HomeMy WebLinkAbout2011-090-09/20/2011-DOCUMENTING AND PRESENTING THE CITY COUNCIL'S COMMENTS ON THE NORTH 1-25 FINAL ENVIRONMENTAL IMPACT RESOLUTION 2011-090
OF THE COUNCIL OF THE CITY OF FORT COLLINS
DOCUMENTING AND PRESENTING THE CITY COUNCIL'S
COMMENTS ON THE NORTH I-25 FINAL ENVIRONMENTAL
IMPACTSTATEMENT
WHEREAS,the Colorado Department of Transportation("CDOT")has,for the past decade,
been developing the North I-25 Environmental Impact Statement ("EIS"), the purpose of which is
to plan for long-range transportation needs to connect northern Colorado with the Denver
metropolitan area; and
WHEREAS, the study area for the EIS focuses on highway and transit plans for the I-25
corridor, the U.S. 287 corridor and the U.S. 85 corridor; and
WHEREAS, on August 19, 2011, CDOT published the final EIS ("FEIS") for the study
corridor and has been seeking agency and public comments for the period ending October 3, 2011;
and
WHEREAS, following extensive public outreach and upon the favorable recommendation
of the Transportation Board,City staff has prepared and presented to the City Council a draft of the
proposed City comments on the EIS; and
WHEREAS, the City Council has determined that the proposed comments accurately
represent the City's staff, Council and other potential community concerns; and
WHEREAS, the City Council hereby desires to document and present these comments to
CDOT as the City's official comments.
NOW,THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF FORT
COLLINS as follows:
Section 1. That the comments contained in Exhibit"A"attached hereto and incorporated
herein by this reference, should be presented to (DOT as the City's documented comments on the
North I-25 final EIS.
Section 2. That,in particular,the City Council strongly encourages CDOT to address the
following concerns of the City in finalizing the EIS and in constructing the improvements that are
the subject of the EIS:
• The phasing plan for the various transportation improvements to'be constructed by
CDOT currently includes three phases of improvements to be constructed over a 50
to 60 year timeframe. The City Council recommends that the plan be revised so
show only two phases: a"fiscally constrained phase" based on anticipated funding
levels through 2035, and a second phase for completing all remaining unfunded
elements of the preferred alternative as expeditiously as possible.
• The transportation and air quality analysis in the FEIS results in travel demand
projections that do not reflect changing fuel costs, use of alternative fuel vehicles,
changing lifestyle choices, long-term sustainability values or other potentially
significant factors that could influence the demand for interstate and transit travel in
the future. The City Council recommends that CDOT use a "triple bottom line"
method of analysis that'includes traditional transportation analysis methods along
with consideration of environmental, economic, and human factors.
• Every effort should be made by CDOT to implement non-barrier methods of noise
mitigation along I-25. The City Council does not support construction of a noise
barrier in this area,nor does it support potential fencing/barriers/sound walls within
other areas of Fort Collins, either along the highway and/or commuter rail corridor.
The City Council requests that CDOT delete these elements and/or include other
options to maintain viewsheds and wildlife movement corridors.
• Wetlands that are impacted by CDOT improvements in the Fort Collins regional area
should be mitigated within that same area. Local mitigation requirements per City of
Fort Collins Land Use Code should be considered for locally impacted wetlands.The
City Council 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 difficult to evaluate for direct and
indirect impacts to wetlands and floodplains. The City Council requests that revised,
site specific mitigation plans for each drainage be developed for public comment,
either as part of the EIS process or as part of the design process during
implementation. In addition, the City Council requests that CDOT follow all
applicable floodplain regulations,including federal,state,and local requirements,and
not just FEMA regulations as indicated in the FEIS.
• The Floodplain Report,Cache La Poudre River section,should be corrected to reflect
that the City of Fort Collins strongly 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.
Passed and adopted at a regular meeting of the Council of the City of Fort Collins this 20th
day of September A.D. 2011.
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EXHIBIT A
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
City Council Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Travel to Denver is emphasized to the exclusion of travel to Longmont and Boulder, 1. All trip types are covered by the analysis. Trips to Boulder and Longmont are also included in the analysis; however
which are apparently at least as important destinations from Northern Colorado. The Figure 4-6 only depicts riders on the specific transit system improvements proposed by this project. Riders transferring Comment addressed - Commuter Rail and
analysis should address a broader spectrum of trips. For example the graphics of to/fom the RID FasTracks and bus system are not directly illustrated, but their activity is discerned through the rail Express Bus routes in the FEIS Preferred
1 travel patterns in Figure 4-6 indicate no riders going to or from Longmont, assuming access/egress in the pie chart. For example, at the Sugar Mill station in Longmont, it can be seen that about three- eights Alternative will provide service to both
all passengers are going to Denver. Really? of the riders getting on or getting off the commuter rail transfer to/from the FasTracks Northwest Rail line. Downtown Denver and Boulder to serve the
different destinations for Fort Collins travelers.
Connections to other transit options, in particular the North and Northwest routes 2. All of the alternatives are connected to the future FasTracks system. Package A extends the end of the FasTracks North
proposed for FasTracks, are vital. How does each alternative interact with them? Metro rail line to terminate at the Downtown Transit Center in Fort Collins. Package A also extends the end ofthe
FasTracks Northwest rail line to a new station in southern Longmont, labeled the Sugar Mill station. This would be a Comment addressed - The Preferred Alternative,
shared station with the North Metro line to Fort Collins, thus allowing rail-to-rail transfers. Package B interacts with the including the Commuter Rail and Express Bus /�
2 FasTracks system in downtown Denver, allowing BRT passengers to access all the FasTracks rail lines as well as the routes, are now integrated with the future /y
RID bus routes serving downtown Denver. In addition, the BRT routes in Package B stop at Wagon Road, a major park- FasTracks sites, re system routes.
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 connectivitypoints as described for Package A, and it includes express
bus to downtown Denver, allowing connectivity to all the FasTracks corridors.
Does the analysis look to the future, anticipating high fuel prices, demand pricing of 3. The ElSforecasts are conservative as no change in the relative cost ofgasoline is assumed, because predicting the Staff continues to be concerned regarding the
car travel, and possible alternatives to commuting? price of fuel would be impracticable. Similarly, the forecasts assume the portion of work-at-home and other alternative travel demand forecast methodology used in the
commute activities remain at similar percentages to that experienced today. If the price ofgas or commute characteristics FEIS, particularly that it is substantially
dramatically change, these could indeed infuence travel behaviorpatterns. (Information about this is in the FEIS in underestimating future transit ridership
Section 4.2.9). The EIS has openly acknowledged that the f ture price ofgas is an unknown and therefore introduces an projections. We appreciate that CDOT openly
uncertainty into the forecasts, as described in section 4.2.6.6. 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
DRCOG's modeling and Denver's experience
with rail transit. Also, the FEIS states that for
communities such as Fort Collins that have
3 "Transit Oriented Development" land-use �'1
policies, there could be up to 35% increase in v
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.
Do the transportation models incorporate the impacts of transportation alternatives on 4. The forecasts use the adopted socioeconomic datasets of the NFRMPO and DR COG. The effect of Package A, Package Staff continues to be concerned regarding this
growth patterns and transportation oriented development? If growth shifts toward I25, B, and the Preferred Alternative on growth patterns is described in Section 4.2. 7: Since the highway improvements are issue and recommends that future travel demand
away from city centers, what will happen with VMT? generally similar between the packages, a similar amount of growth near I-25 is anticipated for any of the packages. forecasts be updated to reflect more recent local
4 However the commuter rail in Package A and the Preferred Alternative would intensify the density of developments near land use and transportation plans to assess the
stations in the city centers. Ifgrowth shifts towards I-25, the amount of VMT would increase by a small amount. potential impacts of changing growth patterns.
For example, Fort Collins' recently updated our
comprehensive plan "City Plan" and our
Page 1 of 22
EXHIBIT A
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
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.
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,
5 as the bus feeder services to commuter rail also serve local inter-community trips. In Package B, feeder bus riders to Comment addressed
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.
The financial analysis in Chapter 6 is very skimpy. Is such a superficial analysis all 6. Cost and financial information is provided in Chapters 2 and 6 of the Final EIS The Cost Estimate Review report, Comment addressed, EIS financial analysis
that is possible? which provides detailed information on the Preferred Alternative and Phase 1 cost estimates, is included in Cost Estimate seems to be more thorough than in DEIS. Larger
Review Final Report, July 2010, FHWA. For more information see the Cost Estimate Review Report, which is a policy concern continues regarding the future of
supporting technical report to this Final EIS and is available for review at CDOT Region 4. 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
6 Alternative shown in the FEIS as well as other �1
local and regional transportation needs. There v
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 otherjoint
projects. We look forward to continuing to work
with CDOT and other regional partners to further
completion of these important regional
connections.
Is sufficient attention paid to freight transportation? The focus seems to be totally on 7. Freight rail service will continue to be maintained in the corridor. The agreement with BNSF will specify the
moving people. infrastructure and operating plan requirements to allow both passenger service and freight service. The volume of truck
traffic impacts the capacity and operation ofI-25 and I-25 interchanges. Because of this, freight truck traffic and
anticipated growth in truck traffe along1-25 is accountedfor 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
7 corridor and constitutes 8 to 14% of the total traffic. It is estimated that under the No Action alternative delay to truck Comment addressed.
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 PreferredAlternative. The preferred cross section identified added both a general
purpose lane and a tolled express lane north ofSH 66. This was, in part, to better accommodate anticipated growth in
freight traffic along I-25. 87 he 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.
Is there an overall picture of environmental damage, including impacts of 8. The DEIS addresses the environmental impacts within each respective resource section. Transportation impacts are See staff comments under each topic area for
8 transportation, infrastructure, dislocations, and induced development? I don't think so. addressed in Chapter 4, dislocations are addressed in Chapters 3.2 and 3.4, and induced development is addressed in details.
Chapter 3.1 and Appendix C—Land Use. Chapter 7 of the DEIS contains the overall `picture " of the trade-offs among
Page 2 of 22
EXHIBIT A
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
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.
Given the enthusiasm which citizens are showing for rail, is the estimate of transit 9. The transit ridership model was calibrated and validated to observed travel patterns in the Denver area. Projections
ridership of the two alternatives accurate? are based on empirical behavior of travelers, as well as future geographical projections ofpopulation and employment
9 and estimated trip origins and destinations. Recent travel survey data collected by RID and DRCOG indicates that, as See comment to #3 above. C
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.
It is important for the North I-25 EIS and recommended improvements to address the 10. The North I-25 EIS provides information to decision-makers about alternatives for transportation improvements and See staff comments in both the transportation
10 link between transportation and environmental sustainability as well as to reflect the their adverse impacts and benefits. Information is included in the Draft and the Final EIS about transportation impacts and environmental topic areas.
visions and values of the communities. and benefits as well as those related to sustamabili (land use, compatibility with community visions, air
It is important for transportation improvements to provide linkages between the core 11. Comment noted. Staff continues to support this position and this is
areas of our communities. This "core to core" link is a very important part of Fort reflected in the City's adopted Transportation
11 Collins' community values. Master Plan and City Plan. This comment is also
linked to the staff comments regarding phasing v
of the Preferred Alternative Commuter Rail
service.
It seems that Package A addresses those core community values. This is not a 12. No Response Needed The Preferred Alternative, including the
statement of a preferred package, but more general thoughts and feelings for this proposed highway, interchange, and transit
12 alternative. system improvements, is consistent with City /�
Plan and the Transportation Master Plan A
(updated in 2010-11).
City Council Comments (February 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
Good information to discuss and North I-25 EIS process should address social, These needs are all discussed in the document Comment addressed
13 environmental, economic needs in addition to transportation needs.
Transportation needs to include moving people and commerce — goods & services. These needs are both discussed in the document Comment addressed
14
Need to consider how the findings in the North I-25 EIS tie to the High Speed Rail This is one of the studies we coordinated with during the DEIS development. The Rocky Mountain Rail Authority Study was See comment on future interchange design
15 Study ongoing at the time ofDEIS publication; coordination efforts show that the EIS's Commuter Rail serves a travel market of and clear space /'�
community to community travel needs, which is different than the intra-state andpossibly inter-state travel market that v
would use high speed rail.
Natural Resources staff comments are very important and need to be addressed in Fencing is to limit access and improve safety. We are following the RTD guidelines. The type offencing may vary See comment on barriers
16 Final EIS document, in particular: depending on adjacent land uses and wildlife use. The FEIS will list a range offencing options to be considered during the /'�
Commuter Rail fence disruptive to wildlife movement. design process, including wildlife friendly fences, and could potentially include wildlife underpasses. v
Mapping needs to be improved to be more accurate for locations of natural areas, All maps have been updated with new info collected from the municipalities. The City of Ft Collins has been directly See comment in Natural Resources section
17 water features, drainage ways, and floodplain areas. contacted and staff has provided us updated GIS f les.
Concern regarding impacts to wildlife habitat areas, large cottonwood trees, and Impacts to riparian habitat will be mitigated by CDOT's revegetation Best Management Practices, including avoiding See comment in Natural Resources section
Threatened & Endangered species. existing trees to the maximum extent possible. The high value of Fossil Creek Reservoir for migratory waterfowl will be
18 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 v
near Fossil Creek Reservoir to reduce the effect on bald eagle roost sites will be incorporated in the FEIS
Page 3 of 22
EXHIBIT A
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
Ci Council Comments (February 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
McKee Farm land may be restricted from Impacts due to GoCo agreement and/or The Commuter Rail alignment is located within existing rail right-of-way. Comment addressed
19 other agreements with funding partners.
Concerns regarding water quality and storm water contaminants Stormwater Best Management Practices have been incorporated which will reduce the predicted increases in stormwater See comment in Storm Water section
20 constituent loading
Concerns regarding CDOT's willingness to address City comments. Tom Anzia, All comments made on the DEIS will be addressed in the FEIS Many comments addressed in FEIS; several
representing Felsburg Holt & Ullevig and serving as the consultant project manager still remaining as noted in these comments
21 for CDOT's North I-25 EIS project team, stated that they are responding to all /'1t
comments received on the draft document and take these comments very seriously. v
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.
Interest in recent CDOT workshops. Input from Council members is important to We have been doing this CDOT to provide summaries from FEIS
22 share with CDOT and representatives from other communities. public meetings to local agencies.
CDOT is hearing a lot of enthusiasm for Package A Commuter Rail service from The FEIS Preferred Alternative rejlects this community interest; it includes Commuter Rail from Package A, as well as Comment addressed
23 many communities because it serves the existing, largest population centers and highway elements from Package B /�
people like the idea of using rail service. A
Starting to hear conflicts arise between communities east of I-25 due to concerns Observation noted, the FEIS compares and contrasts the potential land use effects of Package A, B, and the Preferred Comment addressed
24 about current land use patterns and population centers compared with future growth Alternative /�
areas. A
The average trip length on I-25 is less than three miles, so the highway is being used Hopefully communities will begin to address these local improvements Impact benefit of I-25 improvements will
25 for local trips, rather than the regional and inter-regional trips that it is intended for. need to be analyzed in the future when the
Cities need to address future improvements to other local north/south arterials to NFRMPO model is updated v
service the shorter distance trips to provide alternative routes to I-25.
More insight on rail alternatives needs to be examined and EIS needs to coordinate Extensive analysis of rail alternatives was conducted during the development of the DEIS and the PreferredAlternative. Comment addressed - more work needs to
26 with other rail studies. Coordination with other rail studies has included FasTracks Northwest Rail, FasTracks North Metro, RMRA High speed continue such as coordination with high speed /'�
rail, etc. rail studies v
Why does the North I-25 not show Commuter Rail service between Greeley and Frequency offreight train traffic is very high; potential ridership projections didn 't warrant rail service and the proposed Comment addressed
27 Denver? Express and Commuter Bus services are able to handle future ridership projections for less cost.
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 Comment addressed
28 downtown cores ofcommunities including Fort Collins, Loveland, Berthoud, and Longmont
Move away from status quo highway planning. We need to plan for sustainable, The FEIS Preferred Alternative includes Commuter Rail, a sustainable transportation connection between the core of Comment addressed
long-term solutions to connect our communities in the future. Not like the T-Rex communities. The 1-25 highway facility needs rebuilding to address aging infrastructure needs. The FEIS Preferred
29 example that only provided 46 seconds of travel time savings after millions of dollars Alternative also includes a Tolled Express Lane (TEL) on I-25, allowing HOV vehicles free travel in a restricted lane hence /�
in investment. supporting the alternative modes of carpooling and vanpooling. Express Bus service, with connecting bus service to the A
communities, also will serve the I-25 corridor in the TEL lanes.
Consider environmental impacts, social mobility for all people, and growth impacts. These impacts are all discussed in the document Comment addressed
30
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 Comment addressed
31 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 lan requirements.
Page 4 of 22
EXHIBIT A
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
Ci Council Comments (February 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
Concern was expressed by Council regarding the number of commuters that leave Agreed, the number of commuters leaving Fort Collins is lower than some other communities. In fact, data from the A11PO Comment addressed
Fort Collins daily to commute to Denver and/or other communities. Commuter rail and other sources has also indicated that the share of all northern area commuters who travel to the Denver metro area is
32 could potentially change nature of Fort Collins to become bedroom community to relatively low. The improvements proposed in the EIS do not noticeably change this pattern.
Denver. Project should compare Fort Collins' numbers to the numbers leaving our
neighboring communities. Fort Collins' numbers are much lower.
City Council Comments (October 2009 Memo) CDOT Response / Final EIS Staff Analysis (2011) Status
Prioritizing transit/commuter rail sooner versus highway widening improvements. The phasing plan developed with the TAC introduces both transit and highway improvements in Phase 1. The highway See comments on phasing
33 Implementing transit/commuter rail services earlier could defer or eliminate the need has aging infrastructure issues that need to be addressed in early phases. Express bus on I-25 and commuter bus along
for future highway widening. US-85 are initiated in Phase 1.
Need to focus on best ways to move people, not vehicles, to meet the long-term needs The FEIS Preferred Alternative includes Commuter Rail, a sustainable regional transportation connection between the Comment addressed, however continued
of our region; core of communities. The I-25 highway facility needs rebuilding to address aging infrastructure needs. The FEIS concerns such as transit ridership projections
34 Preferred Alternative includes a Tolled Express Lane (TEL) on I-25, allowing HOV vehicles free travel in a restricted /1
lane hence supporting the alternative modes of carpooling and varpooling. Express Bus service, with connecting bus v
service to the communities, also will serve the I-25 corridor in the TEL lanes.
Consider emerging larger-scale trends (fuel prices, new energy sources, demographics, We are aware ofthese trends that effect future travel. These issues will be qualitatively addressed in the FEIS. See comments on modeling
35 etc.) that will determine transportation needs/options in the future ;
Concern over how to serve commerce related transportation (freight, goods & Freight rail service will continue to be maintained in the corridor. The volume of future freight truck traffic is accounted Comment addressed
36 services); for in all the trajjic analyses conducted in the DEIS and FEIS The design ofI-25 and its interchanges will meet the /�
requirements offreight trucks. A
Concern over a consensus approach applied by CDOT to identify and prioritize Please elaborate on this concern?
37 improvements;
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
38
Need for more detailed analysis and data driven approach. Detailed analyses based on data have been conducted and documented in the DEIS; the same will be true for the See comments on modeling
39 Preferred Alternative in the FEIS
Cost estimates must be realistic and include costs for construction as well as on-going Detailed cost estimates are being updated for the Preferred Alternative and will be documented in the FEIS; including Comment addressed
40 operations & maintenance; capital construction costs and on-going operations and maintenance costs.
Need to consider more environmental factors such as air quality, land impacts, etc. in These factors are all discussed in the document See comments in each topic section
41 the detailed analysis of the proposed improvements.
Need to consider the costs vs. benefits for expenditure of public resources to support Costs are considered throughout the project development process, among other factors. Benefits are difficult to calculate Continue to be concerned regarding the issue
core transportation services and which provide the greatest degree of return on in terms of dollars, because monetary relationships are less definitive. For example, travel time savings would need to be for more systematic triple bottom line
42 investment. converted to dollars, and assumptions for value-of-time necessarily introduce subjectivity. For this reason, benefit-cost analysis
ratios are not typically calculated.
Consider the costs associated with deferring the improvements beyond 20 year horizon As you know, funding sources are extremely limited. Unfortunately, the 65 year timeframe is the construction schedule See phasing comments
shown in the phasing plans. The phasing plan 65 year timeframe is unrealistic and given current projections of revenue. It is possible the schedule for implementation of this project, and similar schedules
43 doesn't make sense, need to find more ways to fund necessary improvements in the for other proposed projects, will be a call to action for stakeholders to initiate new revenue possibilities so that the
nearer term. phasing plan can be accelerated
Page 5 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
General comment: Transportation Planning staff agrees with the purpose and need 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
of the North I-25 DEIS. CDOT, FHWA, FTA, and their consultant team, have been the same appreciation to CDOT staff and their
helpful to work with City staff over the years during the development of the EIS consultant team for their work with City staff and
alternatives analysis process and development of the DEIS document. City Council over the years and supports the
recommended Preferred Alternative however we
The DEIS packages "A" and `B" reflect input from City staff regarding offer these formal comments on the FEIS for
compatibility with the City's Transportation Master Plan, Master Street Plan, CDOT's consideration at this time as well as for
Transfort Strategic Plan (currently being updated) and the Mason Corridor Master input for the future implementation phases of the
Plan, Environmental Assessment, and Preliminary Engineering documents. Either highway and transit improvements.
44 of the DEIS proposed packages can serve Fort Collins' transportation needs in the /�
future to address both highway and transit improvements. A
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.
Travel Model:
In terms of more specific comments and concerns, Transportation Planning staff 2. The FEIS includes updated long-term forecasts to reflect 2035 RTP socioeconomic and network conditions. Agreed, CDOT did update the long-term forecasts to
recommends that future travel demand forecast modeling be updated by CDOT and separate land use forecasts would more accurately reflect the inter-relationship between land use and transportation 2035 which should more accurately reflect the
their consulting team as part of the selection process for the preferred alternative and infrastructure. Since the highway improvements are generally similar between packages, an expert paned concluded that future travel demand. However see prior staff
Final EIS analysis process to ensure that the most recent transportation and land-use future growth along I-25 would not substantially differ between the packages. The commuter rail ofPackage A and the comments items regarding continuing modeling
45 data is used for determining long-term transportation improvements. Also, separate Preferred Alternative would tend to attract growth near station areas in city centers, in contrast to the I-25 BRT and concems.
land use data assumptions should be developed for each of the two packages of express bus of Package B and the Preferred Alternative, but the magnitude of the differences would be relatively small.
alternatives based on the expected land use changes that would be driven by the For these reasons, the results of the comparison and evaluation of alternatives with different land use sets would not have
proposed transportation corridor improvements to more accurate reflect the inter- differed appreciably from the results with a single land use data set. Separate forecasts were not prepared due to the
relationship between land use and transportation planning. constant need or prudent use ofstudy resources.
Also, the current results of the travel model show that many trips are moving within 3. The DEIS technical analysis accounts for all trip purposes and trip origins and destinations within the northern and The inter- and intra-regional travel patterns
the North Front Range and to/from the Fort Collins and Longmont, Boulder areas Denver front range area. For purposes ofpresentation, some illustrations highlight travel along I-25. appear to have been included in the analysis.
along the US287 corridor. These inter- and infra-regional travel patterns, in addition
46 to the Fort Collins to downtown Denver trips, need to be analyzed in more detail for However those patterns need to be better
each package of alternatives and as part of the process to determine the preferred illustrated.
alternative. The preferred alternative should address all of these trip purposes, not
just the Fort Collins to downtown Denver trips along I-25.
Interchanges
Staff supports the analysis completed during the early stages of the North I-25 EIS 4. FHWA and CDOT would like to thank you for your participation and look forward to your continued involvement. Comments addressed
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
47 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.
Page 6 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Package A 5. The modeling for the FEIS has been updated to include the Mason Street BRT since it is a committed project; the effect The updated modeling reflects the City's
The proposed improvements shown in Package A, the regional commuter rail of co-locating the three stations in Fort Collins is reflected in the ridership projections for Package A and the Preferred comments regarding adding Mason BRT.
service and addition of general purpose lanes on I-25, are very effective to address Alternative. Similarly, the FEIS modeling jar Package B includes the Mason BRT and the effect of a common BRT station
high-quality transit system improvements as well as general highway travel, safety, at the South Transit Center.
and freight improvements to serve the Fort Collins community and North Front
Range region.
48 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.
City Transportation Planning staff does not agree with the need for double-tracking 6. Note that Package A has single track between University and the downtown transit center. During development of the The Preferred Alternative supports the single
of the BNSF railroad tracks from Prospect Road north through Downtown and Preferred Alternative, single track for the corridor between South Transit Center and downtown Fort Collins was track as suggested by the City.
believes that the existing single track is sufficient to operate service through evaluated in further detail, as you suggest. As a result, it was concluded that single track would have fewer
Colorado State University (CSU) main campus and through Downtown Fort Collins, environmental impacts while accommodating the Mason Corridor BRT. However, it was necessary to revise the service
as the DEIS states is shown for the downtown Loveland area. Staff has previously pattern on this segment of the corridor. The service plan for the Preferred Alternative consists of hourly service to/from
shared this comment with CDOT staff and their consultant team. 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
From Transportation Planning's perspective, the regional commuter rail transit serves the College Avenue Corridor at the South Transit Center.
alternative, while initially more costly than bus service, is an effective transit
49 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 7. Comment noted. Your observations of commuter rail's influence on land development patterns are generally consistent The Preferred Alternative with regional
Collins community will lessen the likelihood of future land development shifts with the findings of an expert panel convened to evaluate the alternatives regarding induced growth. The effect of commuter rail alignment along the BNSF
occurring away from the existing central population & activity centers within our Package A, Package B, and the Preferred Alternative on growth patterns is described in Section 4.2. 7: Since the highway corridor supports the City of Fort Collins
50 community. Fort Collins' adopted Transportation Master Plan and City Plan are improvements are generally similar between the packages, a similar amount ofgrowth near I-25 is anticipated for any of Transportation Master Plan and City Plan.
based on compact urban development occurring within the core areas of our the packages. However the commuter rail in Package A and the Preferred Alternative would intense the density of
community. The proposed regional commuter rail alignment along the BNSF developments near stations in the city centers.
corridor supports these transportation and land use master plans.
Page 7 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Also, the long-term return on investment that is likely to occur within Fort Collins 8. Yes, Package A and the Preferred Alternative connect to the RTD FasTracks system via commuter rail at both The Preferred Alternative, particularly commuter
due to the location of the three proposed regional commuter rail stations would be a Longmont and the North Metro end-of-line, and in downtown Denver. In contrast, the BRT of Package B connects only in rail, is in line with the City of Fort Collins goals
strong economic catalyst for additional higher density, mixed-use, transit-oriented downtown Denver. We agree with your assessment that commuter rail stations will be a strong economic catalyst for to support TOD development, and providing
development (TOD) over and above what is currently envisioned as part of the higher density, mixed use TOD. Values of TOD adjacent properties in the US have increased from 6.4 percent to more regional connections.
Mason Corridor. The potential synergy of high quality local and regional transit than 40 percent in the past few years. Office buildings have fewer vacancies if located within walking distance of a transit
service along this central corridor of the Fort Collins community will greatly serve station. As you state, the general purpose lanes of Package A provide additional capacity and are not restricted by
our long-range economic vitality and environmental stewardship values, as well as vehicle type. The Preferred Alternative includes adding both general purpose lanes and tolled express lanes to I-25 which
address our established transportation and land-use goals. will similarly address both passenger and freight traffic needs.
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.
51 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.
Package B: 9. That is correct, access to the regional BRT service would be by either walking, driving, or taking a local bus to a The Preferred Alternative provides general
station or stop on the Harmony Road corridor. Note that the access to commuter rail in Package A or the Preferred purpose lanes as well as toll lanes to serve
Transportation Planning staff has reviewed CDOT's DEIS Package `B" that Alternative is via the same choice of access modes but to the US-287 corridor through the core population area of Fort highway travel needs and includes the regional
includes regional Bus Rapid Transit (BRT) service originating from the City's South Collins. With the inclusion of express bus, the Preferred Alternative provides regional transit service on both the US 287 express bus service along Harmony Road from
Transit Center and making stops at the intersection of Harmony & Timberline roads and Harmony corridors. The evaluation indeed identified that freight traffic would not be directly served by the addition the City's new south transit center to I-25
as well as at the Harmony & I-25 Transportation Transfer Center and then traveling of TEL in Package B. However, note that mobility in the adjacent general purpose lanes is improved for freight and non- connecting to Denver.
to the Denver area along the center of I-25 in the High Occupancy/Toll (HOT) lanes, toll paying vehicles, but not as much as Package A. The Preferred Alternative includes additional general purpose lanes
also referred to in the DEIS as the Tolled Express Lanes (TEL). 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 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
52 service as well as other local Transfort routes. In addition, the regional BRT service A
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
Page 8 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
toll for speed/convenience purposes. Staffs 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.
General: 10. The PreferredAlternative has been developed through a collaborative decision makingprocess with communities and Fort Collins appreciates CDOT's efforts to
stakeholders from the study area. The future horizon year of 2035 has been used in the analyses presented in the Final include collaborative input from a wide spectrum
Overall, Package "A" and `B" are both sound alternatives and propose important EIS. The 2035 socio-economic projections use the adopted land use data sets of the NFRWO and DRCOG. Each of the of communities and stakeholders. The Preferred
transportation safety and capacity improvements for highway users and transit alternativesprovides multi-modal solutions thatprovide transportation choices for future travelers. Note the evaluation Alternative is consistent with the City
passengers to address the purpose and needs identified for the EIS process. for 2035 does not rely on a historical trend analysis but utilizes a travel model based on reasonable assumptions offuture transportation and land use plans.
However, it is important for the North I-25 EIS and community stakeholders to transportation conditions.
develop effective long-term solutions for our inter- and intra-regional transportation One of the most significant concerns the City
needs based on the anticipated future needs for travel, land-use, energy At this point in theplanningprocess, the only funds identified in the FEIS are those likely to come in through traditional continues to have regarding the FEIS document
consumption, sustainability, and environmental concerns — not based on past needs funding sources over the next 25 years. These f unds, and the projects associated with these funds are identified in the is the proposed phasing.
and trends. The next 20, 30, and 50 years will bring significant changes to our fiscally constrained regional transportation plans (NFRMPO and DRCOG). While the toll lanes have the ability to
communities, region, state, nation, and world and we need to be planning for the generate revenue and provide opportunities for bonding, the FEIS does not make any recommendations for or against Implementation phasing for the various
future — not based on the past. implementation through this means off ending. Additional funding identified by state,federal and local agencies will transportation improvements, specifically the
enable projects in Phases 2 and 3 to be implemented sooner. Fort Collins will continue to participate in determining how phasing plan shown for the future commuter rail
All of the proposed improvements (highway and transit) come at a steep price tag and which projects are funded in the North Front Range through their role on the NFRMPO Technical Advisory service extending from Loveland to Fort Collins
and CDOT, FHWA, and FTA will need to work collaboratively with all of the North Committee and the NFRMPO Planning Council. The TAC advises the Council and the council is the decision-making is not shown until Phase 3 (CDOT expected
Front Range communities, counties, and metropolitan planning organizations to body. Fort Collins has a seat on each. timeframe of 2075+).
strategize workable financing options for any of these proposed future regional
transportation infrastructure improvements. Thank you for your continued involvement in the process. Staff recommends that CDOT should revise the
53 FEIS to only show two phases — Phase 1 as
Transportation Planning staff will continue to be actively involved with CDOT, shown now, as the "fiscally constrained plan" v
FHWA, and FTA throughout the development of the final EIS document and will based on anticipated funding levels through
make every effort to convey the input and concerns from the Fort Collins' City 2035. Then, the new "Phase 2" would include all
organization, City Council, and community members to influence the final of the remaining elements of the Preferred
recommendations for these significant regional improvements. 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.
Additional/New comments, questions, and
suggestions on the FEIS for the
Transportation Planning section:
54 N 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.
Page 9 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Staff TAC and RCC representatives have voiced
our concerns about this phasing plan during the
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 should 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.
Correct reference is the "Mason Corridor", not
"Mason Street Corridor" nor the "Mason Street
Transportation Corridor '. The correct location
for the "South Transit Centel' 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.
55 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 Mi chelbrink, City Engineer, at (970)
Page 10 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
218-1409 or via e-mail:
hmigchelbrink@fcgov.com.
Page 2-64, will the new Park & Ride location
being built as part of the current SH292 & I-25
56 interchange project accommodate the future w t
parking demand (95 additional spaces) shown in ' Y
the FEIS?
The proposed Quiet Zone noise mitigation
strategies in the FEIS along the BNSF corridor
are consistent with the City's plans to evaluate
57 potential Quiet Zone improvements along this A '
corridor to address noise impacts associated with ' Y
the existing freight rail operations as well as
future passenger mil service.
I-25 highway improvements north of Harmony
Road need to accommodate the future extension
58 of the regional Poudre River Trail that will A ,
connect Fort Collins and Timnath and ultimately ' V
connect through to Greeley.
Regional "Foxtrot" route is now referred to as
"Flex" and connects from Fort Collins through
59 Loveland to Longmont where is connects into
RTD's transit system.
The list of Access Control Plans listed in the
FEIS (Chapter 2, section 2. 1 .3 should also
60 include the two access plans for US287 — North
College and South College Access Control Plans.
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
61 high speed rail? For example, are bridges over 1-
25 being designed with a "clear span" to allow
for future opportunities for rail transportation in
the center of I-25?
Page 2-15 seems to be missing a graphic diagram
of the future plans for improving the I-25 &
62 Prospect interchange — this interchange location A '
is mentioned in the text, but not included in the ' Y
page of images.
Page 11 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
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
63 begin. It should read: "Downtown Fort Collins
at Mason and Maple streets" (not at University
Avenue).
Pages 2-24 and 2-74, 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
64 information is important for the Commuter Rail
route shown in the Preferred Alternative and will
help address safety, traffic operations, and noise
concerns.
Sections 2.2.2. 11 and 2.2.4.9, City does not what
65 physical barriers to view sheds and wildlife A '
movement corridors in Fort Collins. ' Y
Page 3. 1-4, include the City of Fort Collins in the
list of I-25 corridor municipal plans (not just on
the US287 list of communities). Also revise the
66 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 .
Page 3. 1-7, regarding zoning, note that the City
of Fort Collins has a designated "Transit
67 Oriented Development Overlay Zone" in our
Land Use Code that covers the entire length of
the Mason Corridor BRT system.
Page 3. 1-11, regarding land use, 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
68 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 in511 and
redevelopment supported by high-qualiry transit
service and multimodal transportation choices.
Page 4-2, the more recent update to the City's
comprehensive plan is "Plan Fort Collins in
69 2010-11 which includes both City Plan and the
Transportation Master Plan. The 2004 updates
are no longer the most current documents.
Page 12 of 22
EXHIBIT A
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
Trans ortation Planning Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
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
70 Alternative (Phase I)? This information will also w '
help better define the potential benefits/impacts ' Y
to the local arterial streets from the planned
highway and transit improvements shown in the
FEIS.
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
71 stations are located in higher density population w t
centers such as Downtown Fort Collins. When t Y
future model projections are run for the
implementation phases of the proposed regional
transit system improvements, CDOT, NFR WO,
and local communities work together to update
these projections.
Page 13 of 22
EXHIBIT A
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
Natural Resources Staff Comments (December 2005) CDOT Response / Final EIS Staff Analysis (2011) Status
Part I: Natural Areas
General comment: The most troubling issue noted is the possibility of a chain link 11. The intent of the Preferred Alternative is to include fencing along the rail corridor to limit access and improve safety
fence installation along the commuter rail through Natural Areas in the southwest and to adhere to current RTD fencing standards and requirements. However, it is also recognized that the type of fencing
72 portion of Fort Collins. The fence would be highly disruptive to wildlife movement. 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 A
wildlife underpasses. The actual fencing selected during the design process will be based on consideration of need and
,function.
General comment: Maps for the EIS are not current and many City of Fort Collins' 12. All maps have been updated with new information that has been collected from the municipalities. The City of Ft.
73 Natural Areas and Parks are not shown. 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 A
arks correctly identified and this information has been used in the FEIS.
3. 1 : Land use. These figures only show land uses as of 2000 and should be updated. 13. All maps have been updated with new information that has been collected from the municipalities. The City of Ft. The map line weights in this section are so thick
Figure 3. 1 .2 doesn't show any open space/parks in Fort Collins. Figures 3. 1-3 Collins has been directly contacted and they haveprovided updated GIS files showing the most recent land use data for the underlying land use is difficult to determine.
through 3. 1-6 do not show all of the Fort Collins area open space/parks. For the city. The mistakes in the referenced maps have been recognized and corrected in the FEIS. Additionally this updated More detailed map sections reflecting individual
74 example, Fossil Creek Regional Open Space is shown as an employment area, even information has been used in the Final EIS. communities would be helpful.
in the 2030 projection.
Longview Open Space is shown as agriculture.
It should be shown as open space and was
designated open s ace at the time of mapping.
3. 10.5: Vegetation. Statement regarding "develop an acceptable revegetation plan" 14. The text has been changed to state that the revegetation plan must be acceptable to the City of Fort Collins within its
75 should note that the plan must be acceptable to the City of Fort Collins within its jurisdictional areas.
jurisdictional areas, not just acceptable to Latimer County.
3. 10-5. Vegetation. Removal of large cottonwood trees at the Cache La Poudre and 15. Impacts to riparian habitat will be mitigated by implementing CDOT's best management practices as described in Re-vegetation plans for disturbed areas should
Big Thompson rivers will seriously impair the quality and functionality of the Section 3.10.3, including avoiding existing trees, shrubs, and vegetation to the maximum extent possible, especially include species that are appropriate to the
riparian habitat. Bald eagles and other raptors frequently use these areas to perch and wetlands and riparian plant communities. The project team will coordinate with the CDOT landscape architect before community disturbed including woody species.
hunt from. Similarly the continuous "thread" of riparian habitat is critical to wildlife construction to determine the types of vegetation that will be protected during construction. A revegetation plan will be
76 movement up and down the river corridors. Also, it is not possible to mitigate the developed with the CDOT landscape architect and with county personnel in Adams, Boulder, Broomfield, Denver, The FEIS does not address the removal of large �1
loss of a large-diameter native cottonwood tree. Larimer, and Weld counties. CDOT will also have to go through the process of working with the CDOW when submitting cottonwood trees at the Cache La Poudre as it v
documentation to satisfy Senate Bill 40 for wildlife certification. will seriously impair the quality and
functionality of the riparian habitat. How can a
generic 150 yr old 36" diameter tree be
mitigated?
Table 3.12.2: Wildlife. Audubon Society has designated Fossil Creek Reservoir as 16. A reference to the high value of Fossil Creek Reservoir for migratory waterfowl and other waterbirds has been added
77 an "Important Bird Area" and the high value for migratory waterfowl and other to the table.
waterbirds is well-documented. This should be represented in the EIS.
Wildlife: Commuter rail appears to be aligned on the McKee Farm which is Latimer 17. The commuter rail alignment will be located within existing rail right-of-way. Construction of commuter rail would The preferred alternative fails to recognize the
County Open Lands property with conservation easements underlying the property result in some impacts to wildlife including habitat fragmentation, disruption of movement corridors, and displacement as significant impacts to wildlife movement along
that would prohibit new construction. Additional train traffic through the area would described in Section 3.12.3.2. Noise impacts to parks and open spaces have been considered in the FEIS, using the proposed commuter rail line between Fort
be a significant impact to recreation users (noise) and displace wildlife use within a appropriate guidelines. McKee Farm near the rail corridor is being actively farmed and has no visible public access or Collins and Loveland. The addition of a
3,000-acre matrix of protected Fort Collins natural areas. visitor facilities. maintenance road, concrete barriers with
additional chain link fence will significantly
78 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
Page 14 of 22
EXHIBIT A
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
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.
Figure 3-18-1. Parks and Recreation. There we quite a few missing natural areas 18. These natural areas and open space properties were identified for the FEIS process. Please see updated Figure 3.18-
79 and open spaces on the map, including Fossil Creek Reservoir Regional Open Space, 1. None of these open space and natural areas were identified as being impacted by the alternatives under consideration.
Coyote Ridge Natural Area, Long View Faun Open Space.
Table 3-18-2. Parks and Recreation. This figure is not up to date. There is 19. The figure and table have been updated to include the missing open space and natural area properties. Fossil Creek
80 misinformation about Fossil Creek Reservoir Natural Area (confused with the Reservoir properties have been correctly identified including their location. This property is not impacted by the
Regional Open Space; location is east of Timberline, not Timber Lake; etc.). alternatives under consideration.
3-18-3. Parks and Recreation. There will be direct impacts to Long View Farm 20. A Preferred Alternative that includes commuter rail has been identified and, along with Package A and B, has been
Open Space, and Colina Mariposa, Hazaleus, and Red-tailed Grove natural areas, as analyzed in the FEIS Impacts to these natural areas have been f lly assessed in that document. The referenced natural
well as indirect impacts (due to proximity) to other natural areas. The EIS states that areas (as well as a complete update to all land use information) have been identified and the design team is recognizing
81 no parks or recreational resources will be impacted by the commuter rail alternative; the potential for impacts to these resources and will make every effort to avoid or minimize impacts under all 3 build /�
however that cannot possibly be true because it goes through and next to a number of alternatives. The Preferred Alternative identifies single-tracking in this area that will remain within the existing right of A
natural areas. 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.
3.6. Noise. Noise studies should be conducted at Arapaho Bend Natural Area in Fort 21. A TNMmodel receiver at Arapaho Bend was included in the FEIS analysis, even though developed facilities are not Every effort to implement non-barrier methods
Collins. Any expanded use as part of the alternatives analysis needs to consider this present at the site. Also, local traffic noise conditions were represented by Receiver B012 at the nearby Strauss Cabin. of noise mitigation along I-25 (where it passes
site. This open space managed by the City of Fort Collins fall into "Land Use Please note that the project team feels Arapaho Bend is a Category B site rather than Category A (e.g., amphitheater). Arapaho Bend Natural Area) should be
Category A". City staff has noticed that noise levels likely exceed the maximum dB The comment is correct that traffic noise levels in the east of Arapaho Bend do exceed the CDOT Category B NAC for implemented. To be clear, we would not
levels outlined by CDOT. This area on the northwest corner of I25 and Harmony some of the open space. Noise mitigation for Arapaho Bend was evaluated and found not to be feasible and reasonable support construction of a barrier to mitigate
Road in Fort Collins should be evaluated. under CDOT's 2002 noise guidelines because there are no developed sites or recreational facilities with frequent human noise in this area.
use present along I-25 that would benefit from a barrier and a barrier did not meet the necessary Cost Benef t Index.
82 Therefore, noise mitigation it 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 EIS21. v
(coat.) 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 def ned facilities or formalized activity areas, a single generalized receptor should beplaced 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
3.6.4.1 . Noise. Any efforts to mitigate road noise (barriers) should consider wildlife 22. Two barriers have been recommended for the project area north of State Highway 7: Wellington East and Mountain
movement (deer, antelope) and create wildlife crossings across I25 especially north Range Shadows. Both of these are in fairly developed areas and are not in obvious wildlife corridors. No final
83 of Fort Collins and including the Wellington area. Any barriers within the more determinations on the specifics of these barriers have been made at this stage of the project, but the final choices will be
"metro" area should provide occasional openings to permit the movement of wildlife sensitive to the larger environmental context of the areas including wildlife movement. Also, see Staff Comment Response
across the interstate. #11.
Table 3.7-5. Water Quality. It is troubling that both action alternatives (Package A 23. It is important to note that there are anticipated pollutant loadings associated with existing and No Action
84 and B) will increase stormwater contaminant loading by 50% (for all modeled Alternatives. These alternatives do not have BMPs associated with them. The BMPs for the action alternatives are
Page 15 of 22
EXHIBIT A
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
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 anticipated, for example, to remove 50 percent to 70 percent of total suspended solids, which accounts for the predicted
under the no-action alternative. increase in loading.
3.8-12 (line 39). Wetlands. The EIS identifies the "former rest area site north of the 24. Comment noted. The relevant statement has been revised and will not include discussion of this site as a potential
85 Cache La Poudre River" as a potential mitigation site. In fact that land was mitigation site to offset impacts to wetlands and other waters of the US.
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 25. Any actions that result in a permanent dredging or filling of wetlands are required to be permitted by the US Army Wetlands impacted in the Fort Collins regional
and Fossil Creek need to be avoided or mitigated. Wetlands in these areas are highly Corps of Engineers (I7SACE). As part of this permitting process, mitigation will be required The first step in this process area should be mitigated within (the same) Fort
valued by wildlife including sensitive aquatic species. More detailed analysis is is avoidance or minimization of wetland impacts. At Spring Creek, avoidance measures have been implemented so no Collins regional area.
necessary. wetland impacts occur. At Fossil Creek, Package A has 0.05 acre of wetland impacts. The Preferred Alternative has 0. 01
acre ofwetland impact. This small amount ofwetland impact has been included in the mitigation package being reviewed Local mitigation requirements per City of Fort
86 by the Corps of Engineers for the Section 404 permit. 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.
3.9-20 (line 6). Floodplains. The proponents of this project need to identify where 26. CDOT is currently discussing possible wetland mitigation sites with Fort Collins staffand the U.S. Army Corps of
87 wetland mitigation would take place. CDOT or private lands would need to be Engineers. The details are in the Section 404 Permit application, which has been provided to the U.S. Army Corps of
identified for the mitigation. Engineers.
3.9 (General Comment) Floodplains. The mitigation measures for each creek, river, 27.Mitigation measures that will be employed consistent with each alternative include: The 100 year FEMA design Reiterate that wetlands disturbed within the Fort
or other drainage is vague, not site specific, and makes it impossible to evaluate for flows will be used for freeboard determinations, scour design, and to ensure that flow velocities are acceptable. The 500- Collins area should be mitigation within the
direct and indirect impacts to wetlands and floodplains. The same four mitigation year design flows will be used to further assess the scour design and set the depths ofpiles or caissons. The design will same region.
measures are identified for separate drainages. Revised, site specific mitigation plans consider the maximum allowable backwater as allowed by FEMA. Degradation, aggregation, and scour are to be
for each drainage should be conducted for the public and appropriate stakeholders to determined. Adequate counter measures will be selected using criteria established by the National Cooperative Highway The mitigation for each creek, river, or other
comment on. Research Program Report 568 (IRB, 2006) The design will be such that minimal disruption to the ecosystem will occur. drainage is vague, not site specific, and makes it
88 The design will consider costs for construction and maintenance. Abridge deck drainage system that controls seepage at impossible to evaluation for direct and indirect
joints will be considered. I possible, bridge deck drains will be piped to a water quality feature before being discharged impacts to wetlands and floodplains. The same
into a floodplain. The designs will comply with federal and state agencies. The designs will make every consideration four mitigation measures are identified for
towards local agency requirements and will be consistent with existing watershed and floodplain management programs. separate drainages. Revised, site specific
Please note that wetland mitigation is discussed in Chapter 3.8 of the EIS. 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 28. Effects are presented by component and by species. For key species, such as Preble 's and bald eagle, effects are also Full-cutoff light fixtures or similar standards
conducting an effects analysis on a broad scale is not adequate and the "one size fits broken out by site. Aquatic species are addressed by drainage. For black-tailed prairie dogs, site by site analysis would should be used in sensitive wildlife habitat areas
89 all approach" to mitigation is not adequate. Site by site and drainage by drainage not be productive due to the large number of small prairie dog colonies involved, and the likelihood that most of these (including the Fossil Creek Reservoir area �1
analyses need to be conducted to ensure impacts are avoided at best, mitigated at colonies will have expanded, contracted, or disappeared by the time of construction. Other species are addressed at a v
worst. 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 or exam le or Preble 's and bald eagle).
3. 13-12. Threatened Species. Additional lighting adjacent to Fossil Creek Reservoir 29. These suggestions have been incorporated in the FEIS for all alternatives.
90 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 A
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 30. The purpose and need for the project and stakeholder input provided the criteria framework for alternatives Regarding the original comment that land use
issue for local au quality improvement is to reduce the growth of vehicle miles development. The purpose of the project is to meet long-term travel needs between the Denver Metro area and the rapidly densification and transit-oriented development
91 traveled, which depends, in turn, upon land use changes that support use of transit, growing population centers along the I-25 corridor north to the Fort Collins-Wellington area. For this reason, both should be key criterion for deciding among
cycling, and walking. For that reason, we believe that land use densification and highway and transit options were considered for the project. While the transportation system can influence land use alternatives, we note the Preferred Alternative
transit-oriented development should be a key criteria in deciding among the patterns, development is regulated at the level of local government. provides the greatest number of alternative
Page 16 of 22
EXHIBIT A
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
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
alternatives. mode choices. Commuter rail and transit
stations can serve as a stimulus to TOD.
Changed conditions
The recent volatility in gasoline prices suggest that the basis of long-range land use 31. The EIS forecasts are conservative as no change in the relative cost ofgasoline is assumed, because predicting the Future transportation planning efforts such as
and transportation planning may now be in question. For example, what if the land price offuel would be impracticable. The forecasts are based on the adopted future population and employment forecasts this one must begin to develop methods to
use projections of I-25 corridor communities prove incorrect under a scenario of of the NFRMPO and DRCOG. If the price ofgas dramatically changes, it could indeed influence land use development define and assess a plausible range of key future
$3.00/gallon gasoline, or $4.00, or $6.00? What if the trip-production rates used in activity as well as travel behavior patterns. The FEIS acknowledges that the future price of gas is an unknown and condition such as fuel price because the risk of
transportation forecasting are incorrect for the same reason? The EIS should address therefore introduces an uncertainty into the forecasts, as described in section 4.2. 6.6. not doing so, and making poor investments with
the risk of making a poor choice from among the alternative due to the uncertainty of public money, is high. If fuel prices increase,
future gasoline prices. transit use will dramatically increase and
roadway investments made in the near future
92 may become stranded assets. Scenario-based
planning is used now in climate adaptation
planning that also involve significant
unknowns.
Fortunately, transit capacity can be relatively
easily expanded, and the FEIS notes that the
Preferred Alternative can accommodate up to a
90% increase in transit mode share.
Greenhouse gases
Several communities in the 125 corridor have adopted policies and/or plans to address 32. The DEIS and the FEIS both address the effect of the project alternatives on carbon dioxide, which is used as the The FEIS briefly discuses carbon dioxide
their contribution to greenhouse gas emissions. The reduction of transportation surrogate for greenhouse gas emissions. Package A produces 0.8 percent more carbon dioxide than the No Action equivalent emissions in Section 3.21 (Energy).
carbon emissions, which is directly proportional to vehicle miles traveled, is critical Alternative, Package B produces 0.4 percent more, and the Preferred Alternative produces 0.9 percent more. The City of Estimates show that the preferred alternative
to the success of these community efforts and the EIS should address the contribution Fort Collins has developed a Climate Action Plan to help reduce Greenhouse Gas (GHQ) emissions. The intent is to would increase CO2e emissions by 0.9% above
of the I25 decision toward their success or failure. 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 the No Action alternative. This is slightly more
implementing measures to reduce VAT, which in turn would reduce GHG emissions. It is estimated that 5 to 10 percent of than any other alternative and is attributed to the
automobile trips can be moved to non-motorized transport which would reduce the total VMT by I percent by 2012. There impact of attracting more VMT from other
are several transit projects proposed within the Denver Metro area. The Mason Corridor transit system will serve as the areas. It is a serious problem for this huge
backbone for the enhanced transit system in Fort Collins. Over time (after 2035), it would be expected that the rail investment in transportation infrastructure to
components of Package A and the Preferred Alternative would provide more options for lower energy consumption result in increased CO2e emissions. However,
because more trains could easily be added as demand increases. the modeling does not presume any use of
93 electric vehicles, does not assume any increases
in the price of fossil transportation fuel, and
acknowledges under-prediction of transit use.
Growth in these areas may result in lower
carbon emissions than predicted by the model.
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.
Ozone Non-Attainment
The DEIS refers to ozone designation inconsistently throughout the Air Quality 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 We appreciate the inclusion of updated ozone
chapter. All text should reflect the November 2007 non-attainment designation area source, as are otherpollutants, but forms as a secondarypollutant. Its precursors are certain reactive hydrocarbons and information in the FEIS.
94 for the 8-hour ozone standard. In addition the new, more stringent 8-hour nitrogen oxides, which react chemically in sunlight to form ozone. The main sources for these reactive hydrocarbons are
promulgated in March 2008 should be discussed. automobile exhaust, gasoline, oil storage and transfer facilities, industrial paint and ink solvents, degreasing agents, and
cleaningfluids. Exposure to ozone has been linked to a number of health effects, including significant decreases in lung
Page 17 of 22
EXHIBIT A
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
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
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, dustparticles, andpollen or mold spores. The size ofa
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 greatestproblems 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,
powerplants, 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.
Air Pollution Emissions Total air pollution emissions, including criteria
pollutants and mobile source air toxics, are
slightly higher for any of the 2035 Build
alternatives than for the 2035 No Action
alternative. For example, 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. This does not comply with
Fort Collins' over-arching policy to continually
improve air quality.
94A However, all alternatives including the N
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 comprehensive transportation demand
management strategies."
PM2.5
The Air Quality analysis does not address PM2.5, presumably because there are no 34. A project level PM2.5 analysis was not conducted since the Denver Metro area and the North Front Range are in The address for the PM2.5 monitor station in
non-attainment areas with the project study area. However, discussion of particulate attainment for PM2.5. However, precursors of PM2.5 include NOx and VOC. Emissions for this were projected for this Fort Collins in Table 3.5-2 should be changed to
matter levels in the Affected Environment chapter (page 3.5-7) acknowledges that project. Table 3.5-4 summarizes the regiomvide total mobile source emission estimates for existing, No Action and the 708 South Mason Street.
95 PM2.5 24-hour maximum concentrations show a steady trend of increasing in many three build packages. For NOx, emissions estimates show very substantial reductions of approximately 164, 000 tons per
areas. In light of this, PM2.5 impacts of alternatives should be addressed. 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 ofPM2.5 impacts are not anticipated in the future, with
or without the project improvements.
More Specific Comments:
3.5 Introduction 35. Figure 3.5-1 has been updated with the correct ozone non-attainment boundary for the Denver Metro area. The Greenhouse gas emissions were not added to the
The DEIS text in the introductory section of the air quality chapter should be updated following text has been added to section 3.5.2: "However, particulate matter levels even below the NAAQS can impact Air Quality affected environment chapter.
to reflect that areas within the project have been designated non-attainment for the the health of individuals with respiratory sensitivity. Therefore, the City of Fort Collins has implemented a policy to
96 federal 8-hour ozone standard in November 2007, per discussion in section 3.5.2. line `continually improve air quality as the city grows. " Table 3.5-2 has been updated with the new monitoring station in Fort Please note the City's over-arching air quality
Collins (3416 W LaPorte Ave) and "2005 " has been removed from the table title. Text has been revised on page 3.5-6, policy has been updated to simply say
3.5.2- Affected Environment section 3.5.2.2, criteria pollutants and critical pollutant data trends as follows:35. (cont.) "Ozone concentrations have "continually improve air quality."
Figure 3.5-1 should be updated to reflect the non-attainment designation area for the shown no consistent trend. Concentrations spiked in 1998, 2003, and 2005, with 2003 and 2005 concentrations exceeding
Page 18 of 22
EXHIBIT A
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
Natural Resources Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
8-hour ozone standard. This non-attainment designation should be discussed clearly the 8-hour standard in much of the regional study area. Concentrations at monitoring stations throughout the regional
in this section, as well as the updated, more stringent 8-hour ozone standard that was study area returned to levels below the 8-hour standard concentrations after the 2003 peak. However, concentrations
promulgated in March 2008. 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
The EIS states, on lines 13 and 14, that: "Other criteria pollutants are no longer Front Range area. Attainment designation for the ozone standard is based on a three year average. Therefore, since
pollutants of concern in the Front Range area." In fact, particulate matter levels even monitoring stations exceeded the 8-hour ozone standard for three consecutive years (2005 to 2007), the EPA designated
below the federal health standards impact the health of individuals with respiratory the Denver metro area and the north Front Range as a non-attainment area for the 8-hour ozone (03) in November 2007.
sensitivity. The City of Fort Collins has a policy to "continually improve air quality The 1-hour ozone standard was revoked after this designation. In March 2008, EPA strengthened the NAAQS for the 8-
as the city grows". hour ozone standard from 0.080 ppm to 0. 075 ppm. " A discussion of GHG is in the Energy section, Section 3.21.
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 36. See response to the "PM2.5 " Staff Comment #34.
non-attainment areas with the project study area. However, discussion of particulate
97 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 v
areas. In light of this, PM2.5 impacts of alternatives should be addressed.
Parks & Recreation Staff Comments (December 2008) CDOT Response / Final EIS Staff Analysis (2011) Status
Page 19 of 22
EXHIBIT A
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
Comments on the DEIS from the view point of affected City of Fort Collins parks and 37. Your review of the impacts is appreciated. The Preferred Alternative and Package A and B have been evaluated with I-25 improvements need to be designed to
trails: respect to parks and recreation resources, and is presented in the FEIS. accommodate the Poudre River Trail extension.
No-Action Alternative: No impact on Fort Collins parks and trails.
Section 3.18 Parks and Recreation, Review: Commuter Rail improvements along BNSF
Archery Range, Creekside Park, Lee Martinez Park, Old Fort Collins Heritage Park need to be designed to accommodate the Fossil
and Washington Park listed as being in the area of the project. Only affected park is Creek Trail.
the Archery Range.
Package A: Archery Range impact of 0.09 acre. Construction would be coordinated
98 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.
Advance Planning - CDOT Response / Final EIS Staff Analysis (2011) Status
Historic Preservation Office Staff Comments (December 2008)
The City of Fort Collins Historic Preservation Office has reviewed those sections of 38. No Response Needed.
the North I-25 Draft EIS document pertaining to historic properties within the Fort
99 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 I-25 project.
Regulatory and Government Affairs Division Staff Comments CDOT Response / Final EIS Staff Analysis Status
(December 2008)
Section 3.7 Water Resources
3.7. 1 Water Resources Reeulations 39. While there currently exists a statement that the project must also comply with local MS4 requirements (Page 3. 7-2,
100 General Comment: While the CDOT MS4 requirements described are generally only lines 19-20), an additional statement regarding construction and development/new development compliance has been /�
applicable in MS4 areas, please note that all local MS4 construction and development added. A
requirements must also be met within the local MS4 jurisdictional boundaries.
Table 3.7-5 40. The predicted constituent loadings from the Package A, Package B, and the Preferred Alternative presented in the
Both packages A and B are projected to increase stormwater contaminant loading by EIS do not include the application ofpermanent BMPs. All of the alternatives would show an increase in contaminant
approximately 50% for all modeled contaminants within the Cache La Poudre runoff in the Cache la Poudre watershed of approximately 50 percent, without the application ofpermanent BMPs. As
watershed above the current situation or under the no-action alternative. Runoff discussed in the mitigation section, the permanent water quality BMPs are expected to remove approximately 30 to 70
intensity and volume and higher pollutant loading are some issues commonly percent of various contaminants. Currently, there are no quantifiable removal rates for temporary construction BMPs
101 associated with increased imperviousness. 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 BAVs associated with all action alternatives, including the
The modeled pollutant loadings are before the application of best management Preferred Alternative are anticipated to reduce the pollutant load by the percentages identified in the comment.
practices. Does this include both those used during construction and permanent water
quality structures?
Page 20 of 22
EXHIBIT A
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
Regulatory and Government Affairs Division Staff Comments CDOT Response / Final EIS Staff Analysis Status
(December 2008)
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.
City of Fort Collins Water & Wastewater Utilities Department CDOT Response / Final EIS Staff Analysis (2011)
Staff Comments (December 2008) Water Quality and Floodplains Status
Technical Report
No comments submitted N/A 1)Pg 65, 5 bullet from top. Add to
sentence. . ....Denver, Adams, Weld and
Latimer Counties, along with most cities and
102 towns within the project area, are w ,
responsible for regulating development in 'V
FEMA designated floodplains and adhere to
FEMA policy and local Floodplain
regulations".
2)Pg 68-69, Cache La Poudre River section,
the bottom paragraphs of page 68 are
incorrectly stated. The City of Fort Collins
highly supports removing the split flow if
103 regulatory issues can be resolved through w '
mitigation with CDOT and staff working t v
together during design phase. State, Federal
and local regulations will all be adhered to
during the design phase.
3)Pg 71, table 6-1 . Would be helpful to add
column indicating what floodplain and what
jurisdiction each tributary is in. For
104 example, Boxelder Creek side drainage —
FEMA Regulatory Floodplain, City of Fort
Collins jurisdiction.
4)Section 6.4. 1, 6.4.2, 6.4.3, For each structure
105 improvement or modification listed, include
what flood lain, and what jurisdiction it is
Page 21 of 22
EXHIBIT A
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
in.
5)Pg 83, unclear what GPL and GP represent.
106 Would suggest defining these more clearly.
6)Pg 85 first bullet, Unsure where this is.
Would be helpful to more clearly show
107 location on map of each improvement w '
detailed in buffeted text for the No Action N
alternative, Package A and Package B.
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
108 have approved Conditional Letter of Map A '
Revisions (CLOMRs). Please contact Brian ' Y
Varrella, bvarrella@fcgov.com , 970-416-
2217 for more information on this location
and correct statements for this section.
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
109 with the administering local Floodplain w '
Administer will be required for all work in ' Y
the floodplains, flood fringes and floodways
to ensure all projects within the FEMA
regulatory floodplains meet federal and local
floodplain requirements.
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
110 modeling will be required on many A '
improvements per Federal and Local N
requirements. CDOT will coordinate with
local jurisdiction floodplain administration
in the initial stages of each project.
Page 22 of 22