Initial Comments on the City Released Untitled and Undated Draft EIS Summary

• This document is endless blah-blah with very few project specific numbers.
• Cost has escalated from $3.7 billion in 2006 to $4.8 billion in current dollars and FTA contribution remains in $900 million 2006 dollars resulting in an FTA contribution of under 25%, the lowest contribution of any recent rail system in the nation.
• This document makes it clear, that the only system in question is from East Kapolei to Ala Moana Center. It does not include any information about west Kapolei, UH and Waikiki which are now “anticipated future plans.” Up till now we believed that anticipated future plans were Mufi’s obfuscations about extensions to Mililani, Waianae and Hawaii Kai.
• 212 condemnations including 1 church and 67 business is a substantial impact. Also 84 affected historical resources is a substantial impact. It is not clear whether any of these impacts and their mitigation costs are in the price tag.
• Extensive utility relocations (sewers, water, gas, electric lines) will be needed. They are not mentioned and are not likely included in the price tag.
• Total congestion reduction estimates of 23% are pure fantasy. No such relief can be achieved even if trains can be filled to their theoretical maximum capacity of 6,000 passengers in the peak direction. Throughout the nation, rail studies show that for modern rail systems only up to 25% of rail riders are ex-motorists. The rest are ex-bus riders, ex-carpoolers and new trips. Thus rail may reduce traffic on H-1 by 6%. This rail will never provide a two digit congestion relief.
• Current City presentations assert that the project covers a corridor that includes 60% of Oahu’s population. The summary says that a Project Station Area is one half mile around each station. The stations are the only relevant point of the system. The station areas cover less than 5% of Oahu’s population.
• The 2003 FEIS used a lower Oahu population and a far cheaper gas price (which works against transit) but it produced much higher ridership for a bus system than the 2006 rail estimates. But this alternative is not in the EIS.
• There is no form of exclusive busway in the EIS. It is rail or nothing. What a poor payoff from a 100+ million dollar consultant contract!
• Visual and aesthetic impacts include “project components that are out of scale and character with their setting.” This is one exceptionally precise statement this DEIS summary makes. The whole project is out of scale and character with Oahu.

One must be cautious in interpreting this FTA approval. It is not a federal approval of the project and its impacts. It is approval as to form and not as to importance of the impacts. In other words, the FTA approval of this DEIS means that it is sufficiently comprehensive in looking at potential impacts and the proper models were used to analyze the impacts. The FTA did not approve of the impacts. Two examples:

The FTA is not in the business of approving the demolition of churches and the destruction of 100+ year old trees. The community must decide if those are acceptable impacts or if the project needs to be rerouted.

The FTA is not in the business of reassigning right of ways from city to state and vice versa. The rail project takes away all the median and some sidewalks of Kamehameha Hwy. in Aiea. That’s State DOT property and the state has to determine whether this permanent loss of their right of way is acceptable.

FTA’s signature to release the DEIS does not mean
-- that the impacts are minimal or approved
-- that the mitigation of impacts is adequate
-- that all outputs are accurate and that the benefits are large
-- that the financial plan is good, or that a better one would be hard to obtain.

All of the above are to be considered by the impacted community and its agencies, and decide on the weaknesses of the study, on the severity of the impacts, on the mitigation strategies, and on the financial details vis-à-vis the ability and willingness of the population to pay.
Once the community and all involved and affected agencies sign off on the impacts and mitigations (as amended), then FTA may give federal approval. It usually takes more than two years from the release of the Draft EIS to the completion of the Final EIS.