TLC's Comments on DEIS for Central Corridor

Following are comments provided by Transit for Livable Communities (TLC) on the draft Environmental Impact Statement (DEIS) on Central Corridor. TLC appreciates the work of Ramsey County and Hennepin County in planning for and promoting a major transit investment for the Central Corridor.

Any questions about TLC’s comments may be directed to Barb Thoman at phone number 651-767-0298 or e-mail barbt@tlcminnesota.org

GENERAL COMMENTS
The Central Corridor will be the core transit connector for the Twin Cities region, connecting the two largest downtowns, the University of Minnesota, and the state Capitol. The corridor has strong bus ridership and contains diverse neighborhoods and a thriving small business community. The east end of the corridor includes the Rondo Community, which suffered severe displacement in the last century caused by the construction of Interstate-94.

Improving transit in the Central Corridor will provide current and new transit riders with faster, more reliable, more frequent and more cost-effective service. It will help address traffic congestion, air and noise pollution, disinvestment in the core cities and suburban sprawl. Any transit investment in the Corridor must preserve key community assets and meet the needs and interests of the communities through which it passes. To ensure community participation in transportation and land-use decision making, timely education and outreach in all phases of planning, design, and construction will be critical. Resources to integrate community input are also necessary.

1. Transit technology. TLC believes that light rail transit (LRT) rather than bus rapid transit (BRT) or other bus alternatives, is the appropriate technology for the Central Corridor. LRT can best accommodate the projected ridership over the long term while improving air quality and reducing traffic noise. LRT also provides easier and faster boarding for wheelchairs, bicycles, and strollers, and people carrying groceries or luggage. Light rail is the technology most likely to result in transit and pedestrian oriented-development.

2. Affordability. TLC recommends housing development that ensures life cycle housing for a range of incomes and household needs. Light rail can play an important role by reducing the need for expensive underground parking and by encouraging location efficient mortgages, both of which make housing more affordable for everyone.

3. Community preservation. TLC recommends emphasizing a “sense of place” in order to preserve and improve community, cultural and historical amenities.

4. Location, number of stations, size of stations. TLC recommends that the County provide additional station(s) east of Snelling Avenue and eliminate station(s) in downtown St. Paul. TLC recognizes that the overall impact of the number of stations must be carefully evaluated as more stops can increase ridership while the increased travel time tends to reduce ridership and that a BRT or LRT project must meet cost-effectiveness guidelines established by the Federal Transit Administration.
Strong consideration should be given to designing stations to serve three cars trains so that they can be most easily and cost-effectively expanded to accommodate three car trains in the future.

5. Alignment. TLC supports the recommendation of the Central Corridor Coordinating Committee to have the Central Corridor transit line follow a University Avenue alignment. Placing light rail in a freeway median provides faster travel times but makes transit oriented development and pedestrian access to stations much more difficult.
TLC asks that the counties and Met. Council evaluate the proposed alignment in downtown St. Paul in light of new development, lessons learned from Hiawatha LRT (wheel squeal and the difficulties of utility relocation) and the time savings provided by a more direct routing (e.g. west on 4th then north on Jackson, or north on Cedar, then jog in front of Capitol following BRT alignment).

TLC recommends that the counties and Met. Council consider a tunnel alignment for motor vehicle through-traffic on Washington Avenue while building LRT and retaining local traffic within the roadway rights of way on the surface. This would reduce traffic noise and vehicle emissions at street level, help to unify the campus, reduce the cost for stations, and make boarding for LRT passengers easier. In Washington DC there are many examples of through traffic being routed through a tunnel.

6. Pedestrian/bicycle environment. The section of the DEIS on pedestrian and bicycle travel is very weak. TLC recommends that the City of St. Paul adopt pedestrian and bike friendly design guidelines for the corridor and that investments be made to greatly improve the pedestrian environment. Improved facilities for pedestrians and bicyclists include such things as bike racks, street trees, pedestrian scale lighting, benches, and pedestrian countdown signal both at the stations and along the Central Corridor.

7. Bus service. TLC recommends the retention of express bus service between the two downtowns as proposed (route #94). Bus service within the corridor (route #16) should be restructured to provide local/circulator service along University Avenue. Existing north/south mainline bus service connecting with University Avenue stations should be greatly expanded and new bus service should be added at Lexington Avenue (from Roseville to Fort Road/West 7th). Bus service should be frequent enough so that a bus on each north/south route will meet a train. This will greatly reduce “hide and ride” vehicle parking in adjacent neighborhoods.

8. Traffic signal priority. Signal priority (shortening the red cycle and lengthening the green) should be for provided for trains along the corridor and for connecting buses with high ridership. The experience with Rapid Bus in Los Angeles is a good example of how this can work well.

9. Roadway design and safety. TLC recommends that University Avenue be redesigned to incorporate traffic calming principals that balance the needs of all users (transit, bike, pedestrian, auto, truck) and to promote driving at or below posted speeds and thereby promote a safer transportation system.

10. Roadway costs. All costs associated with reconstruction of University Avenue for vehicle traffic should be kept separate from the costs of the transit project and should be paid for with non-transit revenues. If the estimated cost for rebuilding University Avenue for motor vehicles is $100 million of the estimated $840 million cost of the project, the project cost should be listed as a $740 million transit project and a $100 million road project. When the costs are bundled, state policy makers and the general public get the impression that transit is too expensive and thus unaffordable.

11. Level of service (LOS). The County should allow for traffic flows at level of service E and F along University Avenue and major connecting streets during peak hours (not a minimum LOS “D” as specified in the document). The document should list other major cities that allow for LOS “E” and “F.” The County should also establish a level of service for bicyclists, pedestrians, and transit users.

12. Density. TLC recommends that development reinforce and support transit use; increase the viability of neighborhood retail and the quality of neighborhood life. Generally, a minimum residential density of 12-24 units per acre is usually needed to support fixed route bus service (frequency of 15 minutes or less), and 12-30 units per acre for light rail.

13. Design. TLC recommends that zoning along the corridor require developments be transit and pedestrian friendly. This generally means that: buildings face the street and include windows and architectural details that enhance the streetscape and increase safety; parking is concentrated off street or in the rear of buildings; drive-through uses are restricted; signage is regulated; alleys are enhanced as pedestrian routes, and historic preservation is encouraged.

14. Mix of land uses. City zoning, site plan and other regulations should encourage a mix of commercial, residential, and retail uses with a de-emphasis on one-story "big box" stores.

15. Integration of density, design, and diversity of land uses. TLC recommends the thoughtful integration of density, design, and diversity to enhance and preserve neighborhoods that are healthy, vibrant and livable.

16. Construction mitigation. TLC recommends implementing strategies of construction staging and mitigation used in cities such as Salt Lake City, Utah, and Portland, Oregon, (Interstate corridor) in order to minimize the impacts on existing businesses and residents. Two lanes of vehicle traffic on University Avenue should be maintained during construction.

17. Parking. TLC recommends that development along the corridor minimize the amount of off-street parking needed and provided through use of shared parking, car sharing, and unbundling the parking from the cost of the development. Generally, off-street parking should be located behind, in, or under any structures. On-street parking is desirable and should be metered. A Parking Benefit District should be considered. Parking Benefit Districts direct existing or new parking revenue from on-street parking to the community in which these revenues are generated. As parking expert Donald Should notes,"Parking Benefit Districts can create a symbiotic relationship between parking generators and their nearby neighborhoods, because any spillover parkers will be paying guests."
Angle parking on connecting streets should be considered for reasons of adding additional parking or traffic calming. Local zoning regulations should emphasize maximum number of spaces allowed instead of minimum.

18. Travel Demand Management plans. Large and mid-size employers located along the Central Corridor should be required to complete a Travel Demand Management (TDM) Plan. TDM plans include specification of on-site infrastructure and incentives that encourage the use of alternatives to driving alone by employees. Effective TDM plans typically involve monetary incentives (e.g. discounted transit passes, alternative transportation allowance in lieu of free parking), designating an employee transportation coordinator, participating in regional alternative transportation promotions (e.g. Commuter Challenge, bike-to-work day) and bi-annual commuter surveys to evaluate (and refine) TDM strategies.
Central Corridor employers are currently served by three transportation management organizations (Saint Paul Area TMO, Midway TMO and Downtown Minneapolis TMO) that will assist employers, at no charge, in promoting transit and other alternative commuting options. The cities of Minneapolis and Eden Prairie offer excellent examples of TDM requirements for new developments.

SPECIFIC COMMENTS
19. Operating and maintenance costs. Page 2-21 and 6-27 and other pages. On page 6-27 the distinction between Central Corridor LRT Operation and Maintenance costs ($13.4 million in 2002), and Central Corridor transit Operation and Maintenance ($48 million in 2002), which includes feeder and supplemental bus services, should be made more explicit.

20. Impacts to neighborhoods. Page 3-22, paragraph 3 and other pages. It is not clear from the document what the plan is in regard to pedestrian crossings of University Avenue. Will pedestrians be allowed to cross at all intersections as they do today or only at signalized intersections? There should not be a physical barrier down University Avenue at non-signalized intersections and pedestrians should not have to detour far out of their way to safely cross University Avenue. Maintaining or constructing a pedestrian refuge in the middle of University Avenue is important.

21. LRT and the State Capitol area. Page 3-23, paragraph 7 and other pages. TLC considers the addition of LRT as a positive impact on the views from the Capitol steps. Today school buses, tour buses, and other motor vehicles travel the road on the south side of the capitol. Many of those vehicles have noise and emission impacts that LRT would not have.

22. Roadway costs included. Page 3-48, paragraph 2 and other pages. The cost to rebuild University Avenue for motor vehicles should not be listed as a cost of the transit project. What is the age of the pavement and roadbed of University Avenue? Isn’t the reconstruction of the road needed with or without the construction of LRT or a BRT? The rebuild of the road should be paid for with state and local dollars available for road projects. Costs for sidewalks and bike and pedestrian amenities are necessary investments along University Avenue and could be paid for with transit dollars, but it would be preferable to also list these costs separately.

23. Impact related to environmental justice. Section 3.9.3. The document should acknowledge the likelihood of rising rents for residential and commercial properties and rising property values and taxes if LRT is built. What has been the experience along Hiawatha LRT and in other parts of the country? What possible strategies could be used to protect current residents against these rising costs and possible displacement?

24. Air quality analysis. Section 4.3.2. It should be noted that emissions for the Baseline and BRT option would be produced by motor vehicles including buses in the breathing zone where people are walking, bicycling, driving, and riding transit. Emissions from LRT come from power plants whose smoke stacks allow for dispersion and dilution and are less concentrated in the breathing zone.

25. Noise modeling. Section 4.4.3, Page 4-27 and 4-28. What has been the experience with wheel squeal on Hiawatha LRT? What might be the level and duration of wheel squeal at curves along the proposed Central Corridor LRT?

26. Energy impacts. Page 4-47 and other pages. What are the assumptions for this analysis? What is the energy use per passenger mile or per passenger trip? From this analysis it appears that from an energy perspective, it would be better not to build anything. Please list the fuel source(s) for each mode and the opportunities for reducing dependence on imported oil for each mode. It could be noted that the LRT system in Calgary is operated with wind power.

27. Economic impact analysis. Page 5-6, paragraph 5. The projected economic impact of the build alternatives should be adjusted based on experience with Hiawatha LRT. The rationale for the estimate should be given and the estimate should be broken down into construction impact, projected new development, and increased property tax base and revenues in Ramsey and Hennepin County. The estimate should also include the impact on transportation costs for households along the corridor. (See the report by the Brookings Institute entitled: The Affordability Index: A New Tool for Measuring the True Affordability of a Housing Choice, January 2006).

28. Mitigation measures for station areas. Page 5-37, paragraph 3. Motor vehicle traffic on Washington Avenue could be mitigated through the construction of LRT, through elimination of low cost parking on the edge of campus, and through implementation of travel demand management strategies at medium and large employers along the Central Corridor. If further mitigation of traffic congestion is needed, then through-lanes of traffic could be placed in a tunnel under Washington Avenue,

29. Use of the word “improvement.” Page 6-1, paragraph 3, and pages 6-3, 6-19, and throughout the DEIS. The word “improvement” is imprecise and should not be used in the document to describe any number of changes that can be made to a roadway to increase the flow of motor vehicle traffic. While some traffic engineers may refer to a lane addition on a roadway or a new right turn lane as an “improvement,” bicyclists and pedestrians may find that these lane additions reduce the safety, speed, or comfort of their trip.

30. Transit operational assumptions. 6-4, paragraph 4 and other pages. The document assumes that LRT and BRT will not have signal priority timing. Given that these modes of travel have the highest people moving capacity, they should have signal priority over motor vehicles carrying fewer passengers. The document should contain an analysis of the travel time savings and increase in transit ridership that would occur with signal priority.

31. Traffic level of service (LOS). Page 6-6, 6-7, other pages and also Traffic Operations Report in the Appendix. Are these LOS definitions standard industry definitions? More detail on each LOS should be provided. During preliminary engineering the LOS projections should be provided for am and pm peak hours and for periods of time (30 minutes, one hour, 90 minutes, etc.) Experience with LOS along Hiawatha LRT should be provided. Experience with the traffic signal timing along Hiawatha LRT should be described. Why do the traffic signals along Hiawatha LRT have no “memory” of the signal sequence after a train passes by? Couldn’t a more sophisticated system be used along the Central Corridor?

32. Transit ridership forecast. Page 6-29 and other pages. The ridership numbers should be updated to reflect experience with Hiawatha LRT.

33. Pedestrian access to stations. Page 6-30 and section 6.7. The document states that nearly 70% of transit riders will access the train by walking and nearly 30% will transfer from another bus. Are these numbers correct? How many LRT riders will access the station by bicycle? Given this high level of pedestrian access, the document should include pedestrian counts within the corridor and much more detailed information about the pedestrian environment and needed improvements along the corridor. The document should also identify pedestrian barriers to stations including roads with poor or missing sidewalks, lack of pedestrian crossings over I-94, high traffic levels, industrial land uses south of University Avenue, and other factors.

34. Parking. Section 6.5. This section should be updated to include current employment and parking occupancy rates. It is likely that parking occupancy rates in downtown St. Paul are lower today given the reduction in the number of jobs. The document should also be updated to include the parking utilization study that was completed by the Midway Transportation Management Organization (TMO).

35. Pedestrian and bicycle environment. Page 6-41, paragraph 4. Much of downtown Minneapolis is not pedestrian friendly as is stated in the text. Much of the downtown environment lacks trees and other vegetation, benches, pedestrian scale street lighting, and public restrooms. Also, driveways (often from parking ramps) cross the sidewalk adding to pedestrian travel times

36. Effects due to construction. Page 6-49. This section should be expanded to include a more detailed analysis of the possible impacts to businesses and residents during construction of LRT or BRT. Strategies to mitigate those effects should be provided.

37. Economic opportunity. Page 7-6. The information on vacant land should be updated. A map of vacant land should be provided. A map of locations with an oversupply of parking should be provided.

Respectfully submitted,

Barb Thoman
Program Director
Transit for Livable Communities
626 Selby Avenue
St. Paul, MN 55104