I -405 Corrridor Record of Decision October 2002

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I-405
Corridor
Program
Record of Decision
October 2002
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Record of Decision
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I-405 Corridor Program
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Record of Decision
Interstate 405 Corridor Program
Process
Pursuant to 23 CFR Section 771.111(g),
corridor-level
2
Draft and Final Environmental
Impact Statements (EIS) for major
transportation actions were prepared for
improvements to the Interstate 405 corridor.
The corridor generally covers an area extending
between the interchanges with Interstate 5 at
Tukwila and Lynnwood in King and Snohomish
counties, Washington. This corridor-level EIS
focuses on broad corridor-wide issues related
to mode choice, general location of
improvements, and how combinations of
improvements may function together as a system
to solve corridor wide transportation problems.
This EIS has evaluated the cumulative impacts,
growth inducing impacts, and effects on the
environment of subsequent specific I-405
corridor projects to the greatest extent
feasible. Through the preparation of the
corridor-level EIS and this Record of Decision
(ROD), it is the intent of the FHWA and FTA
that the process time for environmental review
of subsequent projects be substantially reduced
to the extent that program impacts have been
reviewed and appropriate mitigation measures
are set forth in the EIS and this ROD.
2
The references to “corridor-level” and “project-specific level” in
this ROD are used with respect to “tiered” environmental reviews as
noted in FHWA’s and FTA’s joint environmental regulations found at 23
CFR section 771.111 (g) and CEQ regulations found at 40 CFR section
1502.20. In addition, the use of corridor-level, project-specific level
or tiered environmental reviews is not meant to imply that subsequent or
project-specific second tier environmental reviews require any
particular level of review. Project-specific level or second tier
environmental reviews can take the form of re-evaluations, categorical
exclusions, environmental assessments or environmental impact statements
and will depend on the project-specific improvements being proposed and
their potential environmental impacts.
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Subsequent environmental reviews and
documentation under the NEPA and the State
Environmental Policy Act (SEPA) will occur
before decisions are made on specific design
details or project footprints when specific
project proposals are advanced. It is
envisioned that this project-specific level
environmental review will be used where the
specific and detailed project is included in
the corridor-level proposal evaluated in the
EIS and described in this ROD. The focused
project-specific environmental impact review
shall incorporate, by reference, the corridor-
level EIS and shall analyze only the subsequent
project's additional effects on the environment
not considered in the corridor-level EIS and
any substantial new or additional project
changes, information, effects, mitigation
measures, or alternatives that were not
identified and analyzed by the corridor-level
EIS. It is anticipated that the project-
specific level environmental review need not
examine the corridor-level alternatives;
impacts and mitigation measures evaluated in
the corridor-level EIS, and the decisions made
in this ROD. Any finding or decision document
made based on the project-specific level
environmental review shall incorporate this ROD
and the findings, decisions, and mitigation
measures made herein.
Program Purpose and Need
The need identified for the I-405 Corridor
Program is to improve personal and freight
mobility and reduce foreseeable traffic
congestion in the corridor in a manner that is
safe, reliable, and cost-effective. The
purpose of the proposed action is to provide an
efficient, integrated, and multimodal system of
transportation solutions within the I-405
corridor that meet the program need in a manner
that:
• Provides for maintenance or enhancement of
livability for communities within the
corridor;
• Provides for maintenance or improvement of
air quality, protection or enhancement of
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fish-bearing streams, and regional
environmental values such as continued
integrity of the natural environment;
• Supports a vigorous state and regional
economy by responding to existing and future
travel needs; and
• Accommodates planned regional growth.
Environmental Review and Issuance of the Final
Environmental Impact Statement
The proposed improvements are described in the
FEIS, FHWA-WA-EIS-01-01-F, approved on June 10,
2002 and issued on June 28, 2002. The Notice of
Availability appeared in the Federal Register on
June 28, 2002. The FEIS and all findings therein
are incorporated in this ROD by reference.
The I-405 Corridor program implemented the
“Transportation Decision Making Process
Improvement” (typically referred to as
“Reinventing NEPA”). Through the Reinventing NEPA
process, the I-405 Corridor Program obtained early
and regular participation from 31 affected
regulatory agencies and jurisdictions throughout
the corridor. Participation of the agencies and
jurisdictions was assured by a series of
coordination meetings and consensus points at key
milestones throughout the environmental analysis,
documentation, and review process. For example,
one of the many key steps in the Reinventing NEPA
process included receiving concurrence on the
Preferred Alternative, which is now the Selected
Alternative, from agencies with jurisdiction.
The I-405 Corridor Program EIS examined the broad
corridor-wide issues related to mode choice,
general location of improvements, and how
combinations of improvements may function together
as a system to solve corridor wide transportation
problems, rather than focusing on specific design
details or project footprints.
The project sponsors will initiate subsequent NEPA
and SEPA environmental analysis, documentation,
and review for improvements contained within the
Selected Alternative.
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Selected Alternative
The Selected Alternative as described in this ROD
was designated as Preferred Alternative in the
FEIS (Section 2.2.6) and becomes the Selected
Alternative in this ROD. All references in this
ROD to the Selected Alternative shall hereafter
refer to the FEIS Preferred Alternative.
The Selected Alternative is a modification of
Alternative 3 - Mixed Mode Emphasis, identified in
the DEIS and FEIS - and is described below with
all of the alternatives considered in the FEIS.
It was identified after the issuance of the Draft
EIS by co-lead agencies upon recommendation by the
I-405 Corridor Program Citizen, Steering, and
Executive committees because it best meets the
identified purpose and need for the I-405 Corridor
Program. Through a consensus building exercise as
part of the Reinventing NEPA process, these
committees were asked to identify which
alternative, or elements of the alternatives, was
preferred. Committee consensus was achieved over
the selection of elements comprising Alternative 3
with the exception that transit expansion would be
limited to 75 percent based on demand and with the
inclusion of expanded capacity on north-south
arterials (with jurisdictional approval) and
accommodation of future planning for expanded
managed lanes in the corridor.
The Selected Alternative does not restrict
meaningful consideration of other reasonably
foreseeable improvements with independent utility
and logical termini. The proposed I-405 freeway
design includes a buffer separating the general
purpose lanes and the high-occupancy vehicle (HOV)
lane to provide safer and more reliable HOV and
transit operations within the corridor. This
design allows for future consideration of expanded
managed lanes operations on I-405, which could
include managing up to two lanes in each
direction. Expansion of managed lane operations
beyond the single HOV lane proposed in the FEIS
would be subject to further environmental analysis
beyond the scope of the I-405 Corridor Program
FEIS.
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Alternatives Considered in the Final EIS
The alternatives evaluated in the FEIS include a
wide range of improvements, each of which serves
one or more of the following corridor solutions:
• Implement an enhanced transportation demand
management (TDM) program (see the FEIS
Section 5, Glossary, for definition of TDM
and other terms used within this ROD);
• Expand the capacity of the existing local bus
transit system;
• Implement new bus rapid transit (BRT) within
the corridor;
• Implement new fixed-guideway high-capacity
transit within the corridor;
• Expand the capacity of the existing I-405
freeway; and
• Expand the capacity and improve the
continuity of the adjacent arterial network.
These improvements are intended to reduce traffic
congestion and improve mobility, reliability, and
safety in the corridor as compared to the No
Action alternative. The major elements of the
alternatives are described in detail in Chapter 2,
as well as in Appendices A and B of the FEIS.
The FEIS examined the following alternatives:
• No Action Alternative
• Alternative 1 - High-Capacity Transit/TDM
Emphasis
• Alternative 2 - Mixed Mode with High-Capacity
Transit/Transit Emphasis
• Alternative 3 - Mixed Mode Emphasis
• Alternative 4 - General Capacity Emphasis
• Preferred Alternative (the Selected
Alternative)
These alternatives were designed to provide
decision makers with the widest range of potential
reasonable solutions. The improvements were
packaged into alternatives in varying levels of
intensity (such as the number of new freeway lanes
or increases in transit service) and choice of
technology (such as the type of high capacity
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transit). Each action alternative is a
combination of multi-modal transportation
improvements and other mobility solutions packaged
to work together as a system, and demonstrates a
unique emphasis in response to the purpose and
need for the I-405 Corridor Program. Solutions
range from a focus on minimizing new impervious
surface from general purpose transportation
improvements by relying on fixed-guideway, high
capacity transit in existing railroad right-of-way
(Alternative 1) to a focus on relieving traffic
congestion by increasing general purpose and HOV
roadway capacity (Alternative 4).
The following discussion describes each
alternative, including (1) the alternative’s
major objective or focus, (2) its package of
improvements and unique features, and (3) the
reasons it was or was not chosen as the
Selected Alternative. A more detailed
discussion of the tradeoffs between the
alternatives is contained in the Summary of the
FEIS, as well as Chapter 2 and Appendices A and
B of the FEIS.
Description of the Alternatives and Basis for
Selection of the Preferred Alternative
No Action Alternative
Under the No Action Alternative, no new major
construction activities described in the program
proposed action would occur. The No Action
Alternative includes the committed and funded
highway and transit capital improvement projects
in the study area belonging to the cities,
counties, Sound Transit, and WSDOT (see Figure
2.2-1, Appendix A, and Appendix B in the FEIS).
These projects are already in the pipeline for
implementation within the next six years, and are
assumed to occur regardless of the outcome of the
I-405 Corridor Program.
Limited expansion of state highways is expected,
while several arterial improvements will be
implemented by local agencies. In addition,
short-term minor construction necessary for
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continued operation of the existing roadway
facility would be accomplished, and minor safety
improvements would be constructed as required.
Phase I of Sound Transit's Sound Move plan is
included, and a 20 percent increase in transit
service hours is assumed by 2020 above the
increases contemplated in the current King County,
Sound Transit, and Community Transit six-year
plans. All improvements contained in the No
Action Alternative are also included in the action
alternatives.
Environmentally Preferred Alternative
The No Action Alternative is determined to be the
environmentally preferred alternative because it
would result in the least overall adverse impacts
on the natural and built environment and would not
require the displacement of any additional
residents or businesses. This determination was
made by comparing each alternative in terms of the
relative number of adverse impacts in each of the
23 areas of the affected environment. The No
Action alternative had the lowest number of
adverse impacts in 20 of 23 areas of the affected
environment. Areas of the affected environment
for which the No Action is not the most beneficial
alternative include air quality, transportation,
and effects on land use and pressure for growth
outside the urban growth area.
After careful study and following consideration
of public and agency comments received on the
Draft EIS (contained in Volume 2 of the FEIS)
and the Final EIS, the FHWA and non-Federal co-
lead agencies chose not to select the No Action
Alternative for reasons listed below.
The No Action Alternative was not selected
because:
• It did not meet the program purpose and need
because of its inability to provide long-term
improvement in general purpose mobility,
freight mobility, or reduction in foreseeable
traffic congestion.
• It would accommodate the lowest peak-period
person travel demand in 2020 of any
alternative.
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• It would result in substantial degradation of
travel times and reliability of travel times
for general traffic.
• It would provide no meaningful improvement in
overall safety on I-405 or other study area
facilities.
• It failed to adequately address social and
economic effects consistent with the program
purpose.
• It does not provide the necessary
transportation improvements to accommodate
planned growth, support implementation of
adopted regional and local land use plans, or
assist local jurisdictions in meeting
transportation concurrency requirements under
the Growth Management Act. (Transportation
concurrency requirements are described in
Chapters 3.12 and 3.13 of the FEIS.)
Alternative 1 - High-Capacity Transit/TDM Emphasis
This alternative attempts to minimize addition of
new impervious surface from general purpose
transportation improvements and to encourage
transit use within the study area. To do this,
Alternative 1 emphasizes reliance on a new
physically separated, fixed-guideway high-capacity
transit system using portions of the existing
Burlington Northern-Santa Fe (BNSF) Railroad
right-of-way to serve major activity centers
within the I-405 corridor (see Figure 2.2-2,
Appendix A, and Appendix B in the FEIS).
Emphasis also would be placed on non-construction
treatments such as transit signal priority and a
combination of aggressive TDM strategies. The TDM
strategies would be similar to those in the other
action alternatives; however, in Alternative 1,
regional pricing strategies similar to those
considered in current Puget Sound Regional Council
(PSRC) studies also are proposed. Local bus
transit service levels would be doubled compared
to the current King County, Sound Transit, and
Community Transit 6-year plans.
As in the other action alternatives, Alternative 1
would include arterial HOV priority for transit,
additional park-and-ride capacity, additional
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transit center capacity, a new bus maintenance and
operations facility, truck freight traffic
enhancements, intelligent transportation system
(ITS) improvements, and pedestrian and bicycle
improvements. There would be basic improvements
to I-405 with no additional general purpose lanes.
Arterial improvements would include limited
arterial HOV/transit treatments to facilitate
access to I-405 and the high capacity transit
system.
Alternative 1 was not selected because:
• It did not meet the program purpose and need
because of its inability to provide
meaningful long-term improvement in general
purpose mobility, freight mobility, or
reduction in foreseeable traffic congestion.
• It would accommodate a minimal amount of the
increased peak-period person travel demand in
2020.
• It would have a minimal effect on reliability
of travel time for general traffic.
• It would not reduce travel times for either
general purpose traffic or 3+ HOVs.
• It would provide no meaningful improvement in
overall safety on I-405 or other study area
facilities.
• It failed to adequately address economic
effects consistent with the program purpose
and need.
• It would contribute only marginally to the
level of transportation improvements needed
to accommodate planned growth, support
implementation of adopted regional and local
land use plans, or assist local jurisdictions
in meeting transportation concurrency
requirements under the Growth Management Act.
• It would provide little benefit beyond that
resulting from the No Action Alternative, yet
it is estimated to cost nearly eight times as
much. Thus, Alternative 1 is not considered
a cost-effective solution.
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Alternative 2 - Mixed Mode with High-Capacity
Transit/Transit Emphasis
This alternative attempts to improve mobility
options in the study area relative to Alternative
1 by providing a substantial commitment to transit
combined with the minimum increase in roadway
capacity for HOV and general purpose traffic. To
emphasize transit, Alternative 2 would implement
the same physically separated, fixed-guideway high
capacity transit system as proposed in Alternative
1. To improve general traffic mobility, this
alternative would widen I-405 by one lane in each
direction, add collector-distributor lanes along
I-405 where warranted, expand the I-405/SR 167
interchange to include ramps for all major
movements, and widen SR 167 by one lane in each
direction south of I-405 to SR 516.
Alternative 2 also would include HOV direct access
ramps along I-405, HOV freeway-to-freeway ramps
along I-405, capacity improvements on arterials
and freeways connecting to I-405, and completion
of arterial improvements planned by local
jurisdictions (see Figure 2.2-3, Appendix A, and
Appendix B in the FEIS).
As in other action alternatives, Alternative 2
would include arterial HOV priority for transit,
additional park-and-ride capacity, additional
transit center capacity, a new bus maintenance and
operations facility, truck freight traffic
enhancements, ITS improvements, pedestrian and
bicycle improvements, and a set of aggressive TDM
strategies. Local bus transit service levels
would be doubled above the increases contemplated
in the current King County, Sound Transit, and
Community Transit six-year plans.
Alternative 2 was not selected because:
• It would result in the highest potential
impacts on wetlands, riparian areas, and
upland wildlife habitat of any alternative.
• It would result in the highest potential for
displacement of residential units of any
alternative.
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• It would provide substantially less
improvement than the Selected Alternative in
transportation performance based on the
adopted evaluation criteria and
transportation performance measures when
examined across all travel modes, yet it is
estimated to cost nearly 14 percent more than
the Selected Alternative. (The evaluation
criteria and transportation performance
measures are described in the FEIS Chapter 2
and Chapter 3.12, respectively.)
• It is less likely than the Selected
Alternative to accommodate planned growth
goals, support implementation of adopted
regional and local land uses plans, or assist
local jurisdictions in meeting transportation
concurrency requirements under the Growth
Management Act.
Alternative 3 – Mixed Mode Emphasis
This alternative attempts to substantially improve
mobility options for all travel modes and to
provide a high capacity transit system throughout
the study area at a lower cost than the physically
separated, fixed-guideway system proposed in
Alternatives 1 and 2. To do this, Alternative 3
would widen I-405 by two lanes in each direction
in most sections. A bus rapid transit (BRT)
system would be implemented throughout the I-405
corridor with appropriate east-west connections to
Redmond and Issaquah. Unlike the fixed-guideway
high capacity transit proposed in Alternatives 1
and 2, this system would consist of express buses
operating in improved access HOV lanes on I-405,
I-90, and SR 520. The BRT system would provide
superior transit service by use of HOV priority
lanes, frequent schedules, and easily accessible
stations.
Like Alternative 2, Alternative 3 also would
include collector-distributor lanes along I-405
where warranted, expansion of the I-405/SR 167
interchange to include ramps for all major
movements, widening of SR 167 by one lane in each
direction south of I-405 to SR 516, HOV direct
access ramps along I-405, addition of HOV freeway-
to-freeway ramps along I-405, capacity
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improvements on arterials and freeways connecting
to I-405, and completion of arterial improvements
planned by local jurisdictions (see Figure 2.2-4,
Appendix A, and Appendix B in the FEIS). In
addition, selected arterial missing segments would
be completed by local jurisdictions.
As in the other action alternatives, Alternative 3
would include arterial HOV priority for transit,
additional park-and-ride capacity, additional
transit center capacity, a new bus maintenance and
operations facility, truck freight traffic
enhancements, ITS improvements, pedestrian and
bicycle improvements, and a set of aggressive TDM
strategies. Local bus transit service levels
would be doubled above the increases contemplated
in the current King County, Sound Transit, and
Community Transit six-year plans.
Alternative 3 was not selected because:
• It has a similar level of overall
environmental effects as the Selected
Alternative, yet it provides a lower level
of transportation performance based on the
adopted criteria and performance measures.
(The evaluation criteria and
transportation performance measures are
described in the FEIS Chapter 2 and
Chapter 3.12, respectively.)
• It is less likely than the Selected
Alternative to accommodate planned growth,
support implementation of adopted regional
and local land use plans, and assist local
jurisdictions in meeting transportation
concurrency requirements under the Growth
Management Act
• It does not relieve congestion in critical
areas as well as the Selected Alternative.
Alternative 4 - General Capacity Emphasis
This alternative places the greatest emphasis on
increasing general purpose and HOV roadway
capacity, with substantially less reliance on new
transit facilities or added local bus transit
service than any of the other action alternatives.
To do this, Alternative 4 would maximize freeway
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capacity by providing three additional lanes in
each direction within the I-405 corridor. These
lanes would include one additional general purpose
lane in each direction on I-405 in most segments,
along with a four-lane I-405 express roadway (see
Figure 2.2-5, Appendix A, and Appendix B in the
FEIS).
Like Alternatives 2 and 3, Alternative 4 would
include collector-distributor lanes along I-405
where warranted, expansion of the I-405/SR 167
interchange to include ramps for all major
movements, widening of SR 167 by one lane in each
direction south of I-405 to SR 516, HOV direct
access ramps along I-405, addition of HOV freeway-
to-freeway ramps along I-405, capacity
improvements on arterials and freeways connecting
to I-405, and completion of arterial improvements
planned by local jurisdictions. In addition,
selected arterial missing segments would be
completed and capacity on major north-south
arterials would be expanded with jurisdictional
approval.
As in the other action alternatives, Alternative 4
would include a new bus maintenance and operations
facility, ITS improvements, pedestrian and bicycle
improvements, and a set of aggressive TDM
strategies. This alternative does not include
arterial HOV priority for transit, additional
park-and-ride capacity, or additional transit
center capacity. Local bus transit service levels
would be expanded by 50 percent above the
increases contemplated in the current King County,
Sound Transit, and Community Transit six-year
lans.
p
Alternative 4 was not selected because:
• It would result in the greatest increase in
impervious surface of any alternative, which
would have adverse effects on surface water,
groundwater, fish, and other aquatic
resources.
• The improvement in overall transportation
performance based on the adopted evaluation
criteria and transportation performance
measures is outweighed by the approximately
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50 percent higher cost of Alternative 4
compared to the Selected Alternative.
• It could contribute to increased pressure for
growth and development at the fringe or
outside of the Urban Growth Area in areas
that are not currently intended for higher
densities under adopted land use plans or the
Growth Management Act.
The Selected Alternative
The Selected Alternative is a multi-modal
solution to the transportation needs in the I-
405 corridor. The Selected Alternative focuses
on substantial improvement of mobility options
for all travel modes and provision of an
effective high capacity transit system
throughout the study area at a lower cost than
the physically separated, fixed-guideway system
proposed in Alternatives 1 and 2.
The Selected Alternative would widen I-405 by
up to two lanes in each direction. The freeway
design includes a buffer, envisioned as a 4-
foot painted barrier in most sections,
separating the general purpose lanes and the
HOV lane. Access to and from the HOV lane
would be limited to the HOV direct access
ramps, freeway-to-freeway connections, and
clearly identifiable locations along the
mainline freeway where the buffer would be open
for merging traffic. The buffer design allows
for future consideration of expanded managed
lane operations along I-405.
The Selected Alternative would implement the
same BRT system as proposed in Alternative 3.
The BRT system would operate with stops every 2
to 3 miles along I-405 and would use the HOV
priority lanes, new HOV direct access ramps,
and new in-line transit stations to maximize
speed and reliability. BRT service also would
operate along connecting facilities such as SR
522, SR 520, I-90, and SR 167 to serve major
activity centers within the I-405 corridor.
This would include connections east to Redmond
and Issaquah and west across Lake Washington to
Seattle. A total of 11 BRT stations are
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proposed (see Figure 2.2-6, Appendix A, and
Appendix B in the FEIS).
The Selected Alternative would include collector-
distributor lanes, auxiliary lanes, and truck
climbing lanes along I-405 where warranted;
expansion of the I-405/SR 167 interchange to
include ramps for all major movements; widening of
SR 167 by up to two lanes in each direction south
from I-405 to South 180
th
Street; HOV direct
access ramps along I-405 at nine locations;
addition of HOV freeway-to-freeway ramps along I-
405; capacity improvements on arterials and
freeways connecting to I-405; completion of
arterial missing segments; and the planned
arterial improvements of local jurisdictions. In
addition, capacity on major north-south arterials
would be expanded with jurisdictional approval.
The Selected Alternative would include arterial
HOV priority for transit, additional park-and-
ride capacity (approximately 5,000 stalls),
additional transit center capacity, a new bus
maintenance and operations facility, truck
freight traffic improvements, ITS improvements,
pedestrian and bicycle improvements, and a set
of aggressive TDM strategies. Overall transit
service within the study area would be
increased, based on demand, by up to 75 percent
above the increases contemplated in the current
King County, Sound Transit, and Community
Transit six-year plans.
The Selected Alternative best meets the purpose
and need of the I-405 Corridor Program. It is
the most desirable solution in terms of balancing
transportation performance, functional efficiency,
and environmental, social, and economic impacts
and:
• It has the lowest impact on wetlands of any
action alternative.
• Environmental impacts of the Selected
Alternative within the corridor will be
avoided or effectively mitigated.
Opportunities to enhance existing
environmental conditions and key
environmental features will be achieved
through sound design practices and the
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proposed “basin approach” to considering
key environmental features. (See Appendix
J of the FEIS for a description of the
“basin approach”.)
• The Selected Alternative provides the
highest level of transportation
performance of any alternative based on
the adopted criteria and performance
measures when examined across all travel
modes. (The evaluation criteria and
transportation performance measures are
described in the FEIS Chapter 2 and
Chapter 3.12, respectively.)
• The Selected Alternative would provide
improved reliability of travel times and
greater safety for general purpose, HOV,
and transit than Alternative 3.
• The mix of modal investments in the
Selected Alternative provides a balanced
system of roadway, transit, and TDM
solutions that are expected to provide the
most reasonable long-term strategy to meet
the needs for personal and freight
mobility and congestion reduction in the
corridor.
• The four-foot buffer on I-405 contained in
the Selected Alternative would accommodate
expanded managed lane operations in the
future or other long-range opportunities
for enhancement of the high capacity
transit system.
• The Selected Alternative would provide the
greatest opportunity of any alternative to
accommodate continuous and orderly
development through congestion reduction,
air quality improvement, improved travel
time reliability, and improved urban
accessibility.
• The Selected Alternative would contribute
the most desirable mix of transportation
improvements to support implementation of
adopted regional and local land use plans
and assist local jurisdictions in meeting
transportation concurrency requirements
under the Growth Management Act.
• The balance of program benefits to costs
for the Selected Alternative is more
desirable than for the other alternatives.
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Mitigation Measures to Minimize Harm
Mitigation measures and the mitigation approach
required of the Selected Alternative under this
ROD are as identified in the FEIS and are
incorporated herein by reference.
Implementation of these mitigation measures and
approach are material conditions of this ROD
and will be incorporated in any subsequent
project-specific level NEPA environmental
review, finding, and mitigation plan.
Additional mitigation measures will be
developed, pursuant to the mitigation
commitments identified herein, under the
project-specific level NEPA environmental
reviews and findings.
Mitigation measures identified herein and in
subsequent NEPA environmental reviews and
findings shall and must be implemented by the
project sponsor(s) if specific projects and
corridor improvements proceed with either FHWA
or FTA financial assistance. These mitigation
measures are now incorporated into the
definition of the project and the project
sponsor(s) shall implement them, provide
funding for their implementation, or ensure
that other agencies fund and implement them
(although this would not alleviate the project
sponsor(s) of overall responsibility for
implementation). The project sponsor(s) is
(are) prohibited from withdrawing or
substantially changing any of the mitigation
measures identified in the environmental record
for the project without the express written
approval by FHWA (for road or highway related
projects) and/or FTA (for transit related
projects). In addition, any change to the
project that may involve new or changed
environmental or community impacts not yet
considered in the existing environmental record
must be reviewed in accordance with FHWA and
FTA’s environmental procedures (23 CFR Part
771) and approved by FHWA and FTA.
FHWA and FTA find that with the incorporation of
these mitigation measures in project-specific
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level NEPA environmental reviews and findings and
the implementation of these mitigation
commitments, the project sponsor(s) will have
taken all reasonable, prudent, and feasible means
to avoid or minimize impacts from the Selected
Alternative.
The following is a summary of the mitigation
commitments imposed under this ROD for the
Selected Alternative. This summary is provided
to facilitate the monitoring of the
implementation of the mitigation measures and
to give a sense of the nature of the mitigation
actions and associated impacts. However, this
summary does not supercede or negate any of the
commitments for environmental mitigation
established in the FEIS. The FEIS identifies
the mitigation commitments required of the
Selected Alternative. Should there be a
conflict between the mitigation commitments
summarized hereinafter and those described in
detail in the FEIS, the FEIS shall prevail.
Air Quality
1. Mitigation measures will be incorporated into
the construction specifications to control
Particulate Matter less than 10 microns
(PM
10
), deposition of particulate matter, and
emissions of carbon monoxide and nitrogen
oxides.
2. Construction of the separate projects will be
managed, staged, and/or phased to reduce
overall system congestion and delays, which
would reduce regional emissions of
pollutants, to the greatest extent
practicable.
Noise
3. Mitigation measures such as using enclosures
or walls to surround noisy equipment,
installing mufflers on engines, or other
methods will be incorporated into the
construction specifications to reduce
construction related noise.
4. Operational noise levels will be reduced
along I-405 by providing noise barriers in
some areas not currently protected by
barriers, consistent with the appropriate
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noise impact and abatement criteria of FHWA
and FTA.
5. Traffic management measures, acquiring land
as buffer zones, and/or other non-structural
measures to reduce long-term operational
noise impacts will be incorporated into
facility design where appropriate.
Energy and Natural Resources
6. Contractors will be encouraged to implement
measures to reduce energy consumption during
construction to the extent practicable.
7. Transportation control measures to reduce
traffic volumes and congestion, would also
decrease energy consumption. Such measures
are listed within the Transportation section,
items 52-54 below.
Geology and Soils
8. Design solutions to avoid, minimize, or
mitigate disturbance to geologic, seismic,
and mine hazard areas will be implemented.
9. Best management practices (BMPs) and other
measures will be incorporated into the
construction specifications to control or
reduce construction related erosion and
sedimentation, increase infiltration (where
appropriate), reduce seismic and soft ground
hazards, improve safety in landslide hazard
areas, and address collapsed mine openings or
underground rooms.
Water Resources
10. The most current criteria and standards to
mitigate stormwater quantity and quality
impacts will be used. These standards will
be presented in a WSDOT stormwater or highway
runoff manual that will be functionally
equivalent to Ecology’s stormwater manual.
Additional avoidance, minimization, and
mitigation of impacts to water resources may
be achieved by following the design
guidelines in the local sensitive area
ordinances and codes, such as for the city of
Renton Aquifer Protection Areas.
11. BMPs and design solutions for preventing
sediment from entering water bodies,
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maximizing treatment of road runoff, and
minimizing the number of stream crossings
will be implemented, as appropriate.
12. Planning for all major road upgrade projects
will consider the practicality of
retrofitting existing impervious road surface
areas for runoff detention and treatment.
Where determined to be practicable, retrofit
measures will be incorporated into the road
upgrade project.
13. Any new road crossings of streams will be via
a bridge spanning the floodway unless a
hydraulic analysis demonstrates that
infringing abutments and/or bridge piers
would not substantially change local high-
water depths or velocities. Disturbed
riparian areas within road right-of-way will
be planted with native vegetation for a
minimum width of 100 feet from each stream
bank where practicable.
14. Opportunities to increase the “perviousness”,
infiltration and base flow conditions, of
affected stream basins will be explored in
cooperation with local agencies.
15. Mitigation for operational impacts to
groundwater quality will include measures to
prevent hazardous materials from reaching the
soil and infiltrating into groundwater.
16. Measures to avoid, minimize, or mitigate the
potential decrease in groundwater recharge in
Critical Aquifer Recharge Areas and other
potential recharge areas during construction
will be implemented.
17. Measures to protect Renton’s Aquifer
Protection Area from infiltration of project
runoff will be implemented.
18. Projects constructed within the Lake
Sammamish Basin will incorporate special
stormwater treatment to reduce phosphorus, as
appropriate.
19. Where practicable, infiltration of treated
stormwater will be used. This measure is
particularly applicable to those basins that
may otherwise experience depletion of base
flows: Springbrook, South Kelsey, East Lake
Washington, Forbes, Juanita, and North Creek.
20. The I-405 Corridor Program will continue to
work closely with the U.S. Fish and Wildlife
Service (USFWS), NOAA Fisheries, the
Washington State Department of Fish and
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Wildlife (WDFW), the Washington State
Department of Ecology (Ecology), the Tribes,
local municipalities, and basin stakeholders
to develop a program of support for both
local and regional stream and riparian
enhancement projects.
21. A Water Resource Inventory Area (WRIA)-wide
approach to mitigate program hydrologic
impacts and address base flow impacts in an
ecologically beneficial and cost-effective
manner will be implemented. This could
include projects that benefit the hydrology
and habitat of streams as compensation for
potential reductions in stream base flow
resulting from proposed road improvements.
22. Construction disturbance will be limited to
the minimum area needed, the shortest
duration, and at an appropriate distance away
from water bodies as practical. Seasonal
work windows will be identified and
implemented.
23. Pervious portions of the project area will be
treated with soil amendments, mulch,
vegetation or other appropriate and available
resources to help absorb stormwater.
Stormwater management facilities will be
located outside of stream, steep slope, and
wetland buffer areas, where practicable.
24. Construction mitigation measures will be
implemented to reduce the use, transfer, and
storage of hazardous materials in sensitive
areas where there is potential for
groundwater and/or surface water
contamination.
25. Measures to mitigate reduction of groundwater
supplies due to dewatering, pump testing, or
other construction activities will be
implemented where practicable.
Wetlands
26. Project-level design, environmental review,
and permitting will include avoidance,
minimization, restoration, and compensation
as part of an appropriate wetland mitigation
approach. Mitigation will be implemented
prior to wetland impacts where feasible, to
reduce temporal losses of wetland functions.
27. BMPs and other measures will be incorporated
into the construction specifications to
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minimize sedimentation and contamination of
wetlands. Stormwater treatment facilities
will be designed consistent with the Ecology
stormwater manual or functionally equivalent
stormwater guidance, such as WSDOT’s highway
runoff manual.
28. Mitigation locations and concepts will be
identified during project-level design,
environmental review and permitting, and
during possible early-action mitigation
activities. WSDOT will continue to meet with
federal, state, and local agencies to
identify mitigation priorities and options,
and to discuss opportunities for on-site
mitigation and mitigation banking.
29. Projects lead by WSDOT will follow guidance
in WSDOT Environmental Procedures Manual
(Volumes 1 and 2) (WSDOT, 2001) that outlines
the issues and actions to be addressed prior
to authorizing work that could impact
wetlands within their right-of-way.
Wildlife, Habitat, and Upland Threatened and
Endangered Species
30. Opportunities to avoid and minimize impacts
to wildlife, habitat, and upland threatened
and endangered species will be identified and
implemented during environmental review and
project-level design.
31. Construction disturbance will be limited to
the minimum area needed, the shortest
duration, and at an appropriate distance away
from sensitive species as practical.
Seasonal work windows will be identified and
implemented as appropriate.
32. Right-of-ways and construction zones will be
re-vegetated with native species as
appropriate to offset loss of habitat.
33. The I-405 Corridor Program will continue to
coordinate with the USFWS on changes in the
project or in threatened and endangered
species status or habitat use, and implement
BMPs and/or other measures to minimize
impacts to threatened and endangered species.
34. Design and construction specifications will
be prepared in coordination with wildlife
biologists to reduce impacts on wildlife
habitat.
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35. The future environmental analyses of federal
actions, that are included in the I-405
Corridor Program projects, will evaluate the
effects of actions on migratory birds, with
emphasis on the species of concern.
Mitigating measures in the documents should
include focus on avoiding and minimizing
adverse impacts to migratory bird resources
and restoring and enhancing migratory bird
habitat as practicable.
Fish, Aquatic Habitat, Threatened and Endangered
Fish Species
36. Project-level design, environmental review,
and permitting will identify avoidance,
minimization, restoration, and compensation
as part of a comprehensive mitigation
approach to reduce adverse effects on fish
and aquatic habitat. Mitigation will be
implemented in advance of project permitting
and construction, where practicable, to avoid
temporal losses of habitat and functions.
37. Consideration will be given to non-
engineering solutions, such as removal of
existing impervious surfaces and conversion
into naturally vegetated habitat, where
practicable and permitable.
38. Compensatory measures will be implemented on-
site/in-kind, within the sub-basin or at the
watershed level. Such measures will be
identified during project-level design,
environmental review, and permitting where
avoidance and minimization does not
sufficiently address impacts to fish and
aquatic habitat.
39. Construction disturbance will be limited to
the minimum area needed, the shortest
duration, and at an appropriate distance away
from water bodies and aquatic habitat as
practical. Seasonal work windows will be
identified and implemented as appropriate.
40. Where practicable, construction and
maintenance will be done during low flow and
periods that are least likely to harm fish
and other aquatic resources.
41. BMPs and other measures will be incorporated
into the construction specifications to
control or reduce temporary construction
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related impacts such as sedimentation and
contamination of fish and aquatic habitat.
42. The I-405 Corridor Program will participate
in habitat enhancement/protection projects
identified by local jurisdictions and
watershed groups to gain mitigation credit
for project-level impacts while contributing
toward overall restoration of sub-basins and
watersheds.
43. Maintenance of stream crossing structures
will be reduced by selecting materials with
longevity and low maintenance requirements
and by selecting larger sizes of culverts or
bridges with more clearance.
44. The I-405 Corridor Program will continue to
coordinate with NOAA Fisheries and USFWS on
changes in the project or in threatened and
endangered species status or habitat use, and
will implement BMPs and/or other appropriate
measures to minimize impacts to threatened
and endangered species.
45. Design and construction specifications will
be prepared in coordination with fisheries
biologists to reduce impacts on the natural
streambed and habitat.
Farmland
46. Where practicable, considering other social,
economic and environmental impacts, the
projects will be designed so that any
expansion outside the right-of-way avoids or
minimizes impacts on farmland. This is
particularly applicable to the Willows Road
improvement.
Floodplains
47. Floodways will be spanned or bridged so that
flows are not impeded.
48. Projects will be designed to limit the amount
of fill in the floodplain, reduce impacts to
flood flows, and avoid rise in flood levels
to the greatest extent practicable.
49. Design and construction specifications will
be prepared in coordination with
hydrologists, hydraulic specialists, and
biologists to reduce impacts on the
floodplain.
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50. Maintenance of floodplain crossing structures
will be reduced by selecting materials with
longevity and low maintenance requirements
and by selecting larger sizes of culverts or
bridges with more clearance.
Shorelines
51. Avoidance, minimization, and mitigation of
impacts to shorelines will be identified and
incorporated as appropriate and practicable
during project-level design, environmental
review, and permitting.
Transportation
52. All reasonable and feasible approaches to
maintain existing traffic lanes during
construction will be implemented.
53. Specific measures to control or reduce
construction related traffic impacts and
maintain safety will be identified during
project-level design and environmental
review, and will be incorporated into the
construction specifications.
54. TDM measures, transit improvements, and/or
other advance measures to provide alternative
means and routes for travel through the
impacted sections of the corridor will be
implemented prior to construction.
Displacements and Right-of-Way Acquisition
55. All reasonable attempts will be made to avoid
acquiring properties or displacing residents
or businesses. Where avoidance is not
reasonable or feasible, WSDOT or local
project sponsors will conform to the
requirements set forth in the Uniform
Relocation Assistance and Real Property
Acquisition Policies Act of 1970, as amended,
to ensure just compensation of all acquired
properties and minimal impact on the current
owners and residents.
Social Impacts
56. Measures will be identified during project-
level design and environmental review to
avoid and mitigate impacts related to
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displacements, traffic, noise, visual
quality, and land use. These measures also
will reduce overall social and neighborhood
impacts.
Economic Impacts
No mitigation is required.
Recreational Resources
57. Avoidance, minimization, and mitigation or
replacement of impacted publicly owned
parkland, trails, recreational resources, and
functions will be identified and incorporated
consistent with Section 4(f) of the
Department of Transportation Act and Section
6(f) of the Land and Water Conservation Fund
Act, as appropriate, during project-level
design and environmental review.
58. Auto and pedestrian traffic control measures
to lessen impacts to the park access and
functions will be implemented.
59. Measures will be identified during project-
level design and environmental review to
avoid, minimize, and mitigate impacts related
to noise, visual quality, and land use.
These measures also can reduce overall
impacts on recreational resources.
Public Services
60. Construction scheduling and staging plans
will be developed to ensure that emergency
and school transportation access is
maintained.
61. Police, fire, emergency, and school
transportation service providers will be
contacted and kept informed to address
possible temporary disruptions in service
during construction. Contingency plans for
unforeseen interruptions of access or
services will be developed in advance of
initiation of construction.
Utilities
62. Utilities may be relocated if conflicts with
project improvements cannot be avoided
through project design.
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Visual Quality
63. Where appropriate and practicable, specific
measures will be identified during project-
level design and environmental review to
mitigate adverse visual impacts of the
transportation improvements.
Historic, Cultural, and Archaeological Resources
64. Avoidance, minimization, and mitigation of
impacts to significant historic sites will be
identified and incorporated consistent with
Section 4(f) of the Department of
Transportation Act, as appropriate, during
project-level design and environmental
review.
65. Mitigation measures for archaeological
resources may include archaeological
monitoring, subsurface testing, and data
recovery, as appropriate to site.
66. Mitigation measures for historic resources
may include, but are not limited to designing
the project to avoid or limit physical
alteration, visual, atmospheric, or long-term
noise impacts; relocating historic resources
to appropriate new sites; and/or modifying
construction methods to avoid or limit
construction-related impacts. Mitigation
will be in accordance with the standards of
the Washington SHPO and local consulting
parties regarding both requirements and
repository, as appropriate.
67. The I-405 Corridor Program will continue to
coordinate with the affected tribes. Prior
to or during project-level design and
environmental review, a cultural resources
study will be initiated in consultation with
local Indian tribes to determine the
presence/absence of tribal cultural resources
and appropriate mitigation measures.
Hazardous Materials and Wastes
68. Management of contaminated media such as soil
or groundwater, control and management of
hazardous wastes, and transport of hazardous
substances will be conducted consistent with
environmental regulations.
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69. Additional site assessment will be conducted,
and measures for addressing hazardous
materials will be identified and implemented
during project-level design, environmental
review, and permitting.
Early Action Environmental Impact Mitigation
70. The goals and objectives listed in the
Corridor Environmental Program (Appendix J of
the FEIS) will guide the future project-level
environmental programs and early-actions.
71. The proposed Early Action Environmental
Impact Mitigation Decision Making Process,
contained in the Corridor Environmental
Program (Appendix J of the FEIS), will be
conducted in coordination with Federal and
state resource agencies. WSDOT will use the
process to develop an early-action mitigation
proposal to mitigate various unavoidable
impacts of the Selected Alternative in
advance of project permitting and
construction. The process and methods
described in Appendix J will evolve and be
refined as WSDOT continues to consult with
local, state, and Federal agencies on
appropriate compensatory mitigation.
Determinations and Findings
The environmental record for the I-405 Corridor
Program includes the previously referenced Draft
and Final Environmental Impact Statements and
Preliminary Draft and Preliminary Final Section
4(f) Evaluations (August, 2001 and June, 2002,
respectively). These documents, incorporated here
by reference, constitute the detailed statements
required by NEPA and 49 U.S.C. Section 5324(b) on:
• The environmental impacts of the proposed
program;
• The adverse environmental effects that cannot
be avoided should the program be implemented;
• Alternatives to the proposed program; and
• Irreversible and irretrievable impacts on the
environment that may be involved in the
program should it be implemented.
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Having carefully considered the environmental
record noted above, the mitigation measures as
required herein, the written and oral comments
offered by other agencies and the public on this
record, and the written responses to comments, the
FHWA and FTA have determined in accordance with 49
U.S.C. Section 5324(b) that adequate opportunity
was offered for the presentation of views by all
parties with a significant economic, social, or
environmental interest, and fair consideration has
been given to the preservation and enhancement of
the environment and to the interest of the
communities in which the program is located; and
all reasonable steps have been taken to minimize
adverse environmental effects of the proposed
program; and, where adverse effects remain, there
exists no feasible and prudent alternative to
avoid or further mitigate such effects.
Section 4(f) Preliminary Determination
Preliminary Section 4(f) evaluations are included
in Appendix H of the Final EIS. Consistent with
23 CFR section 771.135(o), the FHWA and FTA have
made a preliminary determination that the Selected
Alternative incorporates all possible planning to
minimize harm to Section 4(f) land and resources
to the extent allowable based on the level of
detail available at the corridor-level EIS.
Furthermore, this preliminary determination finds
that there are no feasible and prudent locations
or alternatives for the action to avoid the use of
Section 4(f) land and resources; and no other
feasible and prudent alternative is more effective
in minimizing potential harm to Section 4(f)
resources. Final determinations of Section 4(f)
impacts will be made upon review of specific
corridor improvement projects and their scope.
Final determinations are not bound by or
prejudiced by this preliminary determination as
specific project scopes are not known and,
therefore, the use of potential Section 4(f)
resources cannot be fully or finally evaluated.
Thus, opportunities to eliminate or minimize harm
at subsequent stages in the development process
have not been precluded by decisions made at the
corridor-level stage of analysis.
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Environmental Justice
An analysis of Environmental Justice is included
in Appendix G of the Final EIS. Consistent with
Executive Order 12898, “Federal Action to Address
Environmental Justice in Minority and Low-Income
Populations” (February 11, 1994) and the U.S.
Department of Transportation Order 5610.2, the
FHWA and FTA have concluded that after the
mitigation measures to minimize harm identified
under this ROD are implemented, no high and
adverse human health or environmental effects are
expected to fall disproportionately on minority or
low-income populations as a result of implementing
the Selected Alternative.
Conformity With Air Quality Plans
An analysis of air quality, conformity with the
Federal Clean Air Act (42 U.S.C. 7506(c)), and
regional conformity with the State Implementation
Plan (SIP) is included in the Final EIS. Analyses
discussed in the Final EIS show that the daily
emission values for the Selected Alternative would
be within the region’s SIP budget.
On April 25, 2002, the Puget Sound Regional
Council (PSRC) Executive Board approved refinement
of the Metropolitan Transportation Plan (MTP) to
reflect the project elements of the Selected
Alternative. PSRC’s revised modeling runs show
regional emissions below the emission budgets for
all pollutants in 2010, 2020, and 2030 for the MTP
including the Selected Alternative. This modeling
demonstrates that air quality in the Puget Sound
region, including implementation of the Selected
Alternative, would conform at the regional level
to the regional air quality maintenance plans.
Thus, the Selected Alternative has been determined
to conform at the regional scale to the Puget
Sound’s air quality maintenance plans. The
Selected Alternative would not cause any new or
contribute to any existing regional exceedances of
the National Ambient Air Quality Standards
(NAAQS). Project-level air quality analysis will
be needed for those individual elements in the
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Selected Alternative that are not exempt from
project-level conformity analysis (CFR 93.134).
Endangered Species Act (ESA)
The Endangered Species Act of 1973, as amended
(ESA), intends to protect threatened and
endangered species and the ecosystems on which
they depend. The ESA requires a federal agency to
ensure that any action it authorizes, funds, or
carries out is not likely to jeopardize the
continued existence of any listed species or
result in direct mortality, destruction, or
adverse modification of critical habitat of listed
species. This requirement is fulfilled under
Section 7 of the ESA by review of the proposed
actions and consultation with the appropriate
agency responsible for the conservation of the
affected species. If necessary, measures will be
required to avoid jeopardizing listed species or
habitat.
Preliminary review under the ESA (as noted in the
FEIS) and informal consultation with the affected
Federal resource agencies has commenced. However,
as previously noted, because specific project
scopes are not known, the impacts, if any, on
endangered species and ecosystems cannot be fully
or finally evaluated at the corridor-level EIS
stage.
In accordance with the methodology and processes
agreed upon with the affected Federal resource
agencies, the FHWA and FTA will continue to work
in coordination with the other I-405 Corridor
Program co-lead agencies, NOAA Fisheries, and the
USFWS to identify actions that could result in the
take of listed species. The I-405 Corridor
Program co-lead agencies will continue corridor-
wide Section 7 informal consultation under the ESA
with NOAA Fisheries and USFWS on the I-405
Corridor Program Selected Alternative. The co-
lead agencies will continue to work with NOAA
Fisheries and USFWS to define the best method for
ESA Section 7 consultation on a corridor level.
Thereafter, upon the presentation of specific
corridor projects to the Federal co-lead agencies,
the co-lead agencies will begin specific
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coordination with NOAA Fisheries and USFWS on
project-level ESA compliance.
Magnuson-Stevens Act
The 1996 Magnuson-Stevens Fisheries
Conservation and Management Act (MSA) amended
federal fisheries management regulations to
require identification and conservation of
habitat that is "essential" to federally
managed fish species. Essential habitat is
defined as “those waters and substrate
necessary to fish for spawning, breeding,
feeding, or growth to maturity.” The Pacific
Fishery Management Council (PFMC) is the body
responsible to review relevant habitat issues
in the Pacific Northwest, including the study
area of the I-405 Corridor Program. The PFMC
has designated Essential Fish Habitat (EFH) for
the Pacific salmon fishery, federally managed
groundfish, and coastal pelagic fisheries
(NMFS, 1999b; PFMC, 1999). Only EFH associated
with the Pacific salmon fishery is present in
the study area.
FHWA and FTA will continue to consult with NOAA
Fisheries on any I-405 Corridor Program project
or proposed activity authorized, funded, or
undertaken by the agencies that may adversely
affect EFH.
Section 106
Section 106 of the National Historic
Preservation Act of 1966, as amended, requires
the review of federally assisted projects for
impacts to districts, sites, buildings,
structures, and objects listed in, or eligible
for inclusion in, the National Register of
Historic Places. FHWA, FTA, and WSDOT have
consulted with the Washington State Historic
Preservation Officer (SHPO), to develop an
approach to consider cultural resources
(archaeological properties, traditional
cultural properties, and properties of the
historic built environment) at a program level,
consistent with the evaluation in the I-405
Corridor Program EIS. Data collection and
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analyses were preliminary by design, and are
not intended to provide a project-level
environmental analysis, documentation, and
review. Measures to avoid, minimize, and
mitigate potential adverse effects on Section
106 resources have been identified by WSDOT at
a corridor level. Since compliance with Section
106 of the National Historic Preservation Act
requires lead federal agencies to take into
consideration the effect of a project on
properties listed in, or eligible for listing
in, the National Register of Historic Places,
it was agreed that formal compliance with
Section 106 will take place during subsequent
project-level environmental analysis,
documentation, and review. In the interim,
absent any commitment to move forward with the
construction of specific transportation
facilities, there is not any undertaking that
the SHPO must review under the Section 106
process.
Consideration of potential project impacts to
cultural resources at this corridor level of
analysis fulfills both the spirit and intent of
Section 106 to take into consideration, at the
earliest possible time, the potential effects
of the proposal on eligible historic
properties. Consistent with this approach,
WSDOT is currently engaging in government-to-
government consultation with federally
recognized and non-recognized Native American
Tribes to facilitate “early consultation” under
the revised Section 106 regulations.
Floodplains
Pursuant to Executive Order 11988 (Floodplain
Management), the I-405 Corridor Program FEIS
analysis evaluated potential impacts of the
program upon/within the 100-year floodplains
and floodways along the corridor, as defined by
the Federal Emergency Agency (FEMA). At this
point, FTA and FHWA find that no adverse
impacts to any 100-year floodplains or
floodways would occur as a result of the I-405
Corridor Program. I-405 project level
environmental analysis and review will take
place prior to any project implementation.
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This analysis and further design will ensure
that no impacts to the floodplains or floodways
will occur unless there is no practicable
alternative to such action.
Wetlands
The United States Department of Transportation
seeks to assure the protection, preservation,
and enhancement of the nation’s wetlands to the
fullest extent practicable during the planning,
construction, and operation of transportation
facilities and projects (DOT Order 5660.1A;
Executive Order 11990).
Potentially feasible mitigation sites for the
I-405 Corridor Program have been identified by
WSDOT within the affected drainage basins.
(Mitigation opportunities are identified by
basin in the FEIS Chapters 3.5 and 3.8.)
Applicable wetland mitigation ratios have not
yet been determined but will be determined
collaboratively during final design by the
project proponents and regulatory agencies.
Implementation of the I-405 Corridor Program
projects will result in no net loss of
wetlands.
With the program’s proposed wetland mitigation
measures, FHWA and FTA find that the I-405
Corridor Program meets the federal wetland
requirements described above.
Farmland
The Farmlands Protection Policy Act (FPPA) of
1981 (7 USC 4201-4209) requires the review of
federally funded activities to identify and
minimize the conversion of farmland to non-
agricultural uses. Pursuant to FPPA, WSDOT
assessed farmlands within the study area. All
of the potentially affected farmlands score 160
or less on the Farmland Conversion Impact
Rating Form (AD-1066) land evaluation and site
assessment, and are categorized as farmland not
requiring further consideration for protection.
Measures to avoid and minimize effects on
farmlands have been identified by WSDOT at a
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program level. FTA and FHWA find the Corridor
Program FEIS analysis to be consistent with the
FPPA and other applicable state and federal
farmlands protection policies, orders, and
guidance. I-405 project-specific level
environmental review and documentation will
further address specific measures to avoid and
minimize impacts to farmlands.
Coastal Zone Management
The Coastal Zone Management Act (CZMA) of 1972
(16 USC 1451 et seq.) encourages advancement of
national coastal management objectives and
implementation of state management programs.
Under Washington’s Coastal Zone Management
Program, local jurisdictions have developed
shoreline management plans. In addition to
demonstrating consistency with these plans and
the Washington State Shoreline Management Act,
projects must meet the requirements of the
Washington State Environmental Policy Act,
Clean Water Act (33 USC 1251 et seq.) to
demonstrate consistency with CZMA.
WSDOT has evaluated the effects of the proposal
consistent with the programmatic I-405 Corridor
Program EIS. Data collection and analyses were
not intended to provide a project-level
environmental analysis, documentation, and
review. Measures to avoid, minimize, and
mitigate potential adverse effects on
shorelines, water quality, and air quality have
been identified by WSDOT at a program level.
Consideration of potential project impacts at
this programmatic level of analysis fulfills
both the spirit and intent of CZMA at this
stage in project development. WSDOT will
request certification of consistency with CZMA
during subsequent project-level environmental
analysis, documentation, and review.
Monitoring and Enforcement
The Division Administrator, Federal Highways
Administration and the Regional Administrator,
Federal Transit Administration are ultimately
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responsible for monitoring and enforcing
mitigation measures outlined within this Record of
Decision. The Urban Corridors Administrator,
Washington State Department of Transportation;
Executive Director, Central Puget Sound Regional
Transit Authority; and Director, King County
Department of Transportation will also ensure the
monitoring and enforcement of mitigation measures
associated with their agencies’ respective
projects.
Comments Received on the Final EIS
Only one comment letter on the FEIS was received
after it was issued. The letter received was from
Judith Lekrone Lee, U.S. Environmental Protection
Agency (EPA) Region 10, to James Leonard, FHWA,
and Michael Cummings, WSDOT, dated August 13,
2002. The letter contained four main issues.
Attachment A includes a copy of the letter and
reference numbers to the four main issues.
Responses to those issues are as follows:
1.) Page 1, Paragraph 3 and 4 regarding EPA’s
comment, “Bus Rapid Transit was selected over
High-Capacity Transit as the transit mode of
choice for the I-405 Corridor Program. Thus,
impacts to aquatic resources are substantially
overstated for Alternatives 1 and 2…”:
The alternatives considered in the I-405
Corridor Program EIS were identified with
participation by EPA to demonstrate a range
of potential solutions and compare their
potential impacts. Each alternative was
evaluated considering the broad range of
anticipated environmental effects as well as
the transportation performance benefits that
would be gained. After weighing all of these
effects, FHWA, WSDOT, the other co-lead
agencies, and I-405 Corridor Program
committees concluded that Alternative 1 would
not achieve the purpose and need for the
corridor program. Also, Alternative 2 did
not perform as well as the Preferred
Alternative in meeting the purpose and need,
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and it was determined to be a less
environmentally responsible choice.
Furthermore, the determination of the
alternative that best meets the purpose and
need is the responsibility of the
transportation agencies.
The most important characteristic of the
high-capacity transit system contained in
Alternatives 1 and 2 was its physical
separation and location outside the I-405
roadway, mostly within the Burlington-
Northern Santa Fe right-of-way. This is the
factor that influenced the greater impacts to
aquatic resources in Alternatives 1 and 2 –
not the choice of technology between rail
transit and bus rapid transit. If either
rail transit was included adjacent to the I-
405 roadway or bus rapid transit was included
within the Burlington-Northern Santa Fe
right-of-way, the overall effects on aquatic
resources would not be less than reported in
the Final EIS for Alternatives 1 and 2, and
the impacts likely could be higher because of
the expanded footprint and additional
impervious surface that would be required.
Thus, we believe that the impacts to aquatic
resources are accurately presented.
Regarding EPA’s concern, addressed on page 1,
paragraph 4 of the comment letter, that the
Preferred Alternative does not represent a
balanced approach or demonstrate a full
commitment to viable multi-modal
transportation, we would point out the Final
EIS (page 3.13-8) concluded that the bus
rapid transit system proposed in the
Preferred Alternative is expected to provide
similar ridership and mobility benefits as
would be achieved by either Alternative 1 or
2. In addition, the proposed bus rapid
transit system could be brought on line more
quickly, at a substantially lower cost, and
with greater flexibility for future expansion
in response to changes in land use or overall
demand. The Preferred Alternative combines
this commitment to new transit infrastructure
and transit stations with a substantial
increase in local bus transit service (up to
75% based on demand), an aggressive TDM
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program, HOV and general purpose roadway
improvements, and non-motorized
transportation improvements. When viewed as
a system, we believe the Preferred
Alternative represents a comprehensive,
regional solution to existing and forecasted
transportation needs that is well balanced,
cost-effective, and sustainable.
2.) Page 2, “Corridor-Level Mode Phasing and
Adaptive Management”:
Per the memorandum from Craig Stone, WSDOT
Project Director, to the I-405 Executive
Committee, project staff has been working
with committee members to develop a range of
implementation concepts that reflect funding
possibilities. The implementation concepts
have been based on the following
implementation principles, as adopted by the
I-405 Executive Committee:
• Fulfill the Vision – The I-405
implementation plan should reflect the
vision and intent of the program’s
Preferred (Selected) Alternative.
• Worst First – The most congested areas of
the corridor should be the focus of early
implementation efforts and investments.
• Complete Logical Segments – Improvements
should be made to their maximum and
completed in distinct segments or
sections.
• Geographic Investments – Investments
should be made throughout the corridor to
evenly distribute benefits as reasonably
as possible.
• Modal Balance – The implementation plan
should include all modes; transit, roads,
and TDM, working together as a
comprehensive package.
• Achieve Early Actions – Projects should be
chosen for their ability to deliver
benefits as soon as possible.
• Early Action Environmental – Early
environmental improvements should be an
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essential component of initial
implementation efforts.
• Minimize Overall Costs and Risks –
Projects selected should provide
opportunities to reduce costs and risks to
schedule.
• Minimize Construction Impacts – The
implementation strategy should minimize
construction impacts to communities by
avoiding repetitive work programs.
3.) Page 2, “Conclusions in Chapter 3
regarding the Significance of Impacts”:
Chapter 3 of the Final EIS was revised to
respond to EPA’s comments regarding
conclusions on the significance of effects of
the alternatives. While EPA prefers use of
the terms “significant” and “significance of
impacts” when describing the level of
effects, it is the policy of FHWA and FTA to
avoid or reduce use of these terms in an EIS.
Specifically, FHWA Technical Advisory T
6640.8A, dated October 30, 1987, states under
Section V:
G. Environmental Consequences
This section includes the probable
beneficial and adverse social, economic,
and environmental effects of
alternatives under consideration and
describes the measures proposed to
mitigate adverse impacts. The
information should have sufficient
scientific and analytical substance to
provide a basis for evaluating the
comparative merits of the alternatives.
The discussion of the proposed project
impacts should not use the term
significant in describing the level of
impacts. There is no benefit to be
gained from its use. If the term
significant is used, however, it should
be consistent with the CEQ definition
and be supported by factual information.
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FTA does not set thresholds for significance
because doing so is not consistent with the
CEQ regulations and does not contribute to
the public's understanding of the project and
its impacts. In addition, experience from
other EISs has shown that it can diminish the
NEPA objective of balanced decision making
that weighs the societal need for the project
against its overall negative impact and cost
by diverting discussion to specific details
of project impact areas and the thresholds
themselves.
To improve the discussion of project impacts
in the Final EIS, qualifiers including use of
the word “substantial” were added to describe
the level of impacts where this was
appropriate. In addition, expanded
discussions were provided for a number of
environmental elements to better explain the
scientific and analytical bases for
evaluation of impacts, the ranking of
impacts, and the comparison of the relative
effects among alternatives.
4.) Page 3, “Responses to Comments on
Transportation, Land Use, Induced Travel and
Growth”:
All input on draft and preliminary versions
of the I-405 Corridor Program documents were
considered and changes were incorporated into
the documentation where necessary. The FEIS
contains full and complete responses to the
questions and issues raised regarding
transportation, land use, induced travel, and
growth.
Findings and conclusions on transportation
mode performance are appropriately addressed
in the Transportation Section 3.12 of the
FEIS. Figures 3.12A-C of the FEIS
graphically represent how each alternative
accommodates peak period person demand by
mode. Tables 3.12-4 through 3.12-7 show the
P.M. peak travel time comparisons between
alternatives for general traffic, HOV
traffic, walk-and-ride transit, and park-and-
ride transit. Also, the effectiveness of the
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I-405 Corridor Program
TDM Program, mode common to all action
alternatives, is summarized in Table 3.12-12.
Regarding land use and the patterns of
growth, Section 3.23 of the FEIS presents the
results of the alternative evaluation using
the PSRC land use forecasting model
(DRAM/EMPAL). Also, Section 3.13 of the FEIS
and responses to relevant comments
acknowledge that land use in the study area
is managed through comprehensive plans
prepared for each jurisdiction and guided by
countywide planning policies adopted in
accordance with the Growth Management Act
(RCW 36.70A). After comments on the DEIS
were received, a detailed review of
consistency with adopted plans and policies
was added to the FEIS Section 3.13.
Attachment
Attachment A:
Letter from EPA to FHWA and WSDOT commenting
on the I-405 Corridor Program FEIS (August
13, 2002).
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Attachment A
Letter from EPA to FHWA and WSDOT commenting on
the I-405 Corridor Program FEIS (August 13, 2002).
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