors; Package A would impact 21.9 acres, Package B would impact
4 21.3 acres, and the Preferred Alternative would impact 18.2 acres. Mitigation would be
5 provided for all wetland impacts in compliance with provisions of the Clean Water Act and
6 requirements of Executive Order 11990.
7 Floodplains
8 Impacts would occur to 100-year floodplains situated along the corridors. Package A would
9 impact 12.8 acres of floodplains, Package B would impact 13.5 acres of floodplains, and the
10 Preferred Alternative would impact 13.0 acres of floodplains. All floodplain impacts would be
11 mitigated in accordance with Executive Order 11988, 23 Code of Federal Regulations
12 (CFR) 650, and local regulations.
13 Wildlife
14 Wildlife and aquatic species habitat would be negatively affected. Package A would impact
15 2.0 acres of sensitive wildlife habitat and 1.8 acres of sensitive aquatic habitat, Package B
16 would impact 2.4 acres of sensitive wildlife habitat and 2.3 acres of sensitive aquatic habitat,
17 and the Preferred Alternative would impact 1.9 acres of sensitive wildlife habitat and 1.5 acres
18 of sensitive aquatic habitat. All impacts would be mitigated to the extent possible.
19 Threatened, Endangered, State Sensitive and Protected Species
20 There would be impacts to threatened, endangered, state sensitive and protected animal
21 species habitat. Package A would impact 292 acres, Package B would impact 353 acres, and
22 the Preferred Alternative would impact 341 acres. Most of these impacts would occur to bald
23 eagle foraging habitat and black tailed prairie dog colonies. All impacts would be mitigated.
24 Historic Preservation
25 There are many archaeological and historic properties along the transportation corridors.
26 Seventy-two of these are either on the National Register of Historic Places or have been
27 determined eligible for inclusion on the National Register of Historic Places. Package A would
28 cause an adverse effect to seven of these properties, Package B would result in an adverse
29 effect to one of these properties, and the Preferred Alternative would cause an adverse effect
30 to four of these properties. Mitigation for impacted properties would occur in compliance with
31 Section 106 of the National Historic Preservation Act (36 CFR 800).
32 Parks and Recreation
33 There are 41 existing and proposed parks or recreational properties along the corridors.
34 Package A would affect eight of these properties, Package B would affect six of these
35 properties, and the Preferred Alternative would affect six of these properties. Mitigation for all
36 impacts would be provided in accordance with the requirements of Section 4(f) of the
37 Department of Transportation Act.
38
Executive Summary
ES-12
Final EIS
August 2011
1 Hazardous Materials
2 All three build alternatives would have hazardous materials impacts associated with sites to be
3 acquired for right-of-way (partial and full). Hazardous materials impacts include sites with
4 either potential or known soil and/or groundwater contamination. Package A would impact
5 96 parcels with potential environmental conditions and 18 parcels with recognized
6 environmental conditions. Package B would impact 40 parcels with potential environmental
7 conditions and 16 parcels with recognized environmental conditions. The Preferred Alternative
8 would impact 67 parcels with potential environmental conditions and 20 parcels with
9 recognized environmental conditions.
10 Compatibility with Area Plans
11 Package A, Package B, and the Preferred Alternative were designed to accommodate future
12 population and employment growth, increased traffic volumes, and expansion plans of
13 municipalities in the regional study area, and to be compatible with both regional and local
14 area transportation plans. Transit improvements were designed to connect and be compatible
15 with RTD’s planned FasTracks rail system. Not all of the improvements included in Package A,
16 Package B, and the Preferred Alternative are included in the fiscally constrained plan for
17 Denver Regional Council of Governments (DRCOG). CDOT has submitted amendments
18 requesting DRCOG to include Phase 1 Preferred Alternative improvements in the fiscally-
19 constrained plan. The amendments are expected to be adopted in September 2011. Adoption
20 of these amendments must occur prior to inclusion of these improvements in a Record of
21 Decision (ROD).
22 Transportation Impacts
23 Transportation travel demand forecasts for 2035 were produced through the use of a multi-
24 modal travel demand model, which was developed by combining the existing DRCOG and
25 NFRMPO travel demand models. Additional expertise was utilized for toll and revenue
26 forecasts. Key transportation impact findings are summarized below.
27 All three build alternatives provide improvements in travel time compared to the No-Action
28 Alternative. In the general purpose lanes, travel would be improved by 16 minutes with
29 Package A and Package B, and 26 minutes with the Preferred Alternative. Using the tolled
30 express lanes, travel time would be 51 minutes faster for Package B, and 52 minutes faster for
31 the Preferred Alternative as compared to the No-Action Alternative. Package A commuter rail
32 would be 40 minutes faster than driving in the No-Action Alternative while the Preferred
33 Alternative commuter rail would be 39 minutes faster. Travel on bus rapid transit (Package B)
34 would be 63 minutes faster.
35 Package A would result in a reduction in traffic on regional study area arterial streets of 10,000
36 to 35,000 vehicles (each arterial per day), Package B would reduce volumes from 5,000 to
37 15,000 vehicles per day, and the Preferred Alternative would reduce arterial volumes 5,000 to
38 25,000 vehicles per day compared to the No-Action Alternative. The reduction in volumes has
39 a notable range, reflecting the natural range in daily total volumes on minor and major
40 arterials. The No-Action Alternative would result in very little physical impact to social,
41 economic, and environmental resources. Air pollution related to traffic congestion would
42 continue to increase and noise impacts from increased traffic also would worsen. Over time,
43 the No-Action Alternative could have a dampening effect on the local economy.
Executive Summary
ES-13
Final EIS
August 2011
1 Travel Demand
2 I-25 capacity improvements attract traffic to I-25 over the No-Action Alternative. The increase
3 in traffic varies by segment reflecting differing origin and destination patterns along the 60-mile
4 corridor. Larger traffic increases occur near mid corridor activity centers. Small increases
5 occur at the northern end of the study area reflecting lower trip generation and at the south
6 end reflecting less available capacity on I-25 south of E-470.
7 Package A projected 2035 daily traffic volumes on I-25 segments between SH 1 and E-470
8 would generally be 8 percent to 33 percent higher than the No-Action Alternative, while
9 Package B 2035 daily traffic projections would be about 1 percent to 27 percent higher than
10 the No-Action Alternative. The Preferred Alternative projected 2035 daily traffic volumes would
11 generally be 2 percent to 40 percent higher than the No-Action Alternative, with similar pattern
12 across the range as Package B. In general, the increased traffic on I-25 with the build
13 alternatives would reduce traffic on the roadways parallel to I-25. Package A and the Preferred
14 Alternative would have a greater effect on parallel arterial volumes than Package B in the
15 northern area. In the Denver metropolitan area, only Package B and the Preferred Alternative
16 have some effect on parallel arterials due to the addition of the TELs.
17 The build alternatives would attract more highway users (people) to I-25 than the No-Action
18 Alternative. Package B would generate slightly more total users than Package A. The
19 Preferred Alternative would have the highest level of users at over 990,000 daily (number of
20 vehicles entering this length of I-25 multiplied by vehicle occupancy). The transit components
21 of Package A, Package B, and the Preferred Alternative would not appreciably reduce I-25
22 highway traffic volumes because transit ridership projections are an order of magnitude
23 smaller than vehicular demand projections.
24 Transit ridership (not including the feeder buses) in 2035 would be about 5,850 riders per day
25 for Package A, about 6,800 riders for Package B, and about 6,500 riders per day for the
26 Preferred Alternative. Station activity for commuter rail, BRT, and express bus would increase
27 from north to south while station activity for the commuter bus generally would be the same at
28 stations along the route.
29 System Operation
30 Package A, Package B, and the Preferred Alternative would experience similar peak hour
31 operation at the I-25 interchange ramp termini but the Preferred Alternative would operate with
32 substantially fewer miles of congestion on I-25 than either Package A or Package B.South of
33 E-470, Package B and the Preferred Alternative would experience fewer miles of congestion
34 on I-25 than Package A due to the increased capacity with the additional TELs.
35 Safety
36 Package A, Package B and the Preferred Alternative would modify newer interchange
37 structures, rehabilitate older structures, or replace the existing structures to address geometric
38 and capacity-related safety concerns. To minimize the potential for conflict between the
39 proposed commuter rail line and private automobiles, railroad grade crossings were designed
40 to comply with both Federal Railroad Administration (FRA) and RTD safety standards through
41 either grade separation or other treatment and warning methods. Along the BNSF alignment in
42 Package A and the Preferred Alternative, existing grade separations would be maintained but
Executive Summary
ES-14
Final EIS
August 2011
1 no new structures would be added. For the new alignment from Longmont to North Metro
2 Corridor in Package A and the Preferred Alternative, six new grade separations would be
3 incorporated into the design.
4 Package A, Package B and the Preferred Alternative are expected to experience
5 approximately the same number of total crashes in 2035 with slightly fewer injury and fatality
6 crashes anticipated under Package B.Barrier-separated sections of Package B were
7 predicted to have fewer accidents than the same sections of I-25 in Package A or the
8 Preferred Alternative.
9 Freight Traffic on I-25
10 Neither Package A, Package B, nor the Preferred Alternative would affect the current growth
11 rate for freight traffic (estimated to be two percent on the south end and three percent on the
12 north end). In general, freight traffic would benefit from improved traffic operations in the GPLs
13 and reconstruction of the highway to a maximum grade of four percent included in all build
14 packages. In Package B and the Preferred Alternative, freight traffic would be prohibited from
15 using the TEL.
16 Pedestrian and Bicycle Systems
17 The No-Action Alternative generally would not affect bicycle/pedestrian facilities along the I-25
18 corridor.All build package improvements along I-25 generally would facilitate future
19 bicycle/pedestrian travel, because reconstruction plans would include provisions for future
20 bicycle/pedestrian facilities to cross the interstate and new bridges over waterways would
21 accommodate planned trails.Pedestrian and bicycle connections to transit stations in
22 Package A and the Preferred Alternative would be located along the BNSF rail line, US 85,
23 and I-25.Pedestrian and bicycle connections to transit stations in Package B would be
24 focused along I-25. Proposed queue jumps along US 34 (Package A, Package B, and
25 Preferred Alternative) and US 85 (Package A) would require acquisition of some new right-of-
26 way, which could affect some pedestrian crossings and on-street bicycle facilities. All
27 connections and trails would be maintained.
28 Construction Impacts
29 Highway construction methods would be similar for all build packages, although Package B
30 and the Preferred Alternative would require additional signage and striping, as well as
31 installation of the toll collection system. In all packages, new highway segments would open as
32 phases are completed and a design-build method could be sought for any of the package
33 improvements. Transit construction methods in Package A and the Preferred Alternative would
34 temporarily disrupt freight rail traffic for the construction of grade crossing improvements and
35 construction of the vertical elements of the commuter rail stations. Transit construction
36 methods in Package B would require night-time closures of the interstate to install the vertical
37 elements of the BRT stations in the interstate median. Regardless of the build package
38 selected, there would be temporary noise, vibration, and visual impacts, although they would
39 be minimized as much as possible. Furthermore, mitigation measures would be needed to
40 avoid air quality, water quality, and traffic impacts. The Section 404 permit would assign
41 additional detailed mitigation measures. Under all build packages, travel demand management
42 measures could be used to minimize traffic impacts.
Executive Summary
ES-15
Final EIS
August 2011
1 ES.6 OTHER FEDERAL ACTIONS REQUIRED
2 The following is a list of other federal actions required for all build packages:
3 Issuance of a Section 404 permit from the U.S. Army Corps of Engineers (USACE) is
4 required prior to impacting any waters of the U.S. A Section 404 permit application has
5 been submitted to the USACE.
6 Issuance of a Biological Opinion from the U.S. Fish and Wildlife Service (USFWS) will be
7 included with the ROD.
8 Consultation with USFWS regarding Platte River water usage.
9 The Final Section 4(f) Evaluation will be submitted to the Department of the Interior during
10 the Final EIS comment period. For more information, see Chapter 5, Section 4(f)
11 Evaluation.
12 Ongoing compliance with the Section 106 Programmatic Agreement.
13 Air quality conformity findings are needed for the Phase 1 ROD and all subsequent RODs.
14 ES.7 NEXT STEPS IN THE NEPA PROCESS
15 This Final EIS has been prepared in compliance with Council on Environmental Quality (CEQ)
16 regulations for implementing NEPA (40 CFR 1500), FHWA environmental impact and related
17 procedures for implementing NEPA and CEQ regulations on highway transportation projects
18 (23 CFR 771), FHWA Technical Advisory T 6640.8A, and other applicable laws. This Final EIS
19 is available to interested parties for review and comment for 30 days. During the review period,
20 public hearings will be held and all comments recorded.
21 The next step in the NEPA process following the Final EIS review period is preparation of a
22 ROD, which will document the federal agency decision for the project.
23 ES.8 PHASED PROJECT IMPLEMENTATION
24 Because there are not enough funds in the long range plan to build the entire Preferred
25 Alternative, the Preferred Alternative has been separated into three phases. The first phase
26 would cost approximately $670 million (2009 dollars) and would be constructed with funding
27 available in the fiscally-constrained 2035 RTPs, as amended. The second and third phases
28 would together cost approximately $1.5 billion (2009 dollars). These later phases would be
29 constructed over time as additional funds become available. Phasing for Package A and
30 Package B could also be developed in a similar manner. Given that all three build alternatives
31 could be phased, identification of the Preferred Alternative was not based on phasing
32 considerations.
33 Phase 1 of the Preferred Alternative is shown in Figure ES-6 and includes the following
34 elements:
35 Widening I-25 between SH 66 and SH 56 – with one tolled express lane in each direction.
36 Widening would include water quality ponds and median barrier features as well as the
37 right-of-way purchase associated with the ultimate Preferred Alternative cross section.
38
Executive Summary
ES-16
Final EIS
August 2011
1 Widening I-25 between SH 392 and SH 14 – would initially be used as continuous
2 accel/decel lanes, but would ultimately become part of the general purpose lanes.
3 Widening would include water quality ponds and median barrier features necessary to
4 accommodate this improvement. Right-of-way purchase associated with the ultimate
5 Preferred Alternative cross section is also included.
6 Widening I-25 between 120th Avenue and approximately US 36 – one buffer-separated
7 tolled express lane in each direction. Widening would include sound walls, water quality
8 ponds, and median barrier features as well as the right-of-way purchase associated with
9 the ultimate Preferred Alternative cross section.
10 Interchange replacement and upgrades – SH 14, Prospect, SH 56, CR 34, and SH 7
11 would be constructed to their ultimate configurations. US 34/Centerra Parkway
12 intersection would be reconstructed to a single point urban interchange. SH 392 and
13 84th Avenue would be completed as part of a separate project. Minor modifications to
14 84th Avenue, Thornton Parkway, 104th Avenue, and SH 392 will be completed as part of
15 Phase 1 highway widening.
16 Six carpool lots at I-25 interchanges.
17 Commuter Rail right-of-way preservation – all right-of-way necessary to construct the
18 ultimate commuter rail configuration would be purchased as part of Phase 1.
19 Initial I-25 Bus – regional bus service connecting Fort Collins and Greeley to downtown
20 Denver and DIA would be initiated. Four transit stations would be constructed as part of
21 Phase 1 and 27 buses would be purchased.
22 Commuter Bus – commuter bus along US 85 connecting Greeley to downtown Denver
23 would be implemented in Phase 1. This would include construction of five stations and the
24 purchase of five buses.
25 Phase 2 is anticipated to include constructing the commuter rail from Loveland to Longmont,
26 constructing TELs and associated interchange upgrades between SH 14 and SH 56 and
27 between E-470 and 120th Avenue. Phase 3 is anticipated to include the completion of the
28 commuter rail, constructing the general purpose lanes from SH 14 to SH 66, and constructing
29 TELs from SH 66 to E-470.
30 Metropolitan Planning Regulation (23 Code of Federal Regulations [CFR] 450.322) and the
31 Clean Air Act (CAA) Transportation Conformity Rule (40 CFR 93.104) work together to require
32 that a project located in a Metropolitan Planning Area and/or in a CAA nonattainment or
33 maintenance area, be contained in a conforming, fiscally-constrained long-range regional
34 transportation plan. Through a ROD, FHWA can approve project improvements that are
35 included in conforming, fiscally-constrained regional transportation plans.
36 After this Final EIS has been made available to the public and the review period concludes,
37 FHWA and CDOT will identify an initial phase for the ROD. Phase 1, as identified in this
38 chapter, is proposed as Phase 1 for the ROD. Consideration of the Final EIS and the first ROD
39 will be part of future implementation of projects. Improvements included in Phase 2 and
40 Phase 3 can be re-evaluated, as necessary, based on future safety needs, funding availability,
41 and transportation needs and identified in subsequent RODs as additional funding becomes
42 available. Phases 2 and 3 do not necessarily need to be selected in their entirety or in order in
43 subsequent RODs. This will be determined at the time of a subsequent ROD, considering
44 available funding, priorities at that time, and the results of any reevaluation that may be
45 needed.
Executive Summary
ES-17
Final EIS
August 2011
1 The identification of a Preferred Alternative for the entire project in this Final EIS is consistent
2 with FHWA’s objective of analyzing and identifying transportation solutions on a broad enough
3 scale to provide meaningful analysis and to avoid segmentation. The identification of an initial
4 phase for implementation is consistent with FHWA requirements to have funding for projects
5 identified before final decisions are made. As funds become available, it is the intent of FHWA
6 and CDOT to work toward implementation of the Preferred Alternative in its entirety through
7 this phased approach.
8
Executive Summary
ES-18
Final EIS
August 2011
1 Figure ES-6 Preferred Alternative Phase 1
2
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 1 of 22
City Council Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
1
Travel to Denver is emphasized to the exclusion of travel to Longmont and Boulder,
which are apparently at least as important destinations from Northern Colorado. The
analysis should address a broader spectrum of trips. For example the graphics of
travel patterns in Figure 4-6 indicate no riders going to or from Longmont, assuming
all passengers are going to Denver. Really?
1. All trip types are covered by the analysis. Trips to Boulder and Longmont are also included in the analysis; however
Figure 4-6 only depicts riders on the specific transit system improvements proposed by this project. Riders transferring
to/from the RTD FasTracks and bus system are not directly illustrated, but their activity is discerned through the rail
access/egress in the pie chart. For example, at the Sugar Mill station in Longmont, it can be seen that about three- eights
of the riders getting on or getting off the commuter rail transfer to/from the FasTracks Northwest Rail line.
Comment addressed - Commuter Rail and
Express Bus routes in the FEIS Preferred
Alternative will provide service to both
Downtown Denver and Boulder to serve the
different destinations for Fort Collins travelers.
A
2
Connections to other transit options, in particular the North and Northwest routes
proposed for FasTracks, are vital. How does each alternative interact with them?
2. All of the alternatives are connected to the future FasTracks system. Package A extends the end of the FasTracks North
Metro rail line to terminate at the Downtown Transit Center in Fort Collins. Package A also extends the end of the
FasTracks Northwest rail line to a new station in southern Longmont, labeled the Sugar Mill station. This would be a
shared station with the North Metro line to Fort Collins, thus allowing rail-to-rail transfers. Package B interacts with the
FasTracks system in downtown Denver, allowing BRT passengers to access all the FasTracks rail lines as well as the
RTD bus routes serving downtown Denver. In addition, the BRT routes in Package B stop at Wagon Road, a major park-
n-Ride in the northern metro area at I-25 and 120th Avenue that is served by numerous bus routes. The Preferred
Alternative includes the commuter rail FasTracks connectivity points as described for Package A, and it includes express
bus to downtown Denver, allowing connectivity to all the FasTracks corridors.
Comment addressed - The Preferred Alternative,
including the Commuter Rail and Express Bus
routes, are now integrated with the future
FasTracks system routes. A
3
Does the analysis look to the future, anticipating high fuel prices, demand pricing of
car travel, and possible alternatives to commuting?
3. The EIS forecasts are conservative as no change in the relative cost of gasoline is assumed, because predicting the
price of fuel would be impracticable. Similarly, the forecasts assume the portion of work-at-home and other alternative
commute activities remain at similar percentages to that experienced today. If the price of gas or commute characteristics
dramatically change, these could indeed influence travel behavior patterns. (Information about this is in the FEIS in
Section 4.2.9). The EIS has openly acknowledged that the future price of gas is an unknown and therefore introduces an
uncertainty into the forecasts, as described in section 4.2.6.6.
Staff continues to be concerned regarding the
travel demand forecast methodology used in the
FEIS, particularly that it is substantially
underestimating future transit ridership
projections. We appreciate that CDOT openly
acknowledges these challenges. For example, the
FEIS states that if fuel prices were to be factored
into the forecasts, the transit projections could be
up to 90% higher and could be up to 40% higher
than projected based on recent data from
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 2 of 22
City Council Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
“Transportation Master Plan” as part of the
2010-11 “Plan Fort Collins” process. These plans
emphasize higher density, transit oriented
development” in the core areas of our
community and support infill/redevelopment
along “Enhanced Travel Corridors” such as the
Mason Corridor and Harmony Road corridor.
Also, the North Front Range MPO has recently
updated their travel demand model and staff
recommends that this new information be used
for future transportation projections for transit
and highway improvements to factor in updated
land use and transportation data sources.
5
In Figures 4-6 and 4-7, the E-W ridership numbers are totally different. Why? 5. The amount of riders on the east-west feeder buses differ between the alternatives because these buses
serve different
regional transit systems, with different route alignments and station locations. In Package A, east-west ridership is high,
as the bus feeder services to commuter rail also serve local inter-community trips. In Package B, feeder bus riders to
BRT along I-25 do not serve as many inter-city trips. In the Preferred Alternative, the feeder routes are designed similar
to Package B, and do not have as high a ridership as Package A.
Comment addressed A
6
The financial analysis in Chapter 6 is very skimpy. Is such a superficial analysis all
that is possible?
6. Cost and financial information is provided in Chapters 2 and 6 of the Final EIS. The Cost Estimate Review report,
which provides detailed information on the Preferred Alternative and Phase 1 cost estimates, is included in Cost Estimate
Review Final Report, July 2010, FHWA. For more information see the Cost Estimate Review Report, which is a
supporting technical report to this Final EIS and is available for review at CDOT Region 4.
Comment addressed, EIS financial analysis
seems to be more thorough than in DEIS. Larger
policy concern continues regarding the future of
multimodal transportation financing for our
region. The City of Fort Collins would like to
continue to be part of regional discussions
regarding potential funding strategies and
partnerships needed to implement the Preferred
Alternative shown in the FEIS as well as other
local and regional transportation needs. There
are many good partnership models from current
projects such as the SH392 & I-25 project, North
College corridor improvements, Jefferson/SH14
project, Flex transit route, and other joint
projects. We look forward to continuing to work
with CDOT and other regional partners to further
completion of these important regional
connections.
C
7
Is sufficient attention paid to freight transportation? The focus seems to be totally on
moving people.
7. Freight rail service will continue to be maintained in the corridor. The agreement with BNSF will specify the
infrastructure and operating plan requirements to allow both passenger service and freight service. The volume of truck
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 3 of 22
City Council Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
alternatives. A summary of environmental impacts is included in the Executive Summary and Chapter 7, and detailed
information is provided in Chapter 3 of the FEIS.
9
Given the enthusiasm which citizens are showing for rail, is the estimate of transit
ridership of the two alternatives accurate?
9. The transit ridership model was calibrated and validated to observed travel patterns in the Denver area. Projections
are based on empirical behavior of travelers, as well as future geographical projections of population and employment
and estimated trip origins and destinations. Recent travel survey data collected by RTD and DRCOG indicates that, as
you suggest, current actual ridership is higher than had been simulated in the model. Section 4.2.6.3 describes the
potential effect these behavior changes might have on ridership. For example, commute rail ridership might be higher by
about 40% than the earlier model estimates.
See comment to #3 above. C
10
It is important for the North I-25 EIS and recommended improvements to address the
link between transportation and environmental sustainability as well as to reflect the
visions and values of the communities.
10. The North I-25 EIS provides information to decision-makers about alternatives for transportation improvements and
their adverse impacts and benefits. Information is included in the Draft and the Final EIS about transportation impacts
and benefits as well as those related to sustainability (land use, compatibility with community visions, air q
See staff comments in both the transportation
and environmental topic areas.
C
11
It is important for transportation improvements to provide linkages between the core
areas of our communities. This “core to core” link is a very important part of Fort
Collins’ community values.
11. Comment noted. Staff continues to support this position and this is
reflected in the City’s adopted Transportation
Master Plan and City Plan. This comment is also
linked to the staff comments regarding phasing
of the Preferred Alternative Commuter Rail
service.
C
12
It seems that Package A addresses those core community values. This is not a
statement of a preferred package, but more general thoughts and feelings for this
alternative.
12. No Response Needed The Preferred Alternative, including the
proposed highway, interchange, and transit
system improvements, is consistent with City
Plan and the Transportation Master Plan
(updated in 2010-11).
A
City Council Comments (February 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
13
Good information to discuss and North I-25 EIS process should address social,
environmental, economic needs in addition to transportation needs.
These needs are all discussed in the document
Comment addressed A
14
Transportation needs to include moving people and commerce – goods & services.
These needs are both discussed in the document
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 4 of 22
City Council Comments (February 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
19
McKee Farm land may be restricted from Impacts due to GoCo agreement and/or
other agreements with funding partners.
The Commuter Rail alignment is located within existing rail right-of-way.
Comment addressed A
20
Concerns regarding water quality and storm water contaminants Stormwater Best Management Practices have been incorporated which will reduce the predicted increases in stormwater
constituent loading
See comment in Storm Water section C
21
Concerns regarding CDOT’s willingness to address City comments. Tom Anzia,
representing Felsburg Holt & Ullevig and serving as the consultant project manager
for CDOT’s North I-25 EIS project team, stated that they are responding to all
comments received on the draft document and take these comments very seriously.
They will be doing more detailed analysis as part of the current work effort as well as
during the preparation for the Final EIS document.
All comments made on the DEIS will be addressed in the FEIS
Many comments addressed in FEIS; several
still remaining as noted in these comments C
22
Interest in recent CDOT workshops. Input from Council members is important to
share with CDOT and representatives from other communities.
We have been doing this
Can CDOT staff provide summaries from
FEIS public meetings to local agencies? C
23
CDOT is hearing a lot of enthusiasm for Package A Commuter Rail service from
many communities because it serves the existing, largest population centers and
people like the idea of using rail service.
The FEIS Preferred Alternative reflects this community interest; it includes Commuter Rail from Package A, as well as
highway elements from Package B
Comment addressed A
24
Starting to hear conflicts arise between communities east of I-25 due to concerns
about current land use patterns and population centers compared with future growth
areas.
Observation noted; the FEIS compares and contrasts the potential land use effects of Package A, B, and the Preferred
Alternative
Comment addressed A
25
The average trip length on I-25 is less than three miles, so the highway is being used
for local trips, rather than the regional and inter-regional trips that it is intended for.
Cities need to address future improvements to other local north/south arterials to
service the shorter distance trips to provide alternative routes to I-25.
Hopefully communities will begin to address these local improvements
Impact/benefit of I-25 improvements will
need to be analyzed in the future when the
NFRMPO model is updated C
26
More insight on rail alternatives needs to be examined and EIS needs to coordinate
with other rail studies.
Extensive analysis of rail alternatives was conducted during the development of the DEIS and the Preferred Alternative.
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 5 of 22
City Council Comments (February 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
32
Concern was expressed by Council regarding the number of commuters that leave
Fort Collins daily to commute to Denver and/or other communities. Commuter rail
could potentially change nature of Fort Collins to become bedroom community to
Denver. Project should compare Fort Collins’ numbers to the numbers leaving our
neighboring communities. Fort Collins’ numbers are much lower.
Agreed, the number of commuters leaving Fort Collins is lower than some other communities. In fact, data from the MPO
and other sources has also indicated that the share of all northern area commuters who travel to the Denver metro area is
relatively low. The improvements proposed in the EIS do not noticeably change this pattern.
Comment addressed
A
City Council Comments (October 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
33
Prioritizing transit/commuter rail sooner versus highway widening improvements.
Implementing transit/commuter rail services earlier could defer or eliminate the need
for future highway widening.
The phasing plan developed with the TAC introduces both transit and highway improvements in Phase 1. The highway
has aging infrastructure issues that need to be addressed in early phases. Express bus on I-25 and commuter bus along
US-85 are initiated in Phase 1.
See comments on phasing C
34
Need to focus on best ways to move people, not vehicles, to meet the long-term needs
of our region;
The FEIS Preferred Alternative includes Commuter Rail, a sustainable regional transportation connection between the
core of communities. The I-25 highway facility needs rebuilding to address aging infrastructure needs. The FEIS
Preferred Alternative includes a Tolled Express Lane (TEL) on I-25, allowing HOV vehicles free travel in a restricted
lane hence supporting the alternative modes of carpooling and vanpooling. Express Bus service, with connecting bus
service to the communities, also will serve the I-25 corridor in the TEL lanes.
Comment addressed, however continued
concerns such as transit ridership projections C
35
Consider emerging larger-scale trends (fuel prices, new energy sources, demographics,
etc.) that will determine transportation needs/options in the future ;
We are aware of these trends that effect future travel. These issues will be qualitatively addressed in the FEIS.
See comments on modeling C
36
Concern over how to serve commerce related transportation (freight, goods &
services);
Freight rail service will continue to be maintained in the corridor. The volume of future freight truck traffic is accounted
for in all the traffic analyses conducted in the DEIS and FEIS. The design of I-25 and its interchanges will meet the
requirements of freight trucks.
Comment addressed A
37
Concern over a consensus approach applied by CDOT to identify and prioritize
improvements;
Please elaborate on this concern?
38
Support to preserve right-of-way for commuter rail as part of phase one improvements;
We have heard this support; Commuter Rail ROW preservation is in Phase 1
Comment addressed A
39
Need for more detailed analysis and data driven approach.
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 6 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
44
General comment: Transportation Planning staff agrees with the purpose and need
of the North I-25 DEIS. CDOT, FHWA, FTA, and their consultant team, have been
helpful to work with City staff over the years during the development of the EIS
alternatives analysis process and development of the DEIS document.
The DEIS packages “A” and “B” reflect input from City staff regarding
compatibility with the City’s Transportation Master Plan, Master Street Plan,
Transfort Strategic Plan (currently being updated) and the Mason Corridor Master
Plan, Environmental Assessment, and Preliminary Engineering documents. Either
of the DEIS proposed packages can serve Fort Collins’ transportation needs in the
future to address both highway and transit improvements.
It is important to note that further discussions are necessary with the Fort Collins
Boards, Commissions, and City Council in 2009 to reach a formal recommendation
to CDOT, and their partnering agencies, regarding a preferred package of
improvements.
The following summary includes a preview of staff comments for both packages and
notes concerns that will need to be addressed by CDOT during the development of
the preferred alternative and the Final EIS document in 2009.
1. FHWA and CDOT would like to thank you for your involvement. Your input is critical to the success of this project. Transportation Planning staff would like to offer
the same appreciation to CDOT staff and their
consultant team for their work with City staff and
City Council over the years and supports the
recommended Preferred Alternative however we
offer these formal comments on the FEIS for
CDOT’s consideration at this time as well as for
input for the future implementation phases of the
highway and transit improvements.
A
Travel Model:
45
In terms of more specific comments and concerns, Transportation Planning staff
recommends that future travel demand forecast modeling be updated by CDOT and
their consulting team as part of the selection process for the preferred alternative and
Final EIS analysis process to ensure that the most recent transportation and land-use
data is used for determining long-term transportation improvements. Also, separate
land use data assumptions should be developed for each of the two packages of
alternatives based on the expected land use changes that would be driven by the
proposed transportation corridor improvements to more accurate reflect the inter-
relationship between land use and transportation planning.
2. The FEIS includes updated long-term forecasts to reflect 2035 RTP socioeconomic and network conditions. Agreed,
separate land use forecasts would more accurately reflect the inter-relationship between land use and transportation
infrastructure. Since the highway improvements are generally similar between packages, an expert panel concluded that
future growth along I-25 would not substantially differ between the packages. The commuter rail of Package A and the
Preferred Alternative would tend to attract growth near station areas in city centers, in contrast to the I-25 BRT and
express bus of Package B and the Preferred Alternative, but the magnitude of the differences would be relatively small.
For these reasons, the results of the comparison and evaluation of alternatives with different land use sets would not have
differed appreciably from the results with a single land use data set. Separate forecasts were not prepared due to the
constant need for prudent use of study resources.
CDOT did update the long-term forecasts to
2035 which should more accurately reflect the
future travel demand. However see prior staff
comments items regarding continuing modeling
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 7 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
48
Package A
The proposed improvements shown in Package A, the regional commuter rail
service and addition of general purpose lanes on I-25, are very effective to address
high-quality transit system improvements as well as general highway travel, safety,
and freight improvements to serve the Fort Collins community and North Front
Range region.
Package A includes the commuter rail transit alternative using the existing BNSF
railroad tracks through Fort Collins and staff agrees with the three passenger rail
stations shown at the City’s Downtown Transit Center, Colorado State University’s
Main Campus, and at the City’s South Transit Center. Staff appreciates CDOT co-
locating the commuter rail stations at the same stations as the City’s Mason Corridor
Bus Rapid Transit stations to allow for easy passenger transfers. This convenience
and potential travel time savings could affect the transit ridership projections and
that is one of the reasons for staff’s request that future travel modeling (roadway &
transit) be completed by the North I-25 EIS team.
5. The modeling for the FEIS has been updated to include the Mason Street BRT since it is a committed project; the effect
of co-locating the three stations in Fort Collins is reflected in the ridership projections for Package A and the Preferred
Alternative. Similarly, the FEIS modeling for Package B includes the Mason BRT and the effect of a common BRT station
at the South Transit Center.
The updated modeling reflects the City's
comments regarding adding Mason BRT.
A
49
City Transportation Planning staff does not agree with the need for double-tracking
of the BNSF railroad tracks from Prospect Road north through Downtown and
believes that the existing single track is sufficient to operate service through
Colorado State University (CSU) main campus and through Downtown Fort Collins,
as the DEIS states is shown for the downtown Loveland area. Staff has previously
shared this comment with CDOT staff and their consultant team.
From Transportation Planning’s perspective, the regional commuter rail transit
alternative, while initially more costly than bus service, is an effective transit
configuration for Fort Collins’ and Northern Colorado’s long-term future because it
centers high-quality regional transit service in the heart of the communities along
the US287/BNSF railroad corridor to serve the largest population centers.
Particularly for the Fort Collins community, the regional commuter rail corridor and
three passenger stations are located along our highest density population centers
such as Downtown, CSU, and the US287/College Avenue corridor. Locating the
regional transit service along this high population corridor allows for easy access
from local activity centers and neighborhoods and minimizes the need for people to
drive or take local transit routes to access regional transit service.
6. Note that Package A has single track between University and the downtown transit center. During development of the
Preferred Alternative, single track for the corridor between South Transit Center and downtown Fort Collins was
evaluated in further detail, as you suggest. As a result, it was concluded that single track would have fewer
environmental impacts while accommodating the Mason Corridor BRT. However, it was necessary to revise the service
pattern on this segment of the corridor. The service plan for the Preferred Alternative consists of hourly service to/from
downtown Fort Collins, with 30 minute service maintained to the South Transit Center during the peak periods. Package
A and the Preferred Alternative serve the population centers of Fort Collins as you describe. Package B only directly
serves the College Avenue Corridor at the South Transit Center.
The Preferred Alternative supports the single
track as suggested by the City.
A
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 8 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
51
Also, the long-term return on investment that is likely to occur within Fort Collins
due to the location of the three proposed regional commuter rail stations would be a
strong economic catalyst for additional higher density, mixed-use, transit-oriented
development (TOD) over and above what is currently envisioned as part of the
Mason Corridor. The potential synergy of high quality local and regional transit
service along this central corridor of the Fort Collins community will greatly serve
our long-range economic vitality and environmental stewardship values, as well as
address our established transportation and land-use goals.
The regional commuter rail service along the existing BNSF railroad tracks/corridor
will also link Fort Collins into Denver’s Regional Transportation District (RTD)
FasTrack “Northwest Rail Corridor” commuter rail line that begins in Longmont.
This provides a cost-effective opportunity to link the North Front Range regional
commuter rail improvements proposed in the North I-25 EIS to the already approved
and funded FasTrack’s Northwest Rail Corridor. This is a synergistic way to link
regional commuter rail passengers from Fort Collins, Loveland, Berthoud to both
Denver Union Station as well as to the Boulder area.
In regards to adding the general purpose lanes shown along I-25, these additional
travel lanes will address safety concerns along I-25 and at the interchanges shown
within Fort Collins area, as well as serve as an effective means to address current
and future vehicle traffic capacity needs (automobile & freight traffic). These
general purpose lanes will not limit the use of the new travel lanes to high-
occupancy vehicles or require tolling. It is important for the EIS to address both
passenger and freight transportation needs.
8. Yes, Package A and the Preferred Alternative connect to the RTD FasTracks system via commuter rail at both
Longmont and the North Metro end-of-line, and in downtown Denver. In contrast, the BRT of Package B connects only in
downtown Denver. We agree with your assessment that commuter rail stations will be a strong economic catalyst for
higher density, mixed use TOD. Values of TOD adjacent properties in the US have increased from 6.4 percent to more
than 40 percent in the past few years. Office buildings have fewer vacancies if located within walking distance of a transit
station. As you state, the general purpose lanes of Package A provide additional capacity and are not restricted by
vehicle type. The Preferred Alternative includes adding both general purpose lanes and tolled express lanes to I-25 which
will similarly address both passenger and freight traffic needs.
The Preferred Alternative, particularly commuter
rail, is in line with the City of Fort Collins goals
to support TOD development, and providing
regional connections.
A
52
Package B:
Transportation Planning staff has reviewed CDOT’s DEIS Package “B” that
includes regional Bus Rapid Transit (BRT) service originating from the City’s South
Transit Center and making stops at the intersection of Harmony & Timberline roads
as well as at the Harmony & I-25 Transportation Transfer Center and then traveling
to the Denver area along the center of I-25 in the High Occupancy/Toll (HOT) lanes,
also referred to in the DEIS as the Tolled Express Lanes (TEL).
The South Transit Center would be a primary connection point for passengers
transferring to/from the regional BRT service to the City’s Mason Corridor BRT
service as well as other local Transfort routes. In addition, the regional BRT service
would link into the City’s future plans for the Harmony Road “Enhanced Travel
Corridor” shown on the City’s adopted Structure Plan, Transportation Master Plan,
and Transfort Strategic Plan. The down side of the regional BRT alternative is that it
does not directly serve the core population and activity centers within Fort Collins
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 9 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
toll for speed/convenience purposes. Staff’s concern is that the major improvement
would not address general travel needs for people who cannot afford the tolls nor do
these specially designated lanes address the needs of additional highway capacity for
freight vehicles.
53
General:
Overall, Package “A” and “B” are both sound alternatives and propose important
transportation safety and capacity improvements for highway users and transit
passengers to address the purpose and needs identified for the EIS process.
However, it is important for the North I-25 EIS and community stakeholders to
develop effective long-term solutions for our inter- and intra-regional transportation
needs based on the anticipated future needs for travel, land-use, energy
consumption, sustainability, and environmental concerns – not based on past needs
and trends. The next 20, 30, and 50 years will bring significant changes to our
communities, region, state, nation, and world and we need to be planning for the
future – not based on the past.
All of the proposed improvements (highway and transit) come at a steep price tag
and CDOT, FHWA, and FTA will need to work collaboratively with all of the North
Front Range communities, counties, and metropolitan planning organizations to
strategize workable financing options for any of these proposed future regional
transportation infrastructure improvements.
Transportation Planning staff will continue to be actively involved with CDOT,
FHWA, and FTA throughout the development of the final EIS document and will
make every effort to convey the input and concerns from the Fort Collins’ City
organization, City Council, and community members to influence the final
recommendations for these significant regional improvements.
10. The Preferred Alternative has been developed through a collaborative decision making process with communities and
stakeholders from the study area. The future horizon year of 2035 has been used in the analyses presented in the Final
EIS. The 2035 socio-economic projections use the adopted land use data sets of the NFRMPO and DRCOG. Each of the
alternatives provides multi-modal solutions that provide transportation choices for future travelers. Note the evaluation
for 2035 does not rely on a historical trend analysis but utilizes a travel model based on reasonable assumptions of future
transportation conditions.
At this point in the planning process, the only funds identified in the FEIS are those likely to come in through traditional
funding sources over the next 25 years. These funds, and the projects associated with these funds are identified in the
fiscally constrained regional transportation plans (NFRMPO and DRCOG). While the toll lanes have the ability to
generate revenue and provide opportunities for bonding, the FEIS does not make any recommendations for or against
implementation through this means of funding. Additional funding identified by state, federal and local agencies will
enable projects in Phases 2 and 3 to be implemented sooner. Fort Collins will continue to participate in determining how
and which projects are funded in the North Front Range through their role on the NFRMPO Technical Advisory
Committee and the NFRMPO Planning Council. The TAC advises the Council and the council is the decision-making
body. Fort Collins has a seat on each.
Thank you for your continued involvement in the process.
Fort Collins appreciates CDOT's efforts to
include collaborative input from a wide spectrum
of communities and stakeholders. The Preferred
Alternative is consistent with the City
transportation and land use plans.
One of the most significant concerns the City
continues to have regarding the FEIS document
is the proposed phasing.
Implementation phasing for the various
transportation improvements, specifically the
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 10 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
development of the FEIS. As we have stated, the
implementation phasing for the various
transportation improvements is a continued
concern, specifically the phasing plan shown for
the future commuter rail service extending from
Loveland to Fort Collins is not shown until Phase
3 (CDOT expected timeframe of 2075+). Staff
recommends that CDOT revise the FEIS to only
show two phases – Phase 1 as shown now, as the
“fiscally constrained plan” based on anticipated
funding levels through 2035. Then, the new
“Phase 2” would include all of the remaining
elements of the Preferred Alternative and be
considered the “unfunded” items and not be tied
to an artificial, 50-60+ year time horizon. These
transportation improvements – highway and
transit – shown in Phase 2 for 2055+ and Phase 3
for 2075+ need to be implemented sooner rather
than later to serve the regional travel demand
forecast for 2035. Dividing them into two
artificial phases with these extreme timeframes
does not solve the issue that the future regional
transportation needs significantly outpace our
current funding sources. The EIS Preferred
Alternative should be a catalyst for convening
regional discussions and partnerships to work
together toward accomplishing these needs
within the 2035 timeframe.
55
Correct reference is the “Mason Corridor”, not
“Mason Street Corridor” nor the “Mason Street
Transportation Corridor”. The correct location
for the “South Transit Center” is located along
the Mason Corridor near west Fairway Lane (not
at Harmony Road). The correct location for the
CSU station is along the Mason Corridor
between University Avenue and Pitkin Street.
Please correct various text references as well as
map “call out boxes” for accuracy and
consistency throughout the FEIS document and
all maps. Also, the opening day for Mason
Corridor “MAX” BRT service is not 2014 based
on the latest schedule information from the
City’s Engineering department. For more details
regarding the MAX BRT project, please contact:
Helen Migchelbrink, City Engineer, at (970)
218-1409 or via e-mail:
hmigchelbrink@fcgov.com.
N
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 11 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
56
Page 2-64, will the new Park & Ride location
being built as part of the current SH292 & I-25
interchange project accommodate the future
parking demand (95 additional spaces) shown in
the FEIS?
N
57
The proposed Quiet Zone noise mitigation
strategies in the FEIS along the BNSF corridor
are consistent with the City’s plans to evaluate
potential Quiet Zone improvements along this
corridor to address noise impacts associated with
the existing freight rail operations as well as
future passenger rail service.
N
58
I-25 highway improvements north of Harmony
Road need to accommodate the future extension
of the regional Poudre River Trail that will
connect Fort Collins and Timnath and ultimately
connect through to Greeley.
N
59
Regional “Foxtrot” route is now referred to as
“Flex” and connects from Fort Collins through
Loveland to Longmont where is connects into
RTD’s transit system.
N
60
The list of Access Control Plans listed in the
FEIS (Chapter 2, section 2.1.3 should also
include the two access plans for US287 – North
College and South College Access Control Plans.
N
61
Chapter 2, regarding coordination with other
regional rail studies, are the future design plans
for I-25 interchanges shown in the FEIS taking
into consideration the long-term potential for
high speed rail? For example, are bridges over I-
25 being designed with a “clear span” to allow
for future opportunities for rail transportation in
the center of I-25?
N
62
Page 2-15 seems to be missing a graphic diagram
of the future plans for improving the I-25 &
Prospect interchange – this interchange location
is mentioned in the text, but not included in the
page of images.
N
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 12 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Avenue).
64
Pages 2-24 and 2-74, please note that the City of
Fort Collins’ Master Street Plan shows grade
separated roadway crossings of the BNSF
railroad at Drake Road and Trilby Road. This
information is important for the Commuter Rail
route shown in the Preferred Alternative and will
help address safety, traffic operations, and noise
concerns.
N
65
Sections 2.2.2.11 and 2.2.4.9, City does not what
physical barriers to view sheds and wildlife
movement corridors in Fort Collins.
N
66
Page 3.1-4, please include the City of Fort
Collins in the list of I-25 corridor municipal
plans (not just on the US287 list of
communities). Also, please revise the title of the
City’s plan to be “Plan Fort Collins” which
includes both City Plan and the Transportation
Master Plan – these plans were updated in 2010-
11.
N
67
Page 3.1-7, regarding zoning, please note that the
City of Fort Collins has a designated “Transit
Oriented Development Overlay Zone” in our
Land Use Code that covers the entire length of
the Mason Corridor BRT system.
N
68
Page 3.1-11, regarding land use, please correct
the statement regarding Fort Collins. The City’s
adopted comprehensive plan “City Plan” calls for
higher density, mixed use, infill and
redevelopment along the US287 and Mason
Corridor. This is the area covered by the TOD
Overlay Zone. Our city plans do not envision
this corridor as built out or remaining the same as
today – it is a focus area for targeted infill and
redevelopment supported by high-quality transit
service and multimodal transportation choices.
N
69
Page 4-2, the more recent update to the City’s
comprehensive plan is “Plan Fort Collins in
2010-11 which includes both City Plan and the
Transportation Master Plan. The 2004 updates
are no longer the most current documents.
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 13 of 22
Transportation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
to the local arterial streets from the planned
highway and transit improvements shown in the
FEIS.
71
Section 4.2.6, additional question regarding
transit projections, it seems odd that the
Commuter Rail ridership projections are shown
to be lower than the projections for the I-25
express bus when the Commuter Rail route and
stations are located in higher density population
centers such as Downtown Fort Collins. When
future model projections are run for the
implementation phases of the proposed regional
transit system improvements, staff suggests that
CDOT, NFR MPO, and local communities work
together to update these projections.
N
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 14 of 22
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Part I: Natural Areas
72
General comment: The most troubling issue noted is the possibility of a chain link
fence installation along the commuter rail through Natural Areas in the southwest
portion of Fort Collins. The fence would be highly disruptive to wildlife movement.
11. The intent of the Preferred Alternative is to include fencing along the rail corridor to limit access and improve safety
and to adhere to current RTD fencing standards and requirements. However, it is also recognized that the type of fencing
may vary depending upon adjacent land uses, wildlife use, or specific safety concerns. The FEIS will list a range of
fencing options to consider during the design process. This includes wildlife friendly fencing and could potentially include
wildlife underpasses. The actual fencing selected during the design process will be based on consideration of need and
function.
A
73
General comment: Maps for the EIS are not current and many City of Fort Collins’
Natural Areas and Parks are not shown.
12. All maps have been updated with new information that has been collected from the municipalities. The City of Ft.
Collins has been directly contacted and they have provided updated GIS files showing all parks and natural areas as well
as many other land use and transportation information. We believe we now have all City of Ft. Collins natural areas and
parks correctly identified and this information has been used in the FEIS.
A
74
3.1: Land use. These figures only show land uses as of 2000 and should be updated.
Figure 3.1.2 doesn’t show any open space/parks in Fort Collins. Figures 3.1-3
through 3.1-6 do not show all of the Fort Collins area open space/parks. For
example, Fossil Creek Regional Open Space is shown as an employment area, even
in the 2030 projection.
13. All maps have been updated with new information that has been collected from the municipalities. The City of Ft.
Collins has been directly contacted and they have provided updated GIS files showing the most recent land use data for
the city. The mistakes in the referenced maps have been recognized and corrected in the FEIS. Additionally this updated
information has been used in the Final EIS.
The map line weights in this section are so thick
the underlying land use is difficult to determine.
More detailed map sections reflecting individual
communities would be helpful.
Longview Open Space is shown as agriculture.
It should be shown as open space and was
designated open space at the time of mapping.
C
75
3.10.5: Vegetation. Statement regarding “develop an acceptable revegetation plan”
should note that the plan must be acceptable to the City of Fort Collins within its
jurisdictional areas, not just acceptable to Larimer County.
14. The text has been changed to state that the revegetation plan must be acceptable to the City of Fort Collins within its
jurisdictional areas.
A
76
3.10-5. Vegetation. Removal of large cottonwood trees at the Cache La Poudre and
Big Thompson rivers will seriously impair the quality and functionality of the
riparian habitat. Bald eagles and other raptors frequently use these areas to perch and
hunt from. Similarly the continuous “thread” of riparian habitat is critical to wildlife
movement up and down the river corridors. Also, it is not possible to mitigate the
loss of a large-diameter native cottonwood tree.
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 15 of 22
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
collisions/etc.
The 3,000 acre native prairie habitat between
Fort Collins and Loveland should be designated
a sensitive habitat and consider/mitigate impacts
as such. Please include this in your mitigation
plan for the project.
FEIS fails to recognize Fossil Creek Reservoir
as an Audubon Society designated Important
Bird Area. The reservoir has extremely high
value for migratory waterfowl and other
waterbirds other than the Bald Eagle.
79
Figure 3-18-1. Parks and Recreation. There are quite a few missing natural areas and
open spaces on the map, including Fossil Creek Reservoir Regional Open Space,
Coyote Ridge Natural Area, Long View Farm Open Space.
18. These natural areas and open space properties were identified for the FEIS process. Please see updated Figure 3.18-1.
None of these open space and natural areas were identified as being impacted by the alternatives under consideration.
A
80
Table 3-18-2. Parks and Recreation. This figure is not up to date. There is
misinformation about Fossil Creek Reservoir Natural Area (confused with the
Regional Open Space; location is east of Timberline, not Timber Lake; etc.).
19. The figure and table have been updated to include the missing open space and natural area properties. Fossil Creek
Reservoir properties have been correctly identified including their location. This property is not impacted by the
alternatives under consideration.
A
81
3-18-3. Parks and Recreation. There will be direct impacts to Long View Farm
Open Space, and Colina Mariposa, Hazaleus, and Red-tailed Grove natural areas, as
well as indirect impacts (due to proximity) to other natural areas. The EIS states that
no parks or recreational resources will be impacted by the commuter rail alternative;
however that cannot possibly be true because it goes through and next to a number of
natural areas.
20. A Preferred Alternative that includes commuter rail has been identified and, along with Package A and B, has been
analyzed in the FEIS. Impacts to these natural areas have been fully assessed in that document. The referenced natural
areas (as well as a complete update to all land use information) have been identified and the design team is recognizing
the potential for impacts to these resources and will make every effort to avoid or minimize impacts under all 3 build
alternatives. The Preferred Alternative identifies single-tracking in this area that will remain within the existing right of
way of the rail corridor which will generally negate any direct impacts to the natural areas. Fencing will be included in all
areas where pedestrian safety is a concern. Indirect impacts such as noise, and visual impacts will be fully evaluated and
the Ft. Collins Natural Resources Staff comments will be taken into account.
A
82
3.6. Noise. Noise studies should be conducted at Arapaho Bend Natural Area in Fort
Collins. Any expanded use as part of the alternatives analysis needs to consider this
site. This open space managed by the City of Fort Collins fall into “Land Use
Category A”. City staff has noticed that noise levels likely exceed the maximum dB
levels outlined by CDOT. This area on the northwest corner of I25 and Harmony
Road in Fort Collins should be evaluated.
21. A TNM model receiver at Arapaho Bend was included in the FEIS analysis, even though developed facilities are not
present at the site. Also, local traffic noise conditions were represented by Receiver B012 at the nearby Strauss Cabin.
Please note that the project team feels Arapaho Bend is a Category B site rather than Category A (e.g., amphitheater). The
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 16 of 22
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
contaminants) within the Cache La Poudre watershed above the current situation or
under the no-action alternative.
anticipated, for example, to remove 50 percent to 70 percent of total suspended solids, which accounts for the predicted
increase in loading.
85
3.8-12 (line 39). Wetlands. The EIS identifies the “former rest area site north of the
Cache La Poudre River” as a potential mitigation site. In fact that land was
transferred to the City of Fort Collins and is not available as a mitigation site.
24. Comment noted. The relevant statement has been revised and will not include discussion of this site as a potential
mitigation site to offset impacts to wetlands and other waters of the US.
A
86
3.9-12. Floodplains. Impacts to natural vegetation and wetlands along Spring Creek
and Fossil Creek need to be avoided or mitigated. Wetlands in these areas are highly
valued by wildlife including sensitive aquatic species. More detailed analysis is
necessary.
25. Any actions that result in a permanent dredging or filling of wetlands are required to be permitted by the US Army
Corps of Engineers (USACE). As part of this permitting process, mitigation will be required. The first step in this process
is avoidance or minimization of wetland impacts. At Spring Creek, avoidance measures have been implemented so no
wetland impacts occur. At Fossil Creek, Package A has 0.05 acre of wetland impacts. The Preferred Alternative has 0.01
acre of wetland impact. This small amount of wetland impact has been included in the mitigation package being reviewed
by the Corps of Engineers for the Section 404 permit.
Wetlands impacted in the Fort Collins regional
area should be mitigated within (the same) Fort
Collins regional area.
Local mitigation requirements per City of Fort
Collins Land Use Code should be considered
for locally (Fort Collins) impacted wetlands.
We support the mitigation of both federally
jurisdictional and non-jurisdictional wetlands
throughout the project area.
C
87
3.9-20 (line 6). Floodplains. The proponents of this project need to identify where
wetland mitigation would take place. CDOT or private lands would need to be
identified for the mitigation.
26. CDOT is currently discussing possible wetland mitigation sites with Fort Collins staff and the U.S. Army Corps of
Engineers. The details are in the Section 404 Permit application, which has been provided to the U.S. Army Corps of
Engineers.
A
88
3.9 (General Comment) Floodplains. The mitigation measures for each creek, river,
or other drainage is vague, not site specific, and makes it impossible to evaluate for
direct and indirect impacts to wetlands and floodplains. The same four mitigation
measures are identified for separate drainages. Revised, site specific mitigation plans
for each drainage should be conducted for the public and appropriate stakeholders to
comment on.
27.Mitigation measures that will be employed consistent with each alternative include: The 100-year FEMA design flows
will be used for freeboard determinations, scour design, and to ensure that flow velocities are acceptable. The 500-year
design flows will be used to further assess the scour design and set the depths of piles or caissons. The design will
consider the maximum allowable backwater as allowed by FEMA. Degradation, aggregation, and scour are to be
determined. Adequate counter measures will be selected using criteria established by the National Cooperative Highway
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 17 of 22
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
alternatives. stations that can serve as a stimulus to TOD
Changed conditions
92
The recent volatility in gasoline prices suggest that the basis of long-range land use
and transportation planning may now be in question. For example, what if the land
use projections of I-25 corridor communities prove incorrect under a scenario of
$3.00/gallon gasoline, or $4.00, or $6.00? What if the trip-production rates used in
transportation forecasting are incorrect for the same reason? The EIS should address
the risk of making a poor choice from among the alternative due to the uncertainty of
future gasoline prices.
31. The EIS forecasts are conservative as no change in the relative cost of gasoline is assumed, because predicting the
price of fuel would be impracticable. The forecasts are based on the adopted future population and employment forecasts
of the NFRMPO and DRCOG. If the price of gas dramatically changes, it could indeed influence land use development
activity as well as travel behavior patterns. The FEIS acknowledges that the future price of gas is an unknown and
therefore introduces an uncertainty into the forecasts, as described in section 4.2.6.6.
We are disappointed the FEIS cannot address
possible changes in fuel price as this is likely to
have a large impact on future transportation
choices. We hope that roadway investments
made in the near future will not become
stranded assets as mode shift occurs. We are
glad to see the statement that the transit system
in the Preferred Alternative can accommodate
up to a 90% increase in transit mode share.
C
Greenhouse gases
93
Several communities in the I25 corridor have adopted policies and/or plans to address
their contribution to greenhouse gas emissions. The reduction of transportation
carbon emissions, which is directly proportional to vehicle miles traveled, is critical
to the success of these community efforts and the EIS should address the contribution
of the I25 decision toward their success or failure.
32. The DEIS and the FEIS both address the effect of the project alternatives on carbon dioxide, which is used as the
surrogate for greenhouse gas emissions. Package A produces 0.8 percent more carbon dioxide than the No Action
Alternative, Package B produces 0.4 percent more, and the Preferred Alternative produces 0.9 percent more. The City of
Fort Collins has developed a Climate Action Plan to help reduce Greenhouse Gas (GHG) emissions. The intent is to
reduce GHG emissions by the end of 2012 to a level not to exceed 2,466,000 tons of CO2. This will be achieved by the City
implementing measures to reduce VMT, which in turn would reduce GHG emissions. It is estimated that 5 to 10 percent of
automobile trips can be moved to non-motorized transport which would reduce the total VMT by 1 percent by 2012. There
are several transit projects proposed within the Denver Metro area. The Mason Corridor transit system will serve as the
backbone for the enhanced transit system in Fort Collins. Over time (after 2035), it would be expected that the rail
components of Package A and the Preferred Alternative would provide more options for lower energy consumption
because more trains could easily be added as demand increases.
The FEIS briefly discuses carbon dioxide
equivalent emissions in Section 3.21 (Energy).
Estimates show that the preferred alternative
would increase CO2e emissions by 0.9% above
the No Action alternative. This is slightly more
than any other alternative and is attributed to the
impact of attracting more VMT from other
areas. If no other circumstances changes, it
would be a serious problem for this huge
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 18 of 22
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
power plants, residential wood burning, forest fires, agricultural burning, and some industrial processes. Because these
smaller particles penetrate deeper into the respiratory system, they have a strong association with circulatory (heart
disease and strokes) disease and mortality.
policy to achieve continual improvement in air
quality. However, all alternatives including the
Preferred Alternative show lower CO hotspot
concentrations at Harmony and I-25 than the No
Action Alternative (Table 3.5-10). The
Preferred Alternative also provides reduced
arterial VMT, and reduced crashed/VMT.
In order to help mitigate the increased
emissions, the best available transportation
technology should be implemented in all cases.
as well as transportation demand management
strategies.”
PM2.5
95
The Air Quality analysis does not address PM2.5, presumably because there are no
non-attainment areas with the project study area. However, discussion of particulate
matter levels in the Affected Environment chapter (page 3.5-7) acknowledges that
PM2.5 24-hour maximum concentrations show a steady trend of increasing in many
areas. In light of this, PM2.5 impacts of alternatives should be addressed.
34. A project level PM2.5 analysis was not conducted since the Denver Metro area and the North Front Range are in
attainment for PM 2.5. However, precursors of PM2.5 include NOx and VOC. Emissions for this were projected for this
project. Table 3.5-4 summarizes the regionwide total mobile source emission estimates for existing, No Action and the
three build packages. For NOx, emissions estimates show very substantial reductions of approximately 164,000 tons per
day for all build alternatives, compared to existing levels. For VOC, the anticipated reduction is 58 tons per day. These
reductions illustrate the likely conclusion that vehicle emissions of PM 2.5 impacts are not anticipated in the future, with
or without the project improvements.
The address for the PM2.5 monitor station in
Fort Collins in Table 3.5-2 should be changed to
708 South Mason Street. C
More Specific Comments:
96
3.5 Introduction
The DEIS text in the introductory section of the air quality chapter should be updated
to reflect that areas within the project have been designated non-attainment for the
federal 8-hour ozone standard in November 2007, per discussion in section 3.5.2, line
3.5.2- Affected Environment
Figure 3.5-1 should be updated to reflect the non-attainment designation area for the
8-hour ozone standard. This non-attainment designation should be discussed clearly
in this section, as well as the updated, more stringent 8-hour ozone standard that was
promulgated in March 2008.
The EIS states, on lines 13 and 14, that: “Other criteria pollutants are no longer
pollutants of concern in the Front Range area.” In fact, particulate matter levels even
below the federal health standards impact the health of individuals with respiratory
sensitivity. The City of Fort Collins has a policy to “continually improve air quality
as the city grows”.
Table 3.5-2 should be updated to reflect the second ozone monitoring site that was
established in west Fort Collins in 2006 and should be updated to reflect data reported
through 2007, not 2005.
Discussion of criteria pollutants should acknowledge that the Fort Collins West
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 19 of 22
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
also has a Climate Action Plan. Regional transportation planning and projects are
one of the major avenues for reducing greenhouse gas emission from the
transportation sector. In April 2007, the U..S. Supreme Court ruled that greenhouse
gases such as carbon dioxide fit within the definition of "air pollutant" under the
Clean Air Act ("Act") and the EPA is now in the process of determining whether, in
its judgment, greenhouse gases cause or contribute to air pollution "which may
reasonably be anticipated to endanger public health or welfare." It is conceivable that
greenhouse gas emissions will need to be addressed more rigorously in future NEPA
processes.
3.5.3.4 - PM analysis
97
The Air Quality analysis does not address PM2.5, presumably because there are no
non-attainment areas with the project study area. However, discussion of particulate
matter levels in the Affected Environment chapter (page 3.5-7) acknowledges that
PM2.5 24-hour maximum concentrations show a steady trend of increasing in many
areas. In light of this, PM2.5 impacts of alternatives should be addressed.
36. See response to the “PM2.5” Staff Comment #34.
C
Parks & Recreation Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
98
Comments on the DEIS from the view point of affected City of Fort Collins parks and
trails:
No-Action Alternative: No impact on Fort Collins parks and trails.
Section 3.18 Parks and Recreation, Review:
Archery Range, Creekside Park, Lee Martinez Park, Old Fort Collins Heritage Park
and Washington Park listed as being in the area of the project. Only affected park is
the Archery Range.
Package A: Archery Range impact of 0.09 acre. Construction would be coordinated
to minimize impacts with the use of BMPs to limit erosion, public safety and City
vegetation requirements used to repair disturbed areas. Coordination and mitigation
measures would be refined in more detail as the specifics of the proposed alternative
are developed.
Package B: Archery Range impact of 0.14 acre. Construction would be coordinated to
minimize impacts with the use of BMPs to control erosion, public safety and City
vegetation requirements used to repair disturbed areas. Coordination and mitigation
measures would be refined in more detail as the specifics of the proposed alternative
are developed.
37. Your review of the impacts is appreciated. The Preferred Alternative and Package A and B have been evaluated with
respect to parks and recreation resources, and is presented in the FEIS.
I-25 improvements need to be designed to
accommodate the Poudre River Trail extension.
Commuter Rail improvements along BNSF
need to be designed to accommodate the Fossil
Creek Trail.
N
Advance Planning -
Historic Preservation Office Staff Comments (December 2008)
CDOT Response / Final EIS Staff Analysis (2011) Status
99
The City of Fort Collins Historic Preservation Office has reviewed those sections of
the North I-25 Draft EIS document pertaining to historic properties within the Fort
Collins Growth Management Area. Staff concurs with the findings that there will be
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 20 of 22
Regulatory and Government Affairs Division Staff Comments
(December 2008)
CDOT Response / Final EIS Staff Analysis Status
Section 3.7 Water Resources
100
3.7.1 Water Resources Regulations
General Comment: While the CDOT MS4 requirements described are generally only
applicable in MS4 areas, please note that all local MS4 construction and development
requirements must also be met within the local MS4 jurisdictional boundaries.
39. While there currently exists a statement that the project must also comply with local MS4 requirements (Page 3.7-2,
lines 19-20), an additional statement regarding construction and development/new development compliance has been
added.
A
101
Table 3.7-5
Both packages A and B are projected to increase stormwater contaminant loading by
approximately 50% for all modeled contaminants within the Cache La Poudre
watershed above the current situation or under the no-action alternative. Runoff
intensity and volume and higher pollutant loading are some issues commonly
associated with increased imperviousness.
The modeled pollutant loadings are before the application of best management
practices. Does this include both those used during construction and permanent water
quality structures?
With packages A & B, a much larger percentage runoff from the roads and other
impervious surfaces will be treated via water quality ponds or other BMPs than the
current situation or the no-action alternative. This area is figured based on current and
projected future MS4 areas and the area available for BMPs within the right-of-way.
The pollutant removal rates for structural BMPs are given as follows:
TSS - 50-70%
Total P - 10-20%
Zn - 30-60%
Cu - 1.4-30%
Chloride - not given
While this may appear that the increased pollutant loadings will not be adequately
treated for all parameters, increased impervious area will be treated with packages
A&B.
40. The predicted constituent loadings from the Package A, Package B, and the Preferred Alternative presented in the
EIS do not include the application of permanent BMPs. All of the alternatives would show an increase in contaminant
runoff in the Cache la Poudre watershed of approximately 50 percent, without the application of permanent BMPs. As
discussed in the mitigation section, the permanent water quality BMPs are expected to remove approximately 30 to 70
percent of various contaminants. Currently, there are no quantifiable removal rates for temporary construction BMPs
in Colorado. The removal percentages cited by the commenter are for permanent water quality structures and represent
the current level of understanding in Colorado, and the BMPs associated with all action alternatives, including the
Preferred Alternative are anticipated to reduce the pollutant load by the percentages identified in the comment.
A
City of Fort Collins Water & Wastewater Utilities Department
Staff Comments (December 2008)
CDOT Response / Final EIS Staff Analysis (2011)
Water Quality and Floodplains
Technical Report
Status
102
No comments submitted N/A 1) Pg 65, 5th bullet from top. Add to
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 21 of 22
incorrectly stated. The City of Fort Collins
highly supports removing the split flow if
regulatory issues can be resolved through
mitigation with CDOT and staff working
together during design phase. State, Federal
and local regulations will all be adhered to
during the design phase.
104
3) Pg 71, table 6-1. Would be helpful to add
column indicating what floodplain and what
jurisdiction each tributary is in. For
example, Boxelder Creek side drainage –
FEMA Regulatory Floodplain, City of Fort
Collins jurisdiction.
N
105
4) Section 6.4.1, 6.4.2, 6.4.3, For each structure
improvement or modification listed, include
what floodplain, and what jurisdiction it is
in. N
106
5) Pg 83, unclear what GPL and GP represent.
Would suggest defining these more clearly.
N
107
6) Pg 85 first bullet, Unsure where this is.
Would be helpful to more clearly show
location on map of each improvement
detailed in bulleted text for the No Action
alternative, Package A and Package B.
N
108
7) Pg 87, Reference to Spring Creek and BNSF
mid page. There are two projects currently
in process at this location, Choice Center
and the Mason BRT project. Both projects
have approved Conditional Letter of Map
Revisions (CLOMRs). Please contact Brian
Varrella, bvarrella@fcgov.com , 970-416-
2217 for more information on this location
and correct statements for this section.
N
109
8) It is very probable a FEMA Conditional
Letter of Map Amendment (CLOMR) and
Letter of Map Amendment (LOMR) will be
required for work performed in a FEMA
regulatory floodway. Close coordination
with the administering local Floodplain
Administer will be required for all work in
the floodplains, flood fringes and floodways
to ensure all projects within the FEMA
regulatory floodplains meet federal and local
ATTACHMENT 2
North I-25 Final Environmental Impact Statement
City of Fort Collins Comments / Comment Response Tracking Sheet
A= Comment Addressed
C= Continued Concern
N= New Comment
Page 22 of 22
110
9) PG 93 last paragraph, add the following or
similar statement: All Federal and Local
floodplain regulations will be followed by
CDOT for each project. Floodplain
modeling will be required on many
improvements per Federal and Local
requirements. CDOT will coordinate with
local jurisdiction floodplain administration
in the initial stages of each project.
N
FACT SHEET
North I-25 Environmental Impact Statement
August 2011
Project Overview
The Federal Highway Administration (FHWA), in coop-
eration with the Colorado Department of Transportation
(CDOT), is completing an Environmental Impact State-
ment (EIS) to identify and evaluate multi-modal trans-
portation improvements along approximately 60 miles
of the I-25 corridor from the Fort Collins-Wellington area
to Denver. The EIS addresses regional and inter-regional
movement of people, goods and services along I-25.
Preferred Alternative
Over the past year, CDOT has been working closely with
FHWA and local agencies to identify a preferred alterna-
tive. With guidance from public comments submitted on
the Draft Environmental Impact Statement (DEIS) and an
extensive collaborative effort, a preferred alternative has
been identified which will include the following elements:
• General Purpose Lanes – one new general purpose
lane in each direction of I-25 between SH 66 and SH
14.
• Tolled Express Lanes (TEL) – one buffer-separated
TEL in each direction of I-25 from the existing HOV/
Express Toll lanes at approximately 84th Avenue
north to SH 14.
Wellington to Denver
• Interchanges - 13 I-25 interchanges will be upgraded.
• Express Bus – Express bus with 13 stations along I-25,
US 34 and Harmony Road with service from Fort Col-
lins and Greeley to downtown Denver and DIA.
• Commuter Rail – Commuter rail service with nine sta-
tions connecting Fort Collins to Longmont using the
Burlington Northern Santa Fe Railroad right-of-way,
generally paralleling SH 119 then County Road 7 and
tying into FasTracks North Metro line in Thornton,
providing service to downtown Denver. Passengers
may also connect to the FasTracks Northwest line in
Longmont, which will travel to Boulder.
• Commuter Bus – Commuter bus service with eight
stations along US 85 connecting Greeley to downtown
Denver.
• Congestion Management- Improvements include
accommodations for ridesharing, carpools and van-
pools, along with additional bicycle and pedestrian
facilities. In addition, signal timing, ramp metering on
I-25 and signage will also be improved.
Frequently Asked Questions
Q. When will we have an opportunity to review the Final
EIS?
A. The North I-25 Final EIS will be available for public re-
view and comment for a 30-day period from mid-August
to mid-September. During this time, the public hearings
listed above will be held to gather feedback.
UPCOMING PUBLIC HEARINGS
The Colorado Department of Transportation will host three public hearings in September to gather feedback
on the Final Environmental Impact Statement. All meetings will take place from 4:30 p.m. to 7 p.m. with a
brief presentation at 5:30 p.m. and an opportunity to comment publicly.
September 12, 2011- Southwest Weld County Building: 4209 Weld County Road 24 1/2 (I-25 exit #240)
September 13, 2011- Longmont Public Library: 409 4th Avenue in Longmont
FACT SHEET
North I-25 Environmental Impact Statement
Wellington to Denver August 2011
Q. What does the Final EIS include?
A. The Final EIS includes a detailed evaluation of the
three build alternatives including Package A, Package
B and the Preferred Alternative. A phased approach for
implementation of the Preferred Alternative will also
be included. The Preferred Alternative and Phase 1 are
shown on the project website at
http://www.coloradodot.info/projects/north-i-25-eis
Q. What is a Record of Decision (ROD)?
A. The Record of Decision for North I-25 is a document
that will describe the transportation improvements that
have been selected by CDOT and FHWA for the first
phase of implementation.
Q. What is the North I-25 ROD expected to include?
A. A final decision on what to include in the North I-25
ROD will be made after the Final EIS public comment
period. It is currently anticipated that Phase 1, as identi-
fied in the Final EIS, will be selected for implementation
in the ROD.
Q. When will the North I-25 ROD be completed?
A. The ROD is expected to be signed by CDOT and
FHWA in Fall 2011.
Q. When will construction begin?
A. To accommodate current funding limitations, CDOT
and FHWA anticipate constructing the improvements
in phases over time. CDOT is already moving forward
with preliminary design of two northern sections of I-25
improvements. At this time, construction funding has not
been identified.
Staying Informed
For the latest information about the project, visit
http://www.coloradodot.info/projects/north-i-25-eis
September 15, 2011- The Ranch (Budweiser Events Center): 5290 Arena Circle (I-25 exit #259)
Continued on page 2
ATTACHMENT 4
floodplain requirements.
N
sentence….“Denver, Adams, Weld and
Larimer Counties, along with most cities and
towns within the project area, are
responsible for regulating development in
FEMA designated floodplains and adhere to
FEMA policy and local Floodplain
regulations”.
N
103
2) Pg 68-69, Cache La Poudre River section,
the bottom paragraphs of page 68 are N
no adverse affects on any historically designated or eligible properties arising from the
implementation of the North I-25 project.
38. No Response Needed.
A
monitoring site had the highest 8-hour ozone reading of the entire Front Range in
2007 and has recorded several 8-hour values that exceed the standard.
Greenhouse gas emissions should be discussed in the Affected Environment section,
not only briefly addressed in the Cumulative Impacts section. Within the DIES
study area, the communities of Fort Collins, Boulder and Denver has active
commitments and plan to reduce greenhouse gas emissions. The State of Colorado
35. Figure 3.5-1 has been updated with the correct ozone non-attainment boundary for the Denver Metro area. The
following text has been added to section 3.5.2: “However, particulate matter levels even below the NAAQS can impact the
health of individuals with respiratory sensitivity. Therefore, the City of Fort Collins has implemented a policy to
“continually improve air quality as the city grows.” Table 3.5-2 has been updated with the new monitoring station in Fort
Collins (3416 W LaPorte Ave) and “2005” has been removed from the table title. Text has been revised on page 3.5-6,
section 3.5.2.2, criteria pollutants and critical pollutant data trends as follows:35. (cont.) “Ozone concentrations have
shown no consistent trend. Concentrations spiked in 1998, 2003, and 2005, with 2003 and 2005 concentrations exceeding
the 8-hour standard in much of the regional study area. Concentrations at monitoring stations throughout the regional
study area returned to levels below the 8-hour standard concentrations after the 2003 peak. However, concentrations
remained above the 8-hour standard after the 2005 peak. In 2006, Fort Collins added a new monitoring station to monitor
ozone concentrations. This monitoring station had the highest concentrations of ozone from 2006 to 2008 within the North
Front Range area. Attainment designation for the ozone standard is based on a three year average. Therefore, since
monitoring stations exceeded the 8-hour ozone standard for three consecutive years (2005 to 2007), the EPA designated
the Denver metro area and the north Front Range as a non-attainment area for the 8-hour ozone (O3) in November 2007.
The 1-hour ozone standard was revoked after this designation. In March 2008, EPA strengthened the NAAQS for the 8-
hour ozone standard from 0.080 ppm to 0.075 ppm.” A discussion of GHG is in the Energy section, Section 3.21.
Please note the City’s over-arching air quality
policy has been updated to simply say
“continually improve air quality.”
C
investment in transportation infrastructure to
result in increased CO2e emissions. However,
the modeling does not presume any use of
electric vehicles, and does not assume any
increases in the price of fossil transportation
fuel. Growth in these areas is likely to result in
reduced carbon emissions for any of the
alternatives.
The FEIS states that mitigation is available for
all impacts. For increased CO2e emissions, it
suggests a focus on VMT reduction. Reduction
of carbon intensity of fuels and improvements
in vehicle fuel economy should be added as
important mitigation measures as well.
C
Ozone Non-Attainment
94
The DEIS refers to ozone designation inconsistently throughout the Air Quality
chapter. All text should reflect the November 2007 non-attainment designation area
for the 8-hour ozone standard. In addition the new, more stringent 8-hour
promulgated in March 2008 should be discussed.
33. The FEIS includes the following text on page 3.5-4: Ground-level ozone is a gas that is not emitted directly from a
source, as are other pollutants, but forms as a secondary pollutant. Its precursors are certain reactive hydrocarbons and
nitrogen oxides, which react chemically in sunlight to form ozone. The main sources for these reactive hydrocarbons are
automobile exhaust, gasoline, oil storage and transfer facilities, industrial paint and ink solvents, degreasing agents, and
cleaning fluids. Exposure to ozone has been linked to a number of health effects, including significant decreases in lung
function, inflammation of the airways, and increased respiratory symptoms, such as cough and pain when taking a deep
breath. Particle pollution (particulate matter) is a mixture of suspended microscopic solids and liquid droplets made up of
various components, including acids, organic chemicals, metals, dust particles, and pollen or mold spores. The size of a
particle is directly linked to its potential for causing health problems. Small particles, that is, those less than 10
micrometers (PM10) in diameter, pose the greatest problems because of their ability to penetrate deeply into the lungs and
bloodstream. Exposure to such particles can affect both the lungs and heart. Particles larger than 10 micrometers (PM10)
act as an irritant to the eyes and throat. Fine particulate matter with a diameter less than 2.5 micrometers is called
PM2.5. Sources of fine particles include all types of combustion, including motor vehicles, particularly diesel exhaust,
We appreciate the inclusion of updated ozone
information in the FEIS.
As with greenhouse gas emissions, it is
distressing that the 2035 No Action Alternative
shows lower total emissions in tons/day than the
2035 Preferred Alternative. Specifically, Table
3.5-5 shows that the 2035 Phase I total
emissions for Fort Collins are 2.2% higher than
the 2035 No Action Alternative. In fact, all
alternatives analyzed show slightly higher 2035
emissions than the No Action Alternative. This
does not comply with Fort Collins air quality
A
Research Program Report 568 (TRB, 2006) The design will be such that minimal disruption to the ecosystem will occur.
The design will consider costs for construction and maintenance. A bridge deck drainage system that controls seepage at
joints will be considered. I possible, bridge deck drains will be piped to a water quality feature before being discharged
into a floodplain. The designs will comply with federal and state agencies. The designs will make every consideration
towards local agency requirements and will be consistent with existing watershed and floodplain management programs.
Please note that wetland mitigation is discussed in Chapter 3.8 of the EIS.
Reiterate that wetlands disturbed within the Fort
Collins area should be mitigation within the
same region.
The mitigation for each creek, river, or other
drainage is vague, not site specific, and makes it
impossible to evaluation for direct and indirect
impacts to wetlands and floodplains. The same
four mitigation measures are identified for
separate drainages. Revised, site specific
mitigation plans for each drainage should be
conducted for the public and appropriate
stakeholders to comment on.
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3.13-9 Threatened Species – Environmental Consequences. The approach of
conducting an effects analysis on a broad scale is not adequate and the “one size fits
all approach” to mitigation is not adequate. Site by site and drainage by drainage
analyses need to be conducted to ensure impacts are avoided at best, mitigated at
worst.
28. Effects are presented by component and by species. For key species, such as Preble’s and bald eagle, effects are also
broken out by site. Aquatic species are addressed by drainage. For black-tailed prairie dogs, site by site analysis would
not be productive due to the large number of small prairie dog colonies involved, and the likelihood that most of these
colonies will have expanded, contracted, or disappeared by the time of construction. Other species are addressed at a
broad scale and impacts are estimated based on suitable habitat due to a lack of actual presence/ absence data. The FEIS
includes site-specific mitigation measures where appropriate (for example for Preble’s and bald eagle).
Full-cutoff light fixtures or similar standards
should be used in sensitive wildlife habitat areas
(including the Fossil Creek Reservoir area C
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3.13-12. Threatened Species. Additional lighting adjacent to Fossil Creek Reservoir
will further impair the quality of the bald eagle roost site at the Reservoir. This could
be mitigated by controlling light leakage or by eliminating lighting from the design of
that interchange.
29. These suggestions have been incorporated in the FEIS for all alternatives. A
Part II: Air Quality
General comments on air quality section:
Induced land use
91
Air quality in the Fort Collins community is dominated by vehicle emissions. A key
issue for local air quality improvement is to reduce the growth of vehicle miles
traveled, which depends, in turn, upon land use changes that support use of transit,
cycling, and walking. For that reason, we believe that land use densification and
transit-oriented development should be a key criteria in deciding among the
30. The purpose and need for the project and stakeholder input provided the criteria framework for alternatives
development. The purpose of the project is to meet long-term travel needs between the Denver Metro area and the rapidly
growing population centers along the I-25 corridor north to the Fort Collins-Wellington area. For this reason, both
highway and transit options were considered for the project. While the transportation system can influence land use
patterns, development is regulated at the level of local government.
Regarding our original comment that land use
densification and transit-oriented development
should be key criterion for deciding among
alternatives, we are glad to see the Preferred
Alternative provides commuter rail and transit
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comment is correct that traffic noise levels in the east of Arapaho Bend do exceed the CDOT Category B NAC for some of
the open space. Noise mitigation for Arapaho Bend was evaluated and found not to be feasible and reasonable under
CDOT’s 2002 noise guidelines because there are no developed sites or recreational facilities with frequent human use
present along I-25 that would benefit from a barrier and a barrier did not meet the necessary Cost Benefit Index.
Therefore, noise mitigation is not recommended for Arapaho Bend. The list of traffic-noise-impacted sites in the Final EIS
documents was updated to include Arapaho Bend and a mitigation analysis summary was included in the Final EIS.21.
(cont.) FHWA and CDOT have recently adopted new noise regulations, taking effect in July 2011. Regarding the 2011
regulations, the result is expected to be the same. The site would be Category C rather than B, but would still be
represented by a single receiver based on the new guidance: "For activity areas that are spread across a property or for
properties that lack defined facilities or formalized activity areas, a single generalized receptor should be placed within
the property that best represents the worst expected traffic noise condition, based on professional judgment of the noise
specialist." A large barrier would be needed to abate noise for a single receiver, which would be too expensive relative to
the benefit; therefore, the reasonableness criteria
Every effort to implement non-barrier methods
of noise mitigation along I-25 (where it passes
Arapaho Bend Natural Area) should be
implemented. To be clear, we would not
support construction of a barrier to mitigate
noise in this area.
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3.6.4.1. Noise. Any efforts to mitigate road noise (barriers) should consider wildlife
movement (deer, antelope) and create wildlife crossings across I25 especially north of
Fort Collins and including the Wellington area. Any barriers within the more
“metro” area should provide occasional openings to permit the movement of wildlife
across the interstate.
22. Two barriers have been recommended for the project area north of State Highway 7: Wellington East and Mountain
Range Shadows. Both of these are in fairly developed areas and are not in obvious wildlife corridors. No final
determinations on the specifics of these barriers have been made at this stage of the project, but the final choices will be
sensitive to the larger environmental context of the areas including wildlife movement. Also, see Staff Comment Response
#11.
A
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Table 3.7-5. Water Quality. It is troubling that both action alternatives (Package A
and B) will increase stormwater contaminant loading by 50% (for all modeled
23. It is important to note that there are anticipated pollutant loadings associated with existing and No Action
Alternatives. These alternatives do not have BMPs associated with them. The BMPs for the action alternatives are
A
15. Impacts to riparian habitat will be mitigated by implementing CDOT’s best management practices as described in
Section 3.10.3, including avoiding existing trees, shrubs, and vegetation to the maximum extent possible, especially
wetlands and riparian plant communities. The project team will coordinate with the CDOT landscape architect before
construction to determine the types of vegetation that will be protected during construction. A revegetation plan will be
developed with the CDOT landscape architect and with county personnel in Adams, Boulder, Broomfield, Denver,
Larimer, and Weld counties. CDOT will also have to go through the process of working with the CDOW when submitting
documentation to satisfy Senate Bill 40 for wildlife certification.
Re-vegetation plans for disturbed areas should
include species that are appropriate to the
community disturbed including woody species.
The FEIS does not address the removal of large
cottonwood trees at the Cache La Poudre as it
will seriously impair the quality and
functionality of the riparian habitat. How can a
generic 150 yr old 36” diameter tree be
mitigated?
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Table 3.12.2: Wildlife. Audubon Society has designated Fossil Creek Reservoir as
an “Important Bird Area” and the high value for migratory waterfowl and other
waterbirds is well-documented. This should be represented in the EIS.
16. A reference to the high value of Fossil Creek Reservoir for migratory waterfowl and other waterbirds has been added
to the table.
A
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Wildlife: Commuter rail appears to be aligned on the McKee Farm which is Larimer
County Open Lands property with conservation easements underlying the property
that would prohibit new construction. Additional train traffic through the area would
be a significant impact to recreation users (noise) and displace wildlife use within a
3,000-acre matrix of protected Fort Collins natural areas.
17. The commuter rail alignment will be located within existing rail right-of-way. Construction of commuter rail would
result in some impacts to wildlife including habitat fragmentation, disruption of movement corridors, and displacement as
described in Section 3.12.3.2. Noise impacts to parks and open spaces have been considered in the FEIS, using
appropriate guidelines. McKee Farm near the rail corridor is being actively farmed and has no visible public access or
visitor facilities.
The preferred alternative fails to recognize the
significant impacts to wildlife movement along
the proposed commuter rail line between Fort
Collins and Loveland. The addition of a
maintenance road, concrete barriers with
additional chain link fence will significantly
impact wildlife movement within and across
this 3,000 acre prairie habitat. Affected areas
include Hazaleus Natural Area, Colina
Mariposa Natural Area, Redtail Grove Natural
Area, and Longview Open Space. The addition
of commuter rail service to current and future
freight train travel will worsen wildlife
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N
70
Once the FEIS is completed and the ROD
approved, will the North Front Range MPO
model network be revised to include the highway
and transit improvements show in the Preferred
Alternative (Phase I)? This information will also
help better define the potential benefits/impacts
N
63
Page 2-20, the description of the Package A
Commuter Rail service seems to be inaccurate in
terms of where the northern end of service would
begin. It should read: “Downtown Fort Collins
at Mason and Maple streets” (not at University
N
phasing plan shown for the future commuter rail
service extending from Loveland to Fort Collins
is not shown until Phase 3 (CDOT expected
timeframe of 2075+). Staff recommends that
CDOT revise the FEIS to only show two phases
– Phase 1 as shown now, as the “fiscally
constrained plan” based on anticipated funding
levels through 2035. Then, the new “Phase 2”
would include all of the remaining elements of
the Preferred Alternative and be considered the
“unfunded” items and not be tied to an artificial,
50-60+ year time horizon. These transportation
improvements – highway and transit – shown in
Phase 2 and 3 need to be implemented sooner
rather than later to serve the regional travel
demand forecast for 2035. Dividing them into
two artificial phases does not solve the issue that
the future regional transportation needs
significantly outpace our current funding
sources. The EIS Preferred Alternative should be
a catalyst for convening regional discussions and
partnerships to work together toward
accomplishing these needs within the 2035
timeframe.
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Additional/New comments, questions, and
suggestions on the FEIS for the
Transportation Planning section:
1. Largest overall concern with FEIS is the
proposed phasing plan. This is new information
developed by CDOT and other agencies since the
DEIS was presented for public comment in 2008.
Staff TAC and RCC representatives have voiced
our concerns about this phasing plan during the
N
such as Downtown, CSU, the central business, employment, and residential areas
along US287/College Avenue. The regional BRT service along Harmony Road to I-
25 will require people to drive to park & rides on the south end of the City or take
local transit routes to transfer to the regional BRT service.
The proposed I-25 Tolled Express Lanes would help give advantage to travelers in
high-occupancy vehicles such as the regional BRT or carpoolers/vanpoolers as well
as support congestion pricing strategies to allow travelers who can afford to pay the
9. That is correct, access to the regional BRT service would be by either walking, driving, or taking a local bus to a
station or stop on the Harmony Road corridor. Note that the access to commuter rail in Package A or the Preferred
Alternative is via the same choice of access modes but to the US-287 corridor through the core population area of Fort
Collins. With the inclusion of express bus, the Preferred Alternative provides regional transit service on both the US 287
and Harmony corridors. The evaluation indeed identified that freight traffic would not be directly served by the addition
of TEL in Package B. However, note that mobility in the adjacent general purpose lanes is improved for freight and non-
toll paying vehicles, but not as much as Package A. The Preferred Alternative includes additional general purpose lanes
as well as TEL north of SH 66. This cross section would improve mobility for freight traffic as well as non-toll paying
vehicle
The Preferred Alternative provides general
purpose lanes as well as toll lanes to serve
highway travel needs and includes the regional
express bus service along Harmony Road from
the City's new south transit center to I-25
connecting to Denver.
A
50
In addition, locating this major regional commuter rail line in the heart of the Fort
Collins community will lessen the likelihood of future land development shifts
occurring away from the existing central population & activity centers within our
community. Fort Collins’ adopted Transportation Master Plan and City Plan are
based on compact urban development occurring within the core areas of our
community. The proposed regional commuter rail alignment along the BNSF
corridor supports these transportation and land use master plans.
7. Comment noted. Your observations of commuter rail’s influence on land development patterns are generally consistent
with the findings of an expert panel convened to evaluate the alternatives regarding induced growth. The effect of
Package A, Package B, and the Preferred Alternative on growth patterns is described in Section 4.2.7: Since the highway
improvements are generally similar between the packages, a similar amount of growth near I-25 is anticipated for any of
the packages. However the commuter rail in Package A and the Preferred Alternative would intensify the density of
developments near stations in the city centers.
The Preferred Alternative with regional
commuter rail alignment along the BNSF
corridor supports the City of Fort Collins
Transportation Master Plan and City Plan. A
concerns. C
46
Also, the current results of the travel model show that many trips are moving within
the North Front Range and to/from the Fort Collins and Longmont, Boulder areas
along the US287 corridor. These inter- and intra-regional travel patterns, in addition
to the Fort Collins to downtown Denver trips, need to be analyzed in more detail for
each package of alternatives and as part of the process to determine the preferred
alternative. The preferred alternative should address all of these trip purposes, not
just the Fort Collins to downtown Denver trips along I-25.
3. The DEIS technical analysis accounts for all trip purposes and trip origins and destinations within the northern and
Denver front range area. For purposes of presentation, some illustrations highlight travel along I-25.
The inter- and intra-regional travel patterns
appear to have been included in the analysis.
However it would have been useful for those
patterns to be better illustrated. C
Interchanges
47
Staff supports the analysis completed during the early stages of the North I-25 EIS
process for each of the interchange areas (existing & potential) serving the Fort
Collins area: Carpenter Road/SH392, Harmony Road, Prospect Road, Mulberry
Street/SH14, and Mountain Vista Drive. Staff concurs with the conclusions and
recommended conceptual designs developed by CDOT and their consultant team.
Staff appreciates CDOT’s efforts to include the City of Fort Collins staff and local
property/business owners throughout the interchange analysis process and the design
modifications that CDOT was willing to make to address our local concerns for
adjacent land impacts.
4. FHWA and CDOT would like to thank you for your participation and look forward to your continued involvement. Comments addressed
A
Detailed analyses based on data have been conducted and documented in the DEIS; the same will be true for the
Preferred Alternative in the FEIS
See comments on modeling C
40
Cost estimates must be realistic and include costs for construction as well as on-going
operations & maintenance;
Detailed cost estimates are being updated for the Preferred Alternative and will be documented in the FEIS; including
capital construction costs and on-going operations and maintenance costs.
Comment addressed A
41
Need to consider more environmental factors such as air quality, land impacts, etc. in
the detailed analysis of the proposed improvements.
These factors are all discussed in the document
See comments in each topic section C
42
Need to consider the costs vs. benefits for expenditure of public resources to support
core transportation services and which provide the greatest degree of return on
investment.
Costs are considered throughout the project development process, among other factors. Benefits are difficult to calculate
in terms of dollars, because monetary relationships are less definitive. For example, travel time savings would need to be
converted to dollars, and assumptions for value-of-time necessarily introduce subjectivity. For this reason, benefit-cost
ratios are not typically calculated.
Continue to be concerned regarding the issue
for more systematic triple bottom line
analysis C
43
Consider the costs associated with deferring the improvements beyond 20 year horizon
shown in the phasing plans. The phasing plan 65 year timeframe is unrealistic and
doesn’t make sense, need to find more ways to fund necessary improvements in the
nearer term.
As you know, funding sources are extremely limited. Unfortunately, the 65 year timeframe is the construction schedule
given current projections of revenue. It is possible the schedule for implementation of this project, and similar schedules
for other proposed projects, will be a call to action for stakeholders to initiate new revenue possibilities so that the
phasing plan can be accelerated
See phasing comments
C
Coordination with other rail studies has included FasTracks Northwest Rail, FasTracks North Metro, RMRA High speed
rail, etc.
Comment addressed - more work needs to
continue such as coordination with high speed
rail studies C
27
Why does the North I-25 not show Commuter Rail service between Greeley and
Denver?
Frequency of freight train traffic is very high; potential ridership projections didn’t warrant rail service and the proposed
Express and Commuter Bus services are able to handle future ridership projections for less cost.
Comment addressed A
28
Core to Core connection is very important to serve population centers.
The FEIS Preferred Alternative reflects the community to community connection with Commuter Rail connecting the
downtown cores of communities including Fort Collins, Loveland, Berthoud, and Longmont
Comment addressed A
29
Move away from status quo highway planning. We need to plan for sustainable,
long-term solutions to connect our communities in the future. Not like the T-Rex
example that only provided 46 seconds of travel time savings after millions of dollars
in investment.
The FEIS Preferred Alternative includes Commuter Rail, a sustainable transportation connection between the core of
communities. The I-25 highway facility needs rebuilding to address aging infrastructure needs. The FEIS Preferred
Alternative also includes a Tolled Express Lane (TEL) on I-25, allowing HOV vehicles free travel in a restricted lane hence
supporting the alternative modes of carpooling and vanpooling. Express Bus service, with connecting bus service to the
communities, also will serve the I-25 corridor in the TEL lanes.
Comment addressed
A
30
Consider environmental impacts, social mobility for all people, and growth impacts.
These impacts are all discussed in the document
Comment addressed A
31
How does Commuter Rail alternative handle the existing freight rail traffic?
The rail corridor will serve both freight rail and the passenger rail service. This will be possible due to coordination of
operating schedules, and use of sidings. Some initial coordination with the BNSF has occurred; a collaborative effort with
the BNSF will establish a joint use agreement regarding infrastructure and operating plan requirements.
Comment addressed A
Comment addressed A
15
Need to consider how the findings in the North I-25 EIS tie to the High Speed Rail
Study
This is one of the studies we coordinated with during the DEIS development. The Rocky Mountain Rail Authority Study was
ongoing at the time of DEIS publication; coordination efforts show that the EIS’s Commuter Rail serves a travel market of
community to community travel needs, which is different than the intra-state and possibly inter-state travel market that
would use high speed rail.
See comment on future interchange design
and clear space C
16
Natural Resources staff comments are very important and need to be addressed in
Final EIS document, in particular:
Commuter Rail fence disruptive to wildlife movement.
Fencing is to limit access and improve safety. We are following the RTD guidelines. The type of fencing may vary
depending on adjacent land uses and wildlife use. The FEIS will list a range of fencing options to be considered during the
design process, including wildlife friendly fences, and could potentially include wildlife underpasses.
See comment on barriers C
17
Mapping needs to be improved to be more accurate for locations of natural areas,
water features, drainage ways, and floodplain areas.
All maps have been updated with new info collected from the municipalities. The City of Ft Collins has been directly
contacted and staff has provided us updated GIS files.
See comment in Natural Resources section C
18
Concern regarding impacts to wildlife habitat areas, large cottonwood trees, and
Threatened & Endangered species.
Impacts to riparian habitat will be mitigated by CDOT's revegetation Best Management Practices, including avoiding
existing trees to the maximum extent possible. The high value of Fossil Creek Reservoir for migratory waterfowl will be
documented in the FEIS. The FEIS will include site-specific mitigation measures for Threatened and Endangered species
where appropriate (for example for Preble’s and bald eagle). City of Fort Collins staff suggestions for controlling lighting
near Fossil Creek Reservoir to reduce the effect on bald eagle roost sites will be incorporated in the FEIS
See comment in Natural Resources section
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traffic impacts the capacity and operation of I-25 and I-25 interchanges. Because of this, freight truck traffic and
anticipated growth in truck traffic along I-25 is accounted for in all the traffic analyses conducted in the DEIS and FEIS.
Freight traffic on I-25 is estimated to grow 2% annual on the south end and slightly more than 3% on the north end of the
corridor and constitutes 8 to 14% of the total traffic. It is estimated that under the No Action alternative delay to truck
traffic would be 67 minutes between SH 1 and 20th Street for a total travel time of 133 minutes. Three cross sections
were evaluated for inclusion in the Preferred Alternative. The preferred cross section identified added both a general
purpose lane and a tolled express lane north of SH 66. This was, in part, to better accommodate anticipated growth in
freight traffic along I-25. 8The Preferred Alternative is expected to provide the most travel time improvement for freight
traffic with a total travel time of 107 minutes between SH 1 and 20th Street.
Comment addressed. A
8
Is there an overall picture of environmental damage, including impacts of
transportation, infrastructure, dislocations, and induced development? I don't think so.
8. The DEIS addresses the environmental impacts within each respective resource section. Transportation impacts are
addressed in Chapter 4, dislocations are addressed in Chapters 3.2 and 3.4, and induced development is addressed in
Chapter 3.1 and Appendix C—Land Use. Chapter 7 of the DEIS contains the overall “picture” of the trade-offs among
See staff comments under each topic area for
details.
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DRCOG’s modeling and Denver’s experience
with rail transit. Also, the FEIS states that for
communities such as Fort Collins that have
“Transit Oriented Development” land-use
policies, there could be up to 35% increase in
ridership projections. These potential differences
in transit ridership projections are substantial.
What would the impact be if these higher
ridership projections are more realistic? Both
from a transit system capacity standpoint as well
as from a highway planning perspective? To
help address these concerns, staff suggests that
travel demand forecasts for automobile trips as
well as transit trips be updated in the future to
reflect new trends and methodologies prior to the
implementation of any of the highway and/or
transit improvements included in the Preferred
Alternative.
C
4
Do the transportation models incorporate the impacts of transportation alternatives on
growth patterns and transportation oriented development? If growth shifts toward I25,
away from city centers, what will happen with VMT?
4. The forecasts use the adopted socioeconomic datasets of the NFRMPO and DRCOG. The effect of Package A, Package
B, and the Preferred Alternative on growth patterns is described in Section 4.2.7: Since the highway improvements are
generally similar between the packages, a similar amount of growth near I-25 is anticipated for any of the packages.
However the commuter rail in Package A and the Preferred Alternative would intensify the density of developments near
stations in the city centers. If growth shifts towards I-25, the amount of VMT would increase by a small amount.
Staff continues to be concerned regarding this
issue and recommends that future travel demand
forecasts be updated to reflect more recent local
land use and transportation plans to assess the
potential impacts of changing growth patterns.
For example, Fort Collins’ recently updated our
comprehensive plan “City Plan” and our
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