While Part 1 addressed the key elements of the draft plan, funding options and public transportation, Part 2 focuses on air quality as it relates to transportation, specific projects included in the draft plan, and public involvement.
Washington County is not regulated by the EPA or Utah Division of Air Quality (DAQ) because it's currently considered an attainment area under the Clean Air Act. However, already there are concerns by the National Parks Conservation Association about air quality and haze affecting Zion National Park and summer ozone is the primary cause of pollution in our area. Formed when volatile organic compounds (VOCs) and nitrogen oxides (NOx) mix with sunlight and heat, ozone can lead to shortness of breath, chest pains and lung inflammation. With the high numbers of retired seniors already here and still flocking to our area, what health challenges – and costs! – will they face if this is not resolved by proper transportation planning? With ozone being a mix of chemicals, many coming from tailpipes, increased numbers of cars, if emissions are not improved considerably, will exacerbate the problem.
With St. George being eliminated from AARP's list of "10 most affordable" retirement locations, perhaps the steady flow of seniors will abate, but our transportation planning should not rest on that assumption when it comes to air quality. As noted in Part 1 of my comments, public transportation which would help serve the transportation needs of our seniors, would also help their health by eliminating extra vehicles on our roads which cause ozone creation.
Health concerns are not the only problem we might face. If Washington County were to become a non-attainment area for pollutants, federally-funded improvements to transportation systems might be restricted. Resulting additional regulatory actions would add to the cost of doing business and planning/implementing projects. The draft report indicates that the Division of Air Quality and the Department of Environmental Quality have offered help to avoid potential problems. The Dixie Transportation Advisory Committee (DTAC) agreed to draft a protection plan and conduct a locally funded short term ozone study, but a review of many meeting minutes in 2011, 2012, 2013, 2014 and early 2015 shows no reference to such an activity. Minutes I've reviewed show that the focus continues to be on bike and walking trails and roads. Who is holding their feet to the fire to do as they agreed?
The transportation plan under review states that Dixie MPO's DTAC worked with SECOR, an air quality-engineering firm to monitor ozone levels. A study I was able to locate at http://www.airquality.utah.gov/Public-Interest/Current-Issues/Ozone/2012_Utah_Ozone_Study.pdf, dated January 2013, revealed 18 monitoring sites; one named Badger Springs was located at the foothills of Beaver Dam Wash Mountains. Ozone exceeded 75 parts per billion (ppb) at Badger Springs on 10 days, making it one of the highest ozone sites in Utah despite its remote location. Interestingly, but perhaps not surprising, the February 2013 DTAC meeting minutes made no note of this study or the results.
The draft report clearly states, "…the potential for air quality problems, especially for Ozone, is real for Utah's Dixie." If true, why is not more effort being put into this?
According to the DAQ's website monitoring information: "PM2.5 and PM10 monitoring at Hurricane (HC) started on January 1, 2014, in order to establish a 3-year baseline record of particulate levels in the St. George MSA." Other than this reference, the DAQ Annual Monitoring Plan for 2014 made no reference to Washington County of any significance. Although, I have to say that the website is not a user-friendly website where citizens can get information easily, and the information is cryptic, to say the least, with most of it being numbers that only a person in their field would be able to decipher. (http://www.airmonitoring.utah.gov/network/AnnualMonitoringPlan2014.pdf).
The current standard is 75 ppb (one which the SECOR study reveals was already being surpassed in 2013 at the Badger Spring/Beaver Dam Wash monitoring site), which is too weak to protect public health according to many in medical and religious communities across the nation, while political and business leaders argue that the new proposed standard in the range of 65-70 ppb would put undue demands on business and hurt economies and is too stringent.
But here's an interesting thing; on March 4, Robert V. Percival spoke at the University of Utah's College of Law. His presentation was titled "Why America's Century-Old Quest for Clean Air May Usher in a New Era of Global Environmental Cooperation." He's been the principal author of the leading U.S. environmental law casebook, Environmental Regulation: Law, Science & Policy for more than two decades, has worldwide experience in the area of environmental law having lectured in 26 countries on six continents and currently works in China. One of Mr. Percival's main points was that although industry, trade groups and politicians argue that stricter enforcement of air standards will harm business bottom lines, past experience shows that "net benefits" result and economic growth continues. Example, cries of doom from the regulated auto industry were not realized; regulation was not the death knell for them.
Adding to the problem is that regional ozone levels found at several monitoring sites throughout Southern Utah – from the Four Corners area, into the Grand Canyon, Zion National Park, Washington County and Southern Nevada – show levels close to the new standard. The draft study plan states, "Efforts are being made by the DAQ and others to document these ozone transport relationships. Postponing empirical results may compromise community health standards and be against the operating values agreed to by DMPO partners."
The draft transportation plan notes traffic congestion as a contributing factor to air quality problems due to increased pollutants as vehicles progress slowly and cue up at intersections. Optimum vehicle operating speed – when less pollutants are emitted – is around 30 mph. It seems then, given this information, that St. George Boulevard may be the only street on which pollutants are at a reasonable level since, on any other roads in the area, people are driving 40 and above – normally above! The plan offers 11 strategies for local government consideration and action. One references public transportation (Improve transit operations to provide more opportunities to leave vehicles at home) but it's near the bottom of the list. The idea of auto emission checks is no where on the list. Every day, I see black smoke pouring out of tailpipes owned by those who feel compelled to make a statement about their freedom to make poor choices that affect all of us. Police drive by either too busy to care or not having the laws to back up their action to stop such bad behavior.
A good deal of the 2015-2040 Draft Regional Transportation Plan deals with air quality issues. This is a good thing, but points to the fact that as St. George grows, if poor decisions are made, we will very likely be dealing with some very serious issues. Although the plan provides some focus on air quality, there seems to be quite a bit of contradiction between what the plan says and what DixieMPO really does.
There are many specific projects listed in the draft report, too many to deal with here, but I will address two. One project – Bluff Street – affects many people currently and the other – Northern Corridor (aka Washington Parkway) – is a future project fraught with many obstacles and for good reason. In fact, these two projects are connected by virtue of the fact that the Northern Corridor/WP is justified as a means of relieving congestion on other main roads such as Bluff. Will that really happen is the question.
First, I think it's important to provide some information directly from the March 2015 draft meeting minutes from DixieMPO's DTAC meeting describing comments received at the February 2015 transportation expo held by DixieMPO (emphasis added):
Survey respondents were asked to pick their top three projects. There were four projects of greatest interest to attendees that include: 1) I-15 Widening and Mall Drive Underpass; 2) Bluff Street and St. George Boulevard; 3) Sunset and Bluff Street; and 4) Expanded Bicycle and Pedestrian paths and lanes. One project, the Northern Corridor, was either fully supported or fully hated. The consultant is in the process of analyzing data collected from the survey. The survey indicates that more people are actually reading and studying information regarding specific projects. They are more informed about projects and are attending the Expo to discuss projects of interest. The highest concerns in terms of transportation systems include: 1) Safety, 2) Congestion Relief and 3) Air Quality. Dana Meier commented that there is likely a tie between congestion and air quality. There is not a statistical difference between respondents support of specific projects this year as compared to last year. A large number of survey participants support the Mall Drive underpass. Active transportation and transit questions responses were also reviewed. A majority of survey respondents indicated that they never ride SunTran (88.8%) and of those 42% responded that they never intend to ride the bus. It appears that more people would ride the bus if more stops were provided and if there were more frequent service that would provide faster trip times. A favorable percentage (81%) indicated that cities should do more to encourage the use of transit services. Respondents support a mix of high, medium and low density housing options for future growth.
DixieMPO, UDOT and other road planning entities do get credit for engaging the public in the planning process. But the result of this effort is what's in question. Let's take the Bluff Street project as an example.
Bluff Street is a problem, but are the plans for dealing with it adequate or realistic? Are they based on good, sound information and data?
A March 2012 letter to UDOT from local architect Richard Kohler (http://www.kohler-architecture.com/Home.html), also formerly involved in highway planning, challenged the idea that the stakeholder group meetings held to review this project for expanding the Bluff Street/Sunset Boulevard intersection were useful but, rather, asserted that they were woefully inadequate. In fact, there's even accusation that the information recorded from those meetings was "willfully distorted" in UDOT's effort to argue their position most effectively. Three workgroup meetings were held with UDOT's own presentations occupying a majority of the time.
Additionally, documents that should have been "public" – specifically a "traffic comparisons" tabulation table document – were not accurate and apparently contained engineering design and evaluation errors. According to Mr. Kohler's letter, this is an effort "to mislead the public by failing to disclose the ever-changing nature and uncertainly surrounding the moving target of the project's future traffic capacity projections."
Following 2012, Mr. Kohler and others, specifically a local businessman Gilbert Jennings who helped develop Sunset Corners, met with UDOT and others to further discuss the intersection options. Mr. Kohler, Mr. Jennings and business owners in the affected area have continued to work the issue with some good results.
But, here is my concern. If UDOT, MPO and others are encouraging public involvement but perhaps don't really even want input from someone with Mr. Kohler's knowledgeable background, what does this say about their "public comment" efforts? As noted by Mr. Kohler, UDOT and others seem to choose to ignore traffic "fall off" that has occurred due to road projects that have already occurred and which make their earlier traffic projections suspect at this point. However, because UDOT is already so entrenched in these projects, they've been reluctant to pull back and re-evaluate at this point.
Apparently, now, UDOT has put this project on hold for further discussion. Would this have happened had the people pushing for this change been Joe or Jane Blow rather than an influential businessman, Mr. Jennings, and Mr. Kohler, who is very persistent and knowledgeable?
Mr. Kohler's letter and backup information support the idea of a roundabout at the Bluff/Sunset intersection as the most effective way of handling projected traffic at lower cost rather than the "fly over" and "jug handle" concepts proposed by UDOT. I do not specifically subscribe to his plan but have seen the effective use of roundabouts elsewhere, and if traffic can be moved at less cost, I am in favor.
For those who would be interested in more details about Bluff Street project concerns, I suggest you listen to the discussion at http://southernutahlive.com/video/view/Talking-Point-ep-5-2015-01-13.
Although the transportation plan under review talks about "hourly delay cost" and presents a 25-year cost benefit analysis to justify the plan's projects, no discussion about the costs to businesses such as those in the Sunset Corners area affected by proposed intersection changes is presented. Is it a fair analysis to exclude these concerns? Also, I've seen many transportation plans offered over my 15 years in Washington County and Bluff Street has been a topic on most of those. Why was a business center such as Sunset Corners given the go ahead for development if traffic concerns would be a challenge for them and their business visibility in the future? Were the developers given adequate information pertaining to future transportation plans to help them make their decision to build?
If UDOT and the MPO plan for excessive traffic volumes on Bluff Street (65,000 cars), well over what good engineering practice would predict according to Mr. Kohler, it would likely have a very negative impact on Bluff Street's current businesses. The investment capital that would normally be used to update and improve individual businesses along Bluff Street would disappear because the projected 65,000 cars a day can only be carried on a freeway, and freeways do not allow ready access to businesses. There's the possibility that the freeway-size road could create blight in this area.
My point in presenting this information is to question the "citizen" process. In this particular instance, as in other citizen processes I've witnessed locally, the effort seems to be to "convince" citizens of the preferred plan by the entity conducting the meeting rather than actually wanting to engage the public in meaningful discourse and sharing of ideas for planning purposes. By this I do not mean that citizens should disengage from the process. Far from it. Rather it means that we need even more citizen involvement and persistence to counter the "institutional" forces at work.
The Bluff Street & Sunset Grade Separated Intersection project appears on the "Regional Transportation Plan – Projects & Phasing -2015-2040 Phase One (2015-2024)" list at a cost of $20 million, and the Bluff Street & St. George Blvd Intersection Improvements & SR-18 Widening project appears on the same list at $38.3 million.
According to the draft plan's map showing "Traffic Congestion 2040 No-Build" scenario, Bluff Street's traffic congestion gets a "between .9-1.2" rating from I-15 to St. George Boulevard and an "above 1.2" rating from St. George Boulevard to Sunset Boulevard. Traffic congestion ratings range from "below .6" (best) to "above 1.2" (worst) on the plan's range scale. So, Bluff Street's ratings are at the high end in the No-Build scenario, but even after planned improvements and much money spent, Bluff Street is still not at the lowest end.
In the plan's "Traffic Congestion 2040 Build" scenario, Bluff Street's traffic congestion is "between .9-1.2" and "between .6-.9" for the areas between I-15 and Sunset Blvd. Nowhere does Bluff Street get the best rating of "below .6" so even with all the money spent on road improvements, there will be delays, and after 2040, with population growth, will future citizens be back in the same predicament we are today? This brings me to the Northern Corridor (aka Washington Parkway) project.
NORTHERN CORRIDOR (aka Washington Parkway)
This is a contentious project that would go through the Red Cliffs Desert Reserve (aka tortoise reserve). The project appears on the Dixie MPO "Project & Phasing 2015-2040 Phase One (2015-2024)" costing $5 million just for environmental work. It then appears on the Phase Two (2025-2034) list costing $47 million.
The Red Cliffs Desert Reserve was established in the mid 1990s to preserve the prime habitat area and allow development in areas outside the reserve. At that time the Habitat Conservation Plan (HCP) was created and the twenty-year plan is up for renewal in 2016. In 2009, an omnibus bill was passed by Congress that established the Red Cliffs NCA and gave direction for management, including provisions for a road. For the last several years the BLM has been reviewing and rewriting their Resource Management Plan (RMP) which is supposed to include several options for a road. Of course, the county really only desires one route, and that's the heart of the problem.
The Feb. 5, 2014, Five County Association of Governments meeting minutes provide some interesting details including information from a handout at the meeting from Utah Sen. Orrin Hatch dealing with the road. From the meeting minutes, the second paragraph in Hatch's letter reads:
"Although the Law stated that there be at least one alternative and the current iteration of the draft does include one alternative, the law did not intend that the BLM include one alternative and then discard the idea of building the Northern Transportation Route (NTR). The law clearly intended that the NTR be built and should, therefore, be included in all of the alternatives, or, at least, the preferred alternative."
While Hatch may have his take on what the law "intended" here is what is clearly stated in Section 1974 of the Law. The purpose of the NCA is "to conserve, protect, and enhance for the benefit and enjoyment of present and future generations the ecological, scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources of the National Conservation Area; and to protect each species that is located in the NCA and listed as a threatened or endangered species on the list of threatened species or the list of endangered species published under section 4(c)(1) of the ESP of 1973." It's difficult to understand how a road through the heart of the reserve could live up to this although UDOT and Dixie MPO had a study conducted several years ago to help bolster their position. It seems obvious that a road through the reserve would result in more noise, more people, more garbage and – worst of all – more fire potential to decimate the tortoise population. So far the desert tortoise has not been listed as "endangered" and is still listed as "threatened." It's possible that the tortoise could be listed at "endangered" if someone or some group chose to do so, which might put additional restrictions on the area.
Section 1977 of the 2009 Omnibus Bill references the travel plan (part of the RMP) and the need to have the decision in "consultation with appropriate Federal agencies, State, tribal, and local government entities, and the public." According to the February 2014 meeting minutes, Dixie MPO and Washington County are very concerned about not being properly included in the BLM's Resource Management Plan process. I hope that consultation with local government entities and the public will be more than just conferring with those in positions of power in our area since they all seem to be more concerned with moving traffic than with honoring the agreement (HCP) that created the area to protect the tortoises and other threatened and/or endangered species. In fact, it's clearly stated in the February 2014 meeting minutes, "The County is working diligently to preserve the Northern Transportation Route to make sure that the road can be constructed sometime in the future."
A Spectrum & Daily News poll conducted in 2009 asking citizens if a road should be built through the Reserve resulted in 30.9 percent voting yes, 64.4 percent voting no and 4.7% didn't care. Although 447 respondents may not be a huge group, a 64.4 percent vote against the road in what's viewed as a conservative paper in our area is meaningful. Most Spectrum & Daily News polls don't seem to get more than a couple hundred respondents.
As a citizen of Washington county and a believer that once an agreement is made it should be held to, I find it dishonorable of the county commissioners and other politicians to be pushing for a road that may essentially negate the Habitat Conservation Plan. Comments made by Washington County Commissioner Alan Gardner at the November 2009 HCAC meeting (http://www.redcliffsdesertreserve.com/wp-content/uploads/2010/01/Minutes-HCAC-11-24-09-approved.pdf)
I assert that St. George Mayor McArthur and Washington City's mayor insisted on the preferred road route being included in the Omnibus lands bill or they would oppose the bill. This was fourteen years after they apparently agreed to the creation of the HCP. The USFWS, along with BLM, should stick to their guns and hold the county to the HCP purpose: protecting the tortoises and the "heart of the habitat" that would be affected by an improperly placed Northern Corridor (aka Washington Parkway).
It's clear from the current Dixie MPO transportation plan's population growth projections, employment location projections and previous studies that the proposed contentious Northern Corridor will not provide the congestion relief that some hope it would. It will, however, cost taxpayers and result in costly lawsuits given the details surrounding this project.
A 2011 report, Washington Parkway Cost/Benefit Study, conducted by Horrocks Engineering for DixieMPO indicated that of the six options studied, "Option #3 provided the highest benefit relative to its cost with respect to traffic congestion relief. None of the options reduced traffic on Bluff St., St. George Blvd. and Red Cliffs Dr. to the point that congestion on these corridors was eliminated. However, Option #3 did show the largest overall trip reductions that would make them more manageable."
Option 3 is the preferred route that appears on the 2015-2040 draft transportation plan under review. As noted at the start of this section on the Northern Corridor, this project appears on the draft plan's Phase Two (2025-2034) list costing $47 million. However, the 2011 Washington Parkway Cost/Benefit Study shows the preferred Option 3 costing $56 million. So, apparently over these four years, the cost of the project has gone done? I find that a little difficult to believe.
The Horrocks study utilized a population projection of approximately 550,000 by 2040. The 5 County Association of Governments' 2012 projection for Washington County's 2040 population is 371,743 – 178,257 less than the study's focus. How reliable are the study's traffic projections at this point? The Horrocks study and the draft transportation plan currently under review show the majority of the future growth – however much that might be – occurring south of I-15 not in the northern part of our county.
Plan charts are provided to support the fact that population and employment numbers are driving transportation projects, but when reviewed, the charts show that by far the majority of population growth and employment areas will be in the St. George, Washington and Hurricane areas of Washington County, south of I-15, which is nothing new given the growth already witnessed. The employment chart shows even more dramatically how future employment growth will be concentrated in these areas. There is some population growth in the Ivins City, Santa Clara and Ledges area projected, but much less than the high-growth areas identified, which makes spending our money on the contentious and questionable Northern Corridor even more suspect.
As noted in the earlier section about the Bluff Street improvements, the 2040 No-Build versus the 2040 Build maps show no significant improvement with or without the Northern Corridor. With Mr. Kohler's assertions that traffic "fall off" has already occurred due to earlier projects, what additional fall off will result from all the other projects on the Dixie MPO list and eliminate the need for this road? I guess the main question I have is: Who are we building this road for and why are all taxpayers being asked to assume this cost?"
From the draft plan: "Moving forward, the MPO is committed to include public involvement initiatives in its decision-making efforts, to communicate public concerns to MPO voting members, and to educate the public on MPO deliberation, options, strategies, and plans of regional significance."
I sincerely hope this is true. Even with the caveats I've offered in my comments, I believe that public involvement is so very important. Many important issues in our county, state, nation and world have been influence by public involvement. One of my most important messages pertains to public transportation. This needs attention. We have created a nation, and particularly our part of the nation, where public transportation has taken a back seat to individuals and cars. We cannot continue to have a viable and effective transportation system and clean air by going down this path.
I hope that my comments provided in Part 1 and Part 2 concerning the 2015-2040 draft transportation plan currently open for public comments will prove useful for anyone wishing to comment themselves.
One thing kept recurring to me during my review of the draft plan: The need for increased attention to public transportation to help alleviate future congestion, maintain air quality and honor the promises made to protect our special areas while serving the needs of the most vulnerable and needy our community. In closing, here's something to think about:
Back in the early part of the 20th century, GM managed to eradicate streetcars from the landscape in their never-ending promotion of the motor car. Perhaps now is the time to get back on board with public transportation and give it the money needed to make it work.