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Thousands comment
on I-90 DEIS ●
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August 5, 2005
Don Whitehouse
Regional Administrator
Washington Dept. of
Transportation
PO Box 12560
Yakima, Washington 98909
Re: Draft EIS on I-90 Snoqualmie
Pass East Project
Dear Mr. Whitehouse:
We submit this letter in response
to the Draft Environmental Impact Statement (DEIS) on the I-90
Snoqualmie Pass East Project. This letter summarizes our concerns and
recommendations and supplements the comments made at the public
meetings. More detailed comments on the Draft EIS and connectivity
measures are attached in the report by our biologist.
We recognize the importance of
Interstate 90 with respect to freight mobility, tourism and other
economic values. Reducing closures due to avalanches, improving safety
and reducing maintenance costs are key considerations. So is restoring
ecological connectivity. DOT should strive for a package that meets each
of these goals to a high degree. Doing so will result in a better
design, built sooner.
Expansion & Restoration
Normally, our coalition members
would not favor widening the I-90 freeway. They are justifiably
concerned about expanding the freeway to six lanes, due to the
additional impacts on adjacent forests, wetlands, water quality and
recreation, and the encouragement of development in the upper Kittitas
Valley. However, this project has the potential to significantly improve
conditions for wildlife and water in the Cascades. There is also
universal support for correcting the avalanche problem in the vicinity
of the snowshed and to improve safety at locations such as Slide Curve.
With the inclusion of structures that provide a high level of wildlife
connectivity and restoration of stream and wetland functions, and full
mitigation for impacts of expansion, we can support the project.
Process
We commend WSDOT for including
ecological connectivity as a goal of the project and for working with
conservation groups and agency biologists to develop the connectivity
elements of this project. There is great value in the information and
recommendations from biologists with the Washington Department of Fish
and Wildlife, US Fish and Wildlife Service, Forest Service, and others
on the Mitigation Development Team.
We also appreciate WSDOT’s sincere
efforts to gather input from conservation groups and the general public.
We have attempted to be proactive and collaborative, hosting field
trips, public meetings and a wildlife science forum to assist in
producing designs that fully meet connectivity objectives at each
crossing. We appreciate your willingness to join these events and
further the public dialogue on this project.
WSDOT’s approach opened
opportunities for collaboration and has led to widespread, preliminary
support for this project, rather than opposition that so often
accompanies highway expansions.
Unique Location
A vast forest once stretched from
Puget Sound to east of Cle Elum, providing a continuous habitat
connection between the north and south Cascades of Washington. That
forested zone has shrunk to less than 40 miles, from North Bend to
Easton, presenting dispersal constraints for many species. Approximately
46 miles of I-90 traverses this zone, creating a unique situation in the
Washington Cascades, where a major freeway crosses such a narrow habitat
corridor. Still, suitable habitat within a range of elevations exists
and can provide an effective connection if I-90 becomes sufficiently
permeable to wildlife. The I-90 Snoqualmie Pass East Project has the
potential to accomplish that within a critical 15-mile stretch.
I-90 Barrier
I-90 is the largest remaining
barrier in the corridor between the Alpine Lakes Wilderness and Mt.
Rainier National Park. Traffic will increase from the current 30,000 to
over 50,000 vehicles per day in 15 years (DEIS 3-153) and this will
likely double within 30 years. By themselves, the traffic and the
expansion would make I-90 even more of a wall. As stated in the DEIS
(1-130), widening and higher speeds tend to increase roadkill. Climate
change only magnifies the ecological consequences of the I-90 barrier
effect.
WSDOT must make the highway more
permeable—not only mitigating for new construction, but to make the
situation substantially better than it is today.
Excellent Opportunity
The proposal to rebuild 15 miles
of Interstate 90 between Hyak and Easton is a great opportunity to
improve the survival of wildlife in the Cascades. We won’t have another
such opportunity for more than 50 years. Let’s do it right. If we don’t,
taxpayers may need to pay millions more dollars later to retrofit the
freeway once a species becomes listed and the highway is considered a
barrier to the stability of the population.
All Native Species
Seventy species of native
terrestrial vertebrates inhabit this area, plus numerous species of fish
and other aquatic animals. In addition, hundreds of species of
invertebrates and plants are found in this area. All are affected by the
freeway. The noise from the freeway also impacts some bird species, and
can be a barrier to some. We need to provide sufficient passage
opportunity not only to migratory species such as deer and elk, but to
all native species. A large, connected population of a species is far
healthier than two smaller populations and better able to withstand
epidemics and habitat changes.
Special care must be taken to
provide adequately for rare and endangered species, such as wolverine,
wolf, grizzly bear, and lynx and bull trout and steelhead. Similarly,
structures must provide improved crossing for low mobility species, such
as amphibians and reptiles, and those with specialized habitats, such as
pikas. Invertebrates, such as mollusks, are an integral part of the
Cascades ecosystem and must also have routes over or under the freeway.
Crossing structures can also benefit dispersal of plants, especially
non-vascular species.
Effective Crossing Structures
Crossing structures do work, as
shown in Canada’s Banff National Park, Arizona and Florida. According to
the latest research, undercrossings work for many species if properly
designed (e.g., sufficient height). Some species, such as elk, deer,
gray wolf and grizzly bear prefer overcrossings. Both undercrossings and
overcrossings should be used in this project. They are a smart and
effective way to make the roadway safer for people and animals.
Complementary Habitat
Preservation & Restoration
The Forest Service, in conjunction
with conservation organizations such as The Cascades Conservation
Partnership, Trust for Public Land and Cascade Land Conservancy, has
made huge strides in conserving habitat in the region by acquiring lands
on either side of freeway which otherwise would have been converted to
cabins and other human housing. Conservation organizations and public
agencies have invested over $200 million dollars to acquire and protect
over 97,000 acres of habitat in this wildlife corridor during the past
ten years, and more is planned.
The Forest Service is also
decommissioning roads, improving management of national forest lands,
and adjusting recreational uses to improve habitat and decrease human
disturbance of wildlife. We will continue to encourage these activities,
though planning and funding of these projects may take a few years.
While there is much left to do in these areas, that fact should in no
way be used as an excuse not to provide the best crossing structures at
the freeway. Some, in fact, will be done before the I-90 project is
completed.
I-90 Snoqualmie Pass East runs
through a national forest and would take national forest land for the
expanded right of way. Thus, it must be consistent with national forest
plans and should complement habitat conservation efforts. This points
again to providing a high level of ecological connectivity and adequate
mitigation in this project.
Selecting Best Option
The DEIS describes crossing
structure options at 14 Connectivity Enhancement Areas (CEAs),
previously termed Connectivity Restoration Areas (CRAs). At only five of
those locations does the DEIS propose a major crossing structure—one
that provides for all species in that area—in all of the options. At
four other locations, major crossing structures are proposed in at least
one option. Designs for other locations are small culverts mainly for
hydrologic flow and associated invertebrates.
WSDOT should meet high level of
wildlife connectivity in the selected design. Of the options presented,
the Coalition supports option A at all the CRAs but one, as it generally
provides the best connectivity for wildlife. The exception is at Easton
Hill, where option B is the best choice. That wildlife crossing over the
entire freeway is important to elk and other species that prefer
overcrossings. Additional measures to the east are also needed as part
of that CRA, such as large culverts or bridges to provide both
hydrologic connectivity and crossings for animals where the highway
splits. The best approach would be a combination of B and C.
The other options do not meet a
standard that is needed in this key connective link in the Cascades. We
cannot support a project with the lower/inadequate effectiveness that
those options provide. In some locations, such as Swamp Creek,
additional connectivity measures need to be developed and included in
the preferred alternative.
The DEIS is missing a connectivity
restoration option at Kachess River. This is the lowest and easternmost
portion of the project. A major crossing structure at this CRA would
re-establish more natural riparian habitat along this stream that is
used by bull trout and other salmonids. Higher and longer bridges should
be considered, as we suggested in our letter of August 13, 2004. While
public use is an issue there, it is limited to summer daylight hours,
mostly on weekends. Design, fencing, signing, and revegetation can make
this a better crossing for both terrestrial and aquatic species. The
crossing at the road underpass a half mile to the west is not equivalent
to the Kachess River site. We urge WSDOT to evaluate both.
Also, we believe an overcrossing
at the rock knob near Keechelus Dam should be considered to provide a
second overcrossing location. Providing only one overcrossing for large
animals along the entire stretch of I-90 (at Easton Hill) does not seem
adequate to maintain genetically viable populations of species.
See attached sheet for specific
comments at each CRA/CEA.
Water Quality Needs
There are also critical wetlands
and local streams crossing under Interstate 90. These have been
constrained, blocked and even filled by the original construction.
Widening of these aquatic crossings under the freeway will ensure
cleaner waters and better habitat for fish and other aquatic species.
Threatened bull trout are in Gold Creek and threatened Mid-Columbia
steelhead spawn in the Yakima River, which parallels the freeway for
several miles. Bridges and other structures that provide natural
substrate and hydrology must be included at the 14 locations noted in
the DEIS. Fish passage must be provided in all streams where fish were
naturally found. In addition, improved wildlife crossings and natural
stream channels at Kachess River should be considered in the DEIS.
Avalanche Alternatives
The long tunnels in Alternative 1
would provide the greatest connectivity benefits and the least
environmental impact. Alternative 1 would provide an undisturbed shore
for nearly 2 miles, plus bridging and restoration at Resort Creek. Some
species may come down to Keechelus Lake for water or traverse along the
shore. Aquatic and semi-aquatic species would also benefit from this
alternative. While it is the most expensive alternative, it also
provides the best package of safety benefits. Alternative 2 is superior
to 3, as it preserves/restores more natural shoreline, connected to the
uplands, and has more effective bridges at the east end of Slide Curve,
rather than the less effective culverts of Alternative 3. Alternative 4
would have excessive impacts to the shore, riparian zone and upper
slopes and should not be chosen.
Mitigation Obligation
The project will destroy between
278 acres and 307 acres of forest, shrub and wetland habitats (the
actual amount depends on the option). These impacts, especially noise,
go far beyond the right-of way, and affect the quality of the
neighboring habitat for hundreds of meters. WSDOT must mitigate for
these impacts, not just in gross acres, but with careful consideration
of quality and location. Realignment generates substantial impacts to
surrounding forests, primarily from straightening curves in order to
increase speeds. The new wildlife bridges could reopen perhaps 15 acres
of habitat, but would not replace the lost mature forest. Reclamation
from realignment only reduces the impact by 11 to 70 acres. Thus, the
remainder, over 200 acres, still needs mitigation.
WSDOT’s commitment to no net loss
of wetlands is a minimum, and the suggested 1:1 replacement is
inadequate (DEIS 4-10). The Department of Ecology recommends ratios
ranging from 1.25:1 (Category IV) up to 6:1 (Category I) depending on
the category of wetland. On a straight gross acreage calculation, the
project will remove 12-17 acres of wetlands. A rough calculation for
Category I, II, and III, would require a mitigation obligation of more
than 20 acres. Since the new crossings will provide no more than 15
acres of unknown quality, there still remains a mitigation obligation
for wetlands. In addition, the expanded freeway ROW will take lands that
were acquired recently by the Forest Service with appropriations from
the Land & Water Conservation Fund. These lands need to be replaced. The
EIS should identify the lands and propose replacements as an offsite
mitigation opportunity.
Excellent candidates for
mitigation and LWCF replacement lands can be found near major
connectivity structures. At Gold Creek and Mardee Lake, bull trout
habitat, mature forest and quality wetlands are available but currently
are at risk. Mature forest north of Swamp Lake and riverine habitat near
Crystal Springs is also available, but also at risk. Near the Yakima
River and west of Lake Easton, wetlands, river shoreline and young
forests could be conserved. We urge you to move quickly on these offsite
mitigation opportunities and protect these lands before they are lost.
There are also opportunities to improve the habitat in the upper end of
Keechelus Lake, where seasonal flooding could be replaced with more
productive forest and wetland habitats. These mitigation opportunities
should be considered in the EIS.
The EIS suggests the use of
various techniques to slow flood runoff, capture sediments, reduce
pollutant discharge into the water, and reduce erosion. These are all
necessary. The project must meet a high level of protection for water
quality, not just minimum standards.
There are many other issues that
are addressed in the DEIS, including effects on recreation and historic
resources and visual and noise impacts of the project. These are serious
issues and we urge you to properly analyze and mitigate for those
impacts. For instance, despite substantial impacts, WSDOT proposes no
substantive mitigation for the effects of noise on recreation and
wildlife. While these need greater attention, we will not go into detail
on those issues in this letter.
Safety
Wildlife bridges and associated
structures (retaining walls and fences) will reduce the risk of
collisions between vehicles and animals.
WSDOT is familiar with the
national statistics showing that thousands of motorists are injured
annually in collisions with large animals. Scientists state that over a
ten-year period in just this 15-mile project area, over 240 elk and deer
were hit by motorists. The DEIS (3-155) notes reported accidents. But
this does not count the many collisions that go unreported, animals that
are injured and die undetected in the forest, or collisions with animals
of other species. Even the swerving to avoid a large or small animal can
cause an accident. Clearly, improving wildlife connectivity will improve
safety.
Incorporating retaining walls is
an excellent technique to reduce the chance of animals getting onto the
roadway. Retaining walls will also yield many other benefits, including
reducing impacts on adjacent forests, wetlands and other habitats by
minimizing the width of the fill slope.
Benefits to the Economy
I-90 Snoqualmie Pass East provides
substantial benefits for both the central Cascades ecosystem and the
region’s economy. The project will relieve congestion, improve safety,
and provide extra lanes for trucks. With effective ecological
connectivity, we are afforded greater flexibility in land and wildlife
management. By choosing a design like option A, WSDOT would demonstrate
that ecological and economic objectives alike are important to this
state, and both can and should meet a high standard.
DEIS Issues
We wrote previously about the
limited range of alternatives (or options, which serve the same role
under NEPA). Decision-makers need to understand the full range of
alternatives and their associated impacts and effects to make an
informed selection of a preferred alternative. Currently, the upper
range of wildlife connectivity is not included. Under the best options,
no more than 20% of the freeway will be permeable. From Keechelus Dam to
Easton, that drops to between 2% (C) and 8% (A). |
