Tuesday, July 8, 2008

Problems with Oahu's Rail EIS

As attempts to push ahead with a rail-only environmental impact statement (EIS) move forward, I would like to draw attention to these comments made by the Army Corps of Engineers to the city’s alternatives analysis, dated April 10, 2007.

(1) “Existing and modeled traffic data from the 2006 Alternatives Analysis Report suggest the implementation of the locally preferred alternative (LPA) will not improve the level of service (LOS) on most segments of the Interstate H-1 Freeway, including the high-occupancy vehicle and Zipper lanes, within the corridor study area [therefore] … the stated goal to “improve” existing conditions, or LOS, is somewhat misleading …”
My interpretation of this is that the City is set on selecting a solution and transportation alternative that is not likely to be of benefit to the people of Oahu.

(2) “… the inclusion of the verbiage “...to provide high-capacity transit...” is appropriate, but again, caution the use of language that is unduly restrictive.”
My interpretation of this is that the City is working with restrictions that are likely to be challenged successfully in court. The fixation on a fixed guideway violates both common sense and fair play, and is forcing the implementation of high-cost options that are detrimental to both taxpayers and commuters.

(3) “The Council on Environmental Quality regulations require an EIS objectively and rigorously examine all reasonable alternatives to the proposal. Towards this end, the range of alternatives should include reasonable alternatives that are not within the jurisdiction of FTA and/or DTS, if they exist.”
My interpretation of this is that the EIS should include a wide gamut of feasible alternatives, even those that are not under Federal Transit Administration (FTA) and Departmation of Transportation Services (DTS) jurisdictions. The Council's fixation on fixed guideways and FTA New Starts funds is not an excuse for improperly designing and analyzing alternatives in the EIS.

Bottom line: the EIS must include regional bus rapid transit (bus only based alternative with many express buses) and a mixed use transitway (Managed lanes/HOT lanes alternative with many express buses) in its detailed environmental assessment. The specifications of the alternatives should be subject to extensive public and expert comment before any results are produced. The Council must put the brakes on the city administration’s railroading of the project. It follows the path of the DC Metro Dulles extension for which FTA withdrew $900 million of funding.

This environmental process is biased and rushed. Please remember that there are no federal New Starts funds for this project before 2011 at the earliest.

I am also glad to see that Mr. Henry Curtis over at Transforming Hawaii has published a well-written and comprehensive post on the concerns with the rail-focused EIS. He leads of with:

There are rumors that the Honolulu Mass transit proposal has eliminated all alternatives except the preferred solution. This can't be so, as it would invalidate the EIS.

At a minimum, the Draft EIS must cover at grade and elevated rail, elevated toll road, expanded bus service, alternative technology and alternative routes and spurs.

and it just gets better from there.