Evaluation of the I-70 Mountain Corridor Draft PEIS

from a Clear Creek County Perspective

Many in Colorado have not embraced an adjacent transit alignment solution as preferred by Clear Creek County for the I-70 Mountain Corridor; however once people get a better understanding of the enormous construction impacts during the 15 year construction period for the CDOT "Preferred" alternatives, they may change their minds.

The focus of the Draft PEIS and surrounding discussion has been on how to fix I-70 through the Mountain Corridor. This is an appropriate discussion and usually triggers a lively debate. While the "fix" is important, we need to take a close look at the construction impacts of each alternative and determine whether or not there is a viable option for capacity in the I-70 Mountain Corridor during the 15 year construction period. We need to be sure that the alternative we select is in fact in our best interest, especially over the next 20 years.

At present the "Preferred" alternatives' impacts, construction length, and the reduced mobility during the construction period are not clearly understood by the public. Without studying the enormous Draft document, the most common initial reaction is that additional Mountain Corridor lanes can and should be added in just a couple of years and the congestion problem will be solved and peak travel times will be significantly reduced. Of course, nothing could be further from the truth and by the time that many realize the truth, CDOT may have already landed on a single preferred alternative that will have potentially devastating consequences for the state. For most Colorado residents and visitors, the time frame and construction impacts of the CDOT "Preferred" alternatives should be at the very least, alarming.

BACKGROUND & DETAILS:

A Record of Decision for the I-70 West PEIS should be reached by early to mid 2006. Specific design level detail Tier 2 Environmental Impact Studies, (as required by NEPA) will follow and likely conclude by 2010. It is also assumed that a meaningful amount of the final design work and initial acquisition of funding for the Record of Decision selected alternative will be completed by 2010 allowing some initial construction to begin in 2010. The construction time period is estimated to be from 2010 to 2025.

Construction in the Mountain Corridor is different than it might be in Metro Denver or other places in the country, since there are in places no viable alternative routes, (no side streets, no frontage roads, no other routes). CDOT has not addressed this aspect of construction in the Draft PEIS which needs visibility and public discussion within the Draft PEIS comment period.

In Clear Creek County there is no viable alternative to I-70 between Bakerville and the Eisenhower Tunnel, between Silver Plume and Georgetown and between Hidden Valley and Kermitt's, (US 6/US40/I-70 junction at mp 244). In other places in the county there are frontage roads, however the frontage roads carry only minimal capacity and are already clogged up during peak I-70 travel periods. The impact of I-70 congestion on the frontage roads and the impact on the local communities that the frontage roads traverse are getting worse and worse every year. The current frontage roads could not carry even limited corridor capacity during periods of major highway reconstruction and the impacts to our local communities would be enormous.

All CDOT "Preferred" alternatives are in the Greatest Construction Impact grouping. These impacts are described fairly well on Pages 2 - 64 through 2 - 68 and again on 3.9 - 17 to 3.9 - 20. Every Denver resident and visitor that enjoys access to the mountains should read these pages. CDOT has provided no viable alternative for mobility in the corridor during the construction period, (2010 to 2025) and basically dismisses the discussion until the conclusion the Tier 2 level studies in 2010, (well after a decision on the selected alternative is made).

The construction time period is estimated to be from 2010 to 2025. Several factors affect the length of the construction period for the CDOT "Preferred" alternatives.

1. Funding Availability

The availability of known funding sources would suggest an extended timeframe, (20 years from 2005 to 2025 in the Draft PEIS document). This 20 year period would provide $1.6 Billion from known sources which just covers the $1.3 Billion cost of the Minimal Action alternative. The "Preferred" alternatives extend to $3.47 Billion and may not contain adequate dollars for specific mitigation measures that will be detailed in the Tier 2 level analysis. Acquiring the funding necessary to complete any one of the "Preferred" alternatives may push completion of the alternative beyond 2025. The most likely of unidentified sources to bridge the funding gap is tolling of the current I-70 four lane facility. It is likely that CDOT will pursue tolling of the I-70 Mountain Corridor and/or the Twin and Eisenhower Tunnels to provide an additional funding option in the very near future. Imagine the possibility of paying tolls for many years for the inconvenience of traveling through an extended construction zone.

2. Highway Reconstruction

Highway reconstruction, (a minimum of 37 miles as included in every CDOT "Preferred" alternative) requires an increased footprint for additional lanes, increased footprint for relaxed curve geometry for higher design speeds and an increased footprint for construction disturbance zones, (not required for the AGS alternative). This will be very difficult work in the mountainous terrain of the corridor and take many years to complete. Challenges will include narrow canyons, huge rock walls, excavation of enormous amounts of material, blasting, additional tunnel bores, intrusion into watershed, rock fall and avalanche areas, disturbance of mill tailings and other heavily mineralized areas and intrusion into private property, towns, parks and historic and landmark districts.

3. Construction Season Length

The length of the productive construction season in the mountains is heavily influenced by weather, especially at higher elevations. Total reconstruction of a minimum of 37 highway miles as proposed in every "Preferred" alternative would suggest an extended number of construction years.

As we approach 2010, peak travel periods for the current I-70 facility will continue to extend into current off peak hours and days as more recreational travelers adjust their behavior to avoid peak congestion and delays. If peak travel periods are to be avoided, then major construction activities will have to occur in the shrinking off peak periods, which will result in less construction time available during each construction season.

4. Operation of the I-70 Highway during the Construction Period

It will be very difficult to maintain some level of operation of the current I-70 highway during the construction period. This will result in a longer construction process and one that is far less efficient than it might otherwise be if a viable option was available and the current facility could be closed for an extended period.

Prior to construction start in 2010, we will see Front Range population growth continue to stress our limited transportation infrastructure and increase peak travel times and congestion in the corridor. In response we could expect CDOT to pursue implementation of some promising early action items relating to Transportation Management and Aviation that could be effective with a low relative cost and impact. These items could include the following.

1. Travel Demand components such as enhanced traveler information and increased capacity at rideshare parking lots.
2. Development of a Transportation Management Organization of Corridor Stakeholders to oversee and encourage peak spreading, ridesharing, alternate recreation schedules and other marketing initiatives.
3. Travel System components such as enhanced incident management, ramp metering and slow moving vehicle plans
4. Aviation components such as radar improvements at Eagle County, Hayden and Aspen Airports to allow more frequent landings.
5. Tunnel Operational Enhancements such as better entrance and overall lighting at all Corridor tunnels.

All of these items will increase the operational efficiency of the current four lane I-70 facility and at the same time increase our reliance on these efficiencies for access in the Mountain Corridor. Some will keep travelers up to date on road conditions and traffic; provide public transportation routes and schedules and move travelers and truck traffic towards non peak hours.

CDOT's "Preferred" grouping in the Draft PEIS selects all the six lane highway alternatives and the bus in guideway transit alternative, (special bus lanes on grade in the center median). Each of these alternatives is identified as having the "Greatest" construction impact of all alternatives due to the number of miles of highway requiring reconstruction. The bus in guideway located on grade and in the center median would require the greatest number of miles of reconstruction, approx. 55 miles from C470, (mp 260) to Silverthorne, (mp 205) to accommodate the guideway in the median. Reversible lanes has the widest footprint and the most severe construction impact through all of Clear Creek County, (approx. 34 miles), and includes 3 miles of reconstruction through Dowd Canyon. The 55 mph and 65 mph six lane highway alternatives contain the same number of miles of highway reconstruction, (approx. 37) with some additional tunnels in the 65 mph alternative and only a slightly less wide footprint than Reversible Lanes.

Each of these alternatives will aim to keep the highway operational during the construction period; however we know that reductions in the number of lanes, and temporary total closures will occur during off peak travel periods. Even during peak periods, these alternatives will likely create lane closures, lane and shoulder narrowings, transitions and detours from old pavement to new pavement with reduced standards and speeds, and convoying of traffic through one-way stretches, all of which will add to travel times. The use of traffic control devices will be extensive and will affect the speed of traffic in construction areas. Construction activity in close proximity of traffic will likely result in extended traffic interference. The residents of Clear Creek County, their visitors, businesses, governments and other institutions, and all of the people traveling through the county will be affected by the construction work.

CDOT officials will downplay the construction impacts of their "Preferred" alternatives and tout their expertise in managing construction activities, as demonstrated on I-25 during T-REX and US 40 on Berthoud Pass. While there is no doubt that CDOT has considerable expertise in this area, the Mountain Corridor is a much more restricted corridor than I-25 and the I-70 traffic volumes are many times greater than US 40 at Berthoud Pass. CDOT also does not control driver's behavior, regardless of their construction management techniques. People slow down when the orange cones and barricades come out and they love to take their time in construction zones and monitor construction activities.

CDOT is assuming a best case scenario for construction management and mobility during the construction period for the "Preferred" alternatives. Assuming a best case scenario does not define good planning. CDOT must identify the mobility restrictions that are possible during the 15 year construction period for each alternative evaluated in the Draft so that the public can better understand and compare the alternatives.

Recreational travelers, unlike commuters who must work specific hours, have a choice in making travel decisions. This choice will continue to push recreational travelers away from current peak travel hours and effectively spread peak hours earlier and later in the day or night and further into weekdays, (especially Thursday's, Friday's and Monday's). Eastbound and westbound peak hours will further overlap on busy travel days. Recreational travelers may even push into adjacent seasons as Summer recreational trips extend into the Spring and Fall to avoid the prime season congestion. The major construction activity will occur in the Spring, Summer and Fall months. Growing peak travel during these months will make avoidance of construction activities during peak travel periods especially difficult. Even if peak period construction activity can be avoided, those who would have made off hour and weekday travel plans to avoid peak hour congestion, will now find considerable construction related congestion and delays in those off peak hours. Almost no one will be able to escape the construction delays.

Highway improvements in the I-70 Mountain Corridor may be inevitable, but 15 years of construction delays is unprecedented. CDOT's pursuit of a highway solution to the corridor's traffic problem regardless of the consequences will have a significant impact on Tourism in the state.

CONCLUSION:

The net result is that by 2010, we will be making the best and most efficient use possible of the existing four lane I-70 facility in the Mountain Corridor. Our lifestyles will have become more reliant than ever before on maintaining this operational efficiency to provide us with some minimum level of access to the mountains. There will be no viable option to mainline I-70 travel when the construction of the CDOT "Preferred" alternatives begin. Even off peak travel will be affected by construction activities resulting in significant delays. As a result, our access to the mountains will be severely compromised. By 2010 recreational peak travel growth may make it impossible to limit construction activities to off peak days and hours.

The outcome of this PEIS will have the greatest impact on those Colorado residents and visitors in their 30's, 40's, 50's and older. Many of these folks are Baby Boomers who make up the primary consumer base and second home owners for the western slope resort communities. The 20 year PEIS time frame would suggest that we will not derive any substantial transportation benefit in the mountain corridor until the construction of the selected alternative is completed. Those younger may be able to take advantage of these improvements, while those in their 30's, 40's and 50's will be more concerned about the next 20 years. Their primary experience with the I-70 West PEIS will be in the next five years as congestion increases prior to major construction and then the fifteen year construction period. Mobility during the next 20 years will be a critical factor in their lifestyles and may ultimately determine whether or not they stay in or visit Colorado.

The effective result of the construction related mobility disruption will be a huge number of people avoiding the mountain corridor altogether during the 15 year construction period. This will drive tourists away from DIA and make states like Utah, Idaho, Wyoming and Montana much more attractive as travel from the airport to the resorts is easier and less stressful.

SOLUTION:

Limiting the scope of this project to 20 years and selecting only highway widening alternatives is short sighted and poor planning. It will simply delay a real solution for another 20 years. We must pursue a long term vision that provides a viable option to I-70 while improvements are made to the current highway facility. We must convince CDOT and the FHWA that the overriding purpose and need of this PEIS should be mobility in the Mountain Corridor during the next 20 years in addition to mobility in the corridor beyond the next 20 years; as opposed to just mobility in the Mountain Corridor in the year 2025 as is the current baseline standard for mobility in the Draft PEIS.

We must pursue an alternative that will leave the current four lane I-70 highway basically intact during the fifteen year construction period. An option must be made available to provide residents and visitors with a viable alternative to extensive construction delays before any main line I-70 highway reconstruction is initiated. Any alternative that reconstructs the highway or builds Transit in the center median, (which requires major highway reconstruction), before a viable option for corridor capacity is made available, must be discarded due to the enormous mobility restriction during the construction period.

Outside from building a new East-West major four lane freeway elsewhere in the state, (alternative routes screened out earlier in the PEIS process), a high speed elevated transit system capable of being built adjacent to or further away from the I-70 highway alignment is the best choice. An elevated guideway could have the ability to deviate from the highway alignment to reduce construction impacts to the highway and to be more cost effective than building new tunnel bores. The theory would be to build a minimally intrusive elevated transit system and keep the current four lane highway operational just as it is today during the construction of the guideway. Elevated guideway construction methods could be explored that work from the elevated platform once the stanchions are placed, which would further reduce construction impact to the highway.

The June 2004 Federal Transit Administration Report on the Colorado Maglev Project describes such a system. The FTA Report was used by CDOT for components of the Advanced Guideway System as evaluated in the Draft PEIS. It could also be argued that a Public/Private partnership may reduce the overall costs of the FTA proposed system which would make it more cost competitive with the other alternatives.

It will take real leadership to create a long term vision and pursue new technology and innovative solutions to select the best alternative to the Corridor's mobility problems. The current transportation mind set in the United States promotes highway alternatives, so a break in this pattern will require a great deal of courage, determination and political will. We should challenge our state leaders to demonstrate this courage and leadership.

ADDITIONAL NOTE ON SIX LANE HIGHWAY ALTERNATIVES:

With anticipated Front Range Growth in the next 20 years and the accumulated suppressed demand over an extensive construction period, we could see very rapid traffic growth in 2025 or in the year that the highway improvements are finally completed. Growth plus liberated suppressed demand by additional highway lanes could very rapidly create congestion over six lanes that is equal to or worse than it is today. We could potentially experience a horrific construction period from 2010 to 2025 or beyond, only to see congestion reach intolerable levels in a very short time after completion. In addition we will need to figure out what to do with all the additional vehicles using this increased capacity once they get to Grand, Summit, Eagle, Pitkin, Lake and Garfield Counties. Do the destination resort communities have the land, resources and desire to build the infrastructure necessary to accommodate a significant increase in vehicles?

When the six lane congestion again reaches an intolerable level, then do we again engage in another PEIS study and again endure the mobility restrictions of yet another extended construction period? This would best define poor planning. A better option might be to build elevated transit today in an adjacent alignment and once operational, address the current I-70 highway deficiencies requiring major reconstruction, especially in the area of safety and maintenance.

When does another PEIS focus on another East-West corridor in the state? It might be argued that this PEIS should have done exactly that. The alternate East-West corridor discussion has perhaps been delayed by this PEIS, however over time; this will be an inevitable solution for the state's transportation needs.

ADDITIONAL NOTE ON ALTERNATIVE ROUTES SCREENED OUT EARLIER IN THE PEIS PROCESS:

On Page ES-46 of the Draft PEIS it states the following Concern and Response.

Concern: An alternative route for access to the Mountain Corridor should be established.

Response: A total of 16 alternative routes, (see Page 2-11) were studied and screened out because they do not address the needs of the I-70 Corridor. Because the purpose and function of the alternative route was oriented toward resolving traffic problems on I-70, many of the alternative routes were screened from consideration because they would involve longer travel distances than does a comparable trip on I-70. Also the new infrastructure along these routes would result in large social and environmental impacts as well as economic costs.

On Page 2-11, two alternate routes did make it to level 2 screening. These were SH 58, SH 93 and SH 72 to Rollinsville in conjunction with a new tunnel paralleling the Moffat Tunnel that would eventually connect to Winter Park. The other alternate route was US 285 to Jefferson in conjunction with a new tunnel under Georgia Pass connecting to SH 9 north of Breckenridge and continuing on to Frisco and I-70 in Summit County.

The conclusion reached in screening out both these alternatives in level 2 screening was that neither route would remove enough traffic from the I-70 Corridor to improve travel conditions and avoid the need to pursue mobility enhancements to I-70. In addition, the improvements to the existing roadways and the new roads and tunnels that would be required would result in large social and environmental impacts, as well as high costs due to tunneling.

If these alternative routes were screened out because they did not address the needs of the I-70 Corridor, I am curious how alternatives with 15 years of construction disturbance will better address the needs of the I-70 Corridor. I am also curious why large social and environmental impacts, as well as high costs due to tunneling are included in the various CDOT "Preferred" alternatives, (especially 65 mph Highway), but were screened out as alternative routes. Apparently large social and environmental impacts and large economic costs in the I-70 Mountain Corridor, (Clear Creek County specifically), are less important than they would be in the areas of these alternative routes.

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