According to the Citizens Guide to the NEPA and EISOne key aspect of a draft EIS is the statement of the underlying purpose and need. Agencies draft a “Purpose and Need” statement to describe what they are trying to achieve by proposing an action. The purpose and need statement explains to the reader why an agency action is necessary, and serves as the basis for identifying the reasonable alternatives that meet the purpose and need.Here are the core "need statements," the reasons for the bridge from the Purpose and Need, along with brief responses. (Over the next month it may be useful to revisit them in more detail. We'll see.)
The identification and evaluation of alternative ways of meeting the purpose and need of the proposed action is the heart of the NEPA analysis. The lead agency or agencies must, “objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” Reasonable alternatives are those that substantially meet the agency’s purpose and need. If the agency is considering an application for a permit or other federal approval, the agency must still consider all reasonable alternatives. Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant. Agencies are obligated to evaluate all reasonable alternatives or a range ofreasonable alternatives in enough detail so that a reader can compare and contrast the environmental effects of the various alternatives.
Need Statement #1. Based on available data, the existing river crossing facilities and local bridge system in Salem are inadequate for current and future traffic demand, resulting in a need to improve traffic operations in the study area over the No Build Alternative conditions.Not True. Available data shows people are driving less, and young people are driving even less. Gas and energy are likely to cost more in the future. We cannot assume that 20th century driving patterns will characterize the 21st century.
Need Statement #2. Based on available data, the existing river crossing facilities and local bridge connections in Salem are inadequate for current and future users (vehicles, freight, bicycles, and pedestrians) with regard to safety conditions, resulting in a need to improve traffic safety for all these users.While the bridge connections (and here and here) are especially bad for people who walk and bike, the proposed solution, a big bridge, won't address the problems. It is a solution for a different set of problems.
Need Statement #3. Based on available data, the existing river crossing facilities and local bridge system in Salem are inadequate for current and future freight-vehicle capacity, resulting in a need to improve freight mobility in the area of the Center Street and Marion Street Bridges.I don't know about freight movement, but this passes the "sniff test" - it's quite plausible. But again, there are many other solutions than a new, big bridge.
Need Statement #4. Congestion levels on the existing river crossing facilities result in unreliable public transportation service, thereby necessitating an improvement in transit travel time and reliability from/to West Salem.Um...tolling will help a lot. As would staggered start times for downtown businesses. The TDM/TSM analysis was inadequate, and conclusions like this should not be drawn from it.
Need Statement #5. The existing river crossing options in Salem are inadequate to accommodate emergency response vehicles in the event of restricted access to and/or closure of the existing bridges because of an emergency or other incident, resulting in the need to provide improved crossings or an additional crossing in case the Center Street and Marion Street Bridges are closed or limited because of an incident.Probably true, but a smaller bridge would address this particular need. So would making each bridge two-way.
As I read the Purpose and Need, rather than asking impartially about transportation and connection problems, and looking at a range of solutions, the project team appears to be backing into a "Purpose and Need" preordained to return a particular solution - a big highway style bridge. The analysis fails to "objectively evaluate all reasonable alternatives."
For more on the River Crossing see a summary critique and all breakfast blog notes tagged River Crossing.
3 comments:
Regarding need 1. The original Capacity Study starts with this whopper: By 2015, traffic volumes on the bridges are
expected to increase again by almost 40 percent to 106,500 ADT. The p.m. peak-hour design
capacity on the Marion Street Bridge is currently estimated at approximately 4,500 vehicles. The
estimated p.m. peak-hour traffic demand on the Marion Street Bridge in 2015 will be
approximately 6,700 vehicles, creating a p.m. peak-hour traffic capacity deficit of about 2,200
It is now 2012 and I doubt we've cracked 90000 ADT.
I'm looking for the freight numbers now. IIRC they are about 4% of trips over the bridge.
On freight from the ES: In 2009, truck trips accounted for 4.5 percent of traffic flow across the bridges. Because of the
region’s growing population and employment, freight travel demand across the river
increased an average of approximately 1.8 percent per year between 1995 and 2009. High
traffic levels are resulting in increasing levels of delay.
Chapter 3 shows that for many intersections in the study area they will actually perform worse with a third bridge than with no build. Even the $700 mil. option shows no improvement over today. So what "fails to meet the mobility standard" today will still fail in 2031.
There's something Medieval and Scholastic about the way a large structure of faulty conclusions are spun out of faulty assumptions and analysis - but hey, it's internally consistent, right?
Never mind the data - it's a glorious cathedral of thought!
But at some point you have to ask when do the faulty conclusions start becoming knowing falsehoods?
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