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Letter to James Kirschensteiner, PE

Bypass not a great idea

October 18, 1999 | By Kelly Thayer
Great Lakes Bulletin News Service

Mr. James A. Kirschensteiner, PE
Federal Highway Administration
315 West Allegan
Room 207
Lansing, Michigan 48933

Dear Mr. Kirschensteiner:

This letter is a follow-up letter to the August 10, 1999 comment letter on the Draft Environmental Impact Statement (DEIS) for the Boardman River Crossing Mobility Study in [Grand] Traverse County, Michigan. After the National Environmental Policy Act (NEPA)/404 Resource Agency meeting on September 24, 1999, the U.S. Environmental Protection Agency (U.S. EPA) was asked to convey in writing what was verbally articulated. As you may recall, Sherry Kamke of my staff expressed concerns with the characterization of the No Build Scenario and with the Alternatives Analysis. She also indicated that U.S. EPA would be interested in reviewing the response to comments from other parties. In particular, Ms. Kamke mentioned that she had reviewed comments from the Michigan Land Use Institute and she believed the comments were credible and deserving of a response. We have summarized the concerns that we articulated in the resource agency meeting in the attachment. We have limited these comments to those that would be necessary or beneficial to provide to us in order that U.S. EPA can provide concurrence on the second NEPA/Section 404 concurrence point “Alternatives Carried Forward.”

We anticipate that we can give our concurrence on Alternatives Brought Forward once these issues are resolved and a commitment is made to include corresponding information in the FEIS. If you have any questions or if you would like to discuss our review of the DEIS, please contact Sherry Kamke of my staff at (312) 353-5794.


    cc: Ms. Lori Noblet
    Michigan Department of Transportation
    425 West Ottawa Street
    Lansing, Michigan 48933


Detailed Comments on the Boardman River Crossing Mobility Study
Alternatives Brought Forward Concurrence Point

As you already know, the U.S. EPA provided concurrence on the purpose and need for the project in a letter dated May 4, 1999. At that time, the stated purpose for the project was to replace the transportation service that has been provided by the now structurally deficient and functionally obsolete Cass Road bridge. The existing bridge over the Boardman River is only one lane wide and is posted at 10 tons which prevents larger vehicles from crossing at the Cass Road bridge. The project should also improve east-west surface traffic patterns if a build alternative is implemented.

Characterization of the No Action Alternative -

More work is needed on discussing the projections of population and employment into the future. More should be said about why the Traverse City Area Transportation and Land Use Study (TC-TALUS) population projections are different from the state Demographer. Some discussion about where the growth is expected should be included in the documentation for this project.

If a substantial amount of development has already been directed to occur along the Hartman-Hammond corridor, the question that should be answered in the FEIS is “what is the extent/type of development along this corridor at the present time?” This information will be needed to compare to the extent/type of development that will occur with the implementation of a build alternative.

More documentation should be included on what restrictions on development are in place along the Hartman-Hammond corridor and elsewhere in the study area. In Garfield Township, there appears to be substantial restrictions on development due to zoning, conservation easements, and other wetland protection mechanisms. These restrictions should be documented as part of the No Build (existing) scenario.

Statements were made in the resource agency meeting that development in Garfield Township has not been slowed by the lack of a connection between Hartman and Hammond roads. This statement can be supported by projecting what land use would look like both with and without a crossing at Hartman/Hammond. More evaluation is needed to show the difference in land use patterns if there is no crossing at Hartman/Hammond (such as the scenario today) and what changes would occur in the study area (and the Hartman/Hammond corridor in particular) with a crossing at Hartman/Hammond.

Alternatives Analysis -

The DEIS did not show how Travel Demand Management Alternatives (TDMs) such as the Village Center and Urban Growth Boundary alternatives could be combined with other build alternatives to provide an overall alternative that meets the project’s purpose and need. An analysis should be made on the effectiveness of TDM


measures as a stand alone measure and in combination with other build alternatives. The documentation should show what effect TDMs and transit system have on traffic projections. Statements were made in the resource agency meeting that these combinations of alternatives is not something that can be evaluated because the TDM alternatives are outside of the Grand Traverse County Road Commission’s jurisdiction. NEPA regulations found at 40 CFR Section 1502.14 require that an EIS include all reasonable alternatives not within the jurisdiction of the lead agency.

More work needs to be done on documenting the types of 4(f) impacts associated with build alternatives. More documentation on what 4(f) impacts are show stoppers and which ones can be mitigated (some discussion of Cass Road bridge expansion as not plausible because it requires acquiring additional ROW) is necessary.

An evaluation of the change in land use associated with each build alternative should be conducted and documented.

In addition to these comments, we recommend that you address the following comments from the Michigan Land Use Institute:

Page 4 - Purpose and Need unreasonably narrow
The project in substance seeks to move traffic from the intersection of M-37 and US-31 to Hammond Road, tying into Three Mile Road or Four Mile Road, and back to U.S. 31 northeast of Traverse City.
[From EPA’s perspective it appears that the DEIS does indeed zero in on this much more specific purpose and need as opposed to the “improve east-west surface traffic patterns if a build alternative is implemented” that EPA provided concurrence on.]
Page 4 - Deficient Cass Road Bridge wrongly linked to regional east-west congestion
The deficient Cass Road Bridge and the projected congestion on some of the other east-west crossings in the Grand Traverse region, in fact, have no relation . . . The table shows that closing the Cass Road Bridge without any other new construction or rebuilding the Cass Road Bridge to its original two-lane structure would result in exactly the same projected volume of traffic on two of the river crossings being studied (Grandview Parkway/U.S. Route 31 and Eight Street).
Meanwhile, traffic volume on the Beitner Road crossing decreases slightly after the Cass Road Bridge is closed . . . We recommend that the FEIS address this issue.
Page 6 - Population/land use projections, first paragraph
In summary the comment says that the FEIS must evaluate the change in land use cause by various road alternatives (see EPA’s comment on this). We recommend that the FEIS do this.
Conflicting population projections, second and third paragraph
In summary the comment says that the State Demographer and TC-TALUS use different population projections. We recommend that more information be included in the Purpose and Need section to support why this was done, how often it is done and where the growth is expected to occur.


Page 7 - Inconsistent population analysis in DEIS
In summary the comment says that the geographic area that is said to reach a population of 124,000 is sometimes described as the TC-TALUS study area (a portion of Grand Traverse County and portion of Leelanau County) and in other places in the DEIS referred to as Grand Traverse county’s population. We recommend the FEIS correct any inconsistencies in this. If errors are found, an assessment should be made as to how this effects traffic forecasting. This information should be included in the FEIS.
Page 11 - Hartman-Hammond Connector would operate at LOS “D” (last paragraph)

In summary the comment says that a Hartman-Hammond Connector with Three Mile Road alternative would immediately operate at a LOS that would be found to be unacceptable. The expected result of this is that some other bridge in the crossing area will have to undergo an expansion in capacity. This raises the question of whether or not the Hartman-Hammond Connector alone is an adequate response to address the areas future traffic congestion problems. We recommend that additional documentation should address this issue. How does a Hartman-Hammond Road connection affect the need for other projects that the County Road Commission has committed to in its plans (such as widening Beitner, and widening Keystone and repairing Cass Road Bridge)? In other words, under what circumstances would these projects be done anyway? A discussion of how does this EIS relate to a Traverse City bypass would also be useful.
Pages 12 and 13 - Faulty traffic modeling
In summary the comment suggests that the very basis for the project, the traffic modeling, has flaws and that TC-TALUS has not evaluated the significance of the “flaws” or remedied any of the them. We strongly recommend that additional work be done here. Assumptions that are made should be supported as much as possible and weaknesses in the model should be acknowledged and evaluated for significance. This information needs to be included in the FEIS.

    Michigan Land Use Institute

    148 E. Front Street, Suite 301
    Traverse City, MI 49684-5725
    p (231) 941-6584 
    e comments@mlui.org