HomeMy WebLinkAbout2008-132-12/16/2008-DOCUMENTING THE CITY COUNCILS COMMENTS ON THE NORTH 1-25 DRAFT ENVIRONMENTAL IMPACT STATEMENT RESOLUTION 2008-132
OF THE COUNCIL OF THE CITY OF FORT COLLINS DOCUMENTING
THE CITY COUNCIL'S COMMENTS ON THE NORTH I-25
DRAFT ENVIRONMENTAL IMPACT STATEMENT
WHEREAS,the Colorado Department of Transportation("CDOT")is conducting the North
I-25 Environmental Impact Statement for the Interstate Highway 25 corridor from Northern Colorado
to the Denver Metropolitan area; and
WHEREAS,CDOT has released the North I-25 Draft Environmental Impact Statement(the
"North I-25 DEIS")document for public comment,which comment must be submitted to CDOT by
December 30, 2008; and
WHEREAS,City staff members from various City departments have reviewed the North I-25
DEIS and have provided comments to the Council for approval and delivery to CDOT as the City's
official comments; and
WHEREAS, City staff will continue working with CDOT in 2009 to provide additional
comments as part of the final Environmental Impact Statement(the North I-25 Final EIS")process
and will also conduct outreach to City boards and commissions and other community representatives
to gather additional input and comments which,when completed and compiled, will be forwarded
to CDOT for consideration in the development of the North I-25 Final EIS; and
WHEREAS, the City Council has determined that the City Manager should add certain
additional comments to those attached to this Resolution to reflect direction and feedback from the
City Council.
NOW,THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF FORT
COLLINS that the document entitled"City of Fort Collins Comments in Response to the Draft I-25
Environmental Impact Statement"dated December 16,2008,attached hereto and incorporated herein
by this reference as Exhibit"A,"is hereby approved by the City Council as the City's comments to
the North I-25 DEIS; provided,however, that the City Manager is hereby authorized and directed
to,in consultation with Transportation staff,supplement the attached,prior to submission deadline,
with such additional comments, if any, as may be needed to reflect Council direction and
Councilmember feedback and deliver the same to the Colorado Department of Transportation.
Passed and adopted at a regular meeting of4Coilhe City of Fort Collithis 16th
day of December A.D. 2008.
ATTEST:
kl)� ,
City Clerk
EXHIBIT A
City of Fort Collins Comments
in Response to the North I-25 Draft Environmental Impact Statement
December 16, 2008
Please note that these are high level, summary comments and not intended to serve as a detailed
overview of the I-25 EIS.
Transportation Planning:
General comment: Transportation Planning staff agrees with the purpose and need of the North
I-25 DIES. 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.
Staff recommends that future travel demand forecast modeling be updated by CDOT and their
consulting team as part of the 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.
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.
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 and safety improvements to serve the
Fort Collins community.
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.
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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.
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.
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 1-25 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 1-25,these additional travel lanes
will address safety concerns along 1-25 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.
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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 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 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.
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.
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.
Natural Resources:
Natural Resources supports efforts to enhance multi-modal travel systems and supports the
Transportation Planning staff's I-25 recommendations.
Please note that the following comments are high level and not intended to serve as a detailed
overview of the I-25 EIS:
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Part I: Natural Areas
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.
General comment: Maps for the EIS are not current and many City of Fort Collins' Natural
Areas and Parks are not shown.
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.
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.
3.10-5. Ve etg ation. 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.
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.
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.
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.
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.).
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.
3.06. 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
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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.
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.
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 contaminants)within the
Cache La Poudre watershed above the current situation or under the no-action alternative.
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.
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.
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.
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 Foodplains. 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.
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.
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.
Part II: Air Quality
General comments on air quality section:
Induced land use
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,
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we believe that land use densification and transit-oriented development should be a key criteria
in deciding among the alternatives.
Changed conditions
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.
Greenhouse eases
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.
Ozone Non-Attainment
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.
PM2.5
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.
More Specific Comments:
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.
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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 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 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
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.
Parks & Recreation:
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.
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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.
Advance Planning—Historic Preservation Office:
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 no adverse affects on any
historically designated or eligible properties arising from the implementation of the North 1-25
project.
Regulatory and Government Affairs Division:
Please note that these are high level comments and not intended to serve as a detailed overview
of the 1-25 DEIS.
Section 3.7 Water Resources
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.
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.
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City of Fort Collins Water& Wastewater Utilities Department
No comments
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