In these comments I will show that this set of "reasonable" alternatives is incomplete: It is at least as reasonable to consider (that is, rigorously explore and objectively evaluate) alternatives that would provide less than 14 freeway lanes, in combination with additional transit and/or demand suppression through better land use.

I should emphasize that I am not attempting to perform my own rigorous exploration of these alternatives. Therefore, the specific assumptions and numbers in this document should not be taken as definitive. (For convenience, many of the assumptions and numbers are taken from the EIS itself. This does not imply that I agree with these assumptions and numbers.) Rather, my purpose is merely to conduct a preliminary analysis to determine what is "reasonable," that is, what alternatives merit further study.

Transit Capacity

Based on a number of brief calculations and analyses, the EIS estimates the "maximum reasonable future transit ridership" in the north corridor to be 3340 persons per hour (peak hour, peak direction) in the year 2020. This number is selected as the largest of five separate estimates (see Table 2-7). Specifically, it is obtained by the "financial constraint" method, which attempts to determine the greatest transit capacity that UTA could provide with foreseeable resources (see page 2-13). In response to this estimate, I will show that it is not hard at all to arrive at a much higher estimate. All of the figures that follow apply to peak-hour, peak-direction travel.

The current capacity of UTA buses in the north corridor is 1560 passengers. Most of UTA's funding currently comes from a sales tax of 0.25%. Even at this level of funding, the projected 70% growth in the economy by the year 2020 would presumably yield a 70% increase in UTA's revenue, allowing it to increase its bus capacity by 70%, to 2650 passengers. However, all three counties in the region (Weber, Davis, and Salt Lake) are about to vote on a proposed doubling of the transit tax to 0.50%. (In Salt Lake County, a small portion of the increase would go not to UTA but to highway construction. However, it is reasonable to assume that by 2020, UTA will receive a full 0.5% in all three counties, possibly more.) A doubling in revenue should allow UTA to double its capacity in 2020 from 2650 to 5300 passengers. Please note that this number is signifantly greater than the number 3340 obtained in the EIS. Apparently, the authors of the EIS did not allow for any significant increase in UTA funding, despite the fact that there is currently widespread support (especially in Davis and Weber Counties) for such an increase. Please also note that the statement on page 2-15 that UTA has "reached the limits of its resources" is irrelevant because it is very likely that these resources will increase significantly by 2020, perhaps much sooner.

The numbers in the previous paragraph, however, are for bus transit. At this time, it appears quite likely that most of the expansion in transit service in the north corridor will be in the form of commuter rail. According to page 2-5, the average operating cost of commuter rail in the U.S. is $6.08 per passenger trip. The corresponding number for express bus service is not given in the EIS, but if the current fare of $2.00 each way represents 20% of the operating cost (as fare revenues do on average within the UTA system), we obtain an estimated operating cost of approximately $10.00 per passenger trip. Furthermore, passengers can reasonably be expected to pay higher fares for the more comfortable rail service. Assuming a one-way rail fare of $3.00, the additional revenue required to operate commuter rail is apparently only about $3.00, compared to $8.00 for buses (per passenger trip). This estimate seems reasonable given that operator salaries are UTA's major operating expense, and fewer operators per passenger are required for commuter rail than for express buses. Of course, local buses will still be needed to provide connections to commuter rail for many passengers. Still, it seems reasonable to expect that a shift from bus to rail service could increase UTA's capacity in 2020 from 5300 passengers to approximately 10,000, given the same revenue assumptions as in the previous paragraph. If further revenue sources are found, the maximum capacity could be even higher.

This analysis is not meant to imply that the entire capacity of 10,000 passengers would in fact be provided by commuter rail. (However, six trains per hour, with ten cars per train and 150 seats per car, would provide a capacity of 9000.) To serve southern Davis County, UTA has suggested that an additional light rail line might be feasible in the not-too-distant future. Express buses operating in HOV lanes would also be an attractive transit option for some commuters. My point is simply that the "financial constraint" calculation at the bottom of page 2-13 gives an answer that is too low by at least a factor of 3.

While discussing financial constraints on transit, let me respond to a claim made in Appendix Q (in response to comments on the DEIS). On pages Q-16 to Q-17 it is claimed that "...UTA indicated that it could not financially support any greater transit investment than what is identified in the FEIS." The reader is then referred to a letter from John Inglish in Appendix J. However, the letter itself makes no such statement. Rather, it merely says that UTA "supports the shared solution" and that UTA can "accomodate its [10%] share of demand" expected by the build alternatives in the FEIS. There is no hint in the letter of the maximum demand that UTA could accomodate.

The claim that UTA cannot possibly provide the capacity needed to make Legacy unnecessary occurs in several other places in Appendix Q. However, no verifiable basis for this claim is ever offered. UTA is constrained by operating expenses, not capital expenses (which can mostly be obtained from the Federal Government). As I have demonstrated above, it is entirely reasonable to expect that by 2020, UTA will have enough revenue to operate a system with a capacity of approximately 10,000 passengers per hour (peak hour, peak direction) in the north corridor.

Transit Ridership

The remaining estimates that are summarized in Table 2-7 attempt to predict actual ridership rather than merely capacity. The first two estimates are fundamentally based on surveys conducted in 1992 and 1993. Obviously, using survey data to predict people's behavior 27 or 28 years in the future is problematic. Public attitudes toward transit have changed significantly already, as shown by a recent scientific poll conducted by the Ogden Standard-Examiner (reported on Sunday, August 6, 2000). This poll (of residents living from Farmington north) showed not only that 2/3 of respondents would be willing to pay for improved transit with a sales tax increase, but also that 1/3 of those residents who work in Salt Lake County say they would ride commuter rail daily (more than 20 times per month). An additional 30% of those who work in Salt Lake County said they would ride commuter rail between five and 20 times per month. While it would be premature to apply these percentages directly to the travel demand numbers in the EIS, the same could be said of the 1992 and 1993 survey data used in the EIS. In any case, the transit use predicted by this poll is obviously far greater than that predicted by the EIS.

Admittedly, commuter rail will probably be less attractive to residents of south Davis County, which was not covered by the Standard-Examiner poll. However, the Legacy Parkway would also be unattractive to those residents, since many of them would have to drive west through considerable city traffic to get to it. Furthermore, light rail could be a very attractive alternative for south Davis County.

Even if we had much more extensive data on current attitudes and behavior, it would be difficult to predict, by extrapolation, how people will behave under very different future conditions. For example, by the year 2020, traffic congestion within Salt Lake City will inevitably be much worse than it is today. Parking in the central business district, at the University of Utah, and at the airport will be more expensive than currently. Gasoline prices will probably increase more quickly than average vehicle fuel economy.

Another significant change that will affect future transit ridership will be the much-improved service by the year 2020. The current bus transit system has many drawbacks, including the extreme slowness of the local routes (one hour and 40 minutes to get from Ogden to Salt Lake City), the congestion on I-15 encountered by express buses (especially since there is currently no HOV lane), and the almost total lack of express service at mid-day and at night (which limits commuters' flexibility in case of emergencies). By 2020, the transit system will offer options that avoid all these drawbacks; the anticipated revenue increase will allow UTA to offer much more frequent service than one would predict based on "historical growth trends" (page 2-12). And, of course, commuter rail and light rail are inherently more attractive to commuters than the current bus system. With all these effects working together, it seems extremely unreasonable for the EIS to dismiss the possibility of transit carrying 10,000 commuters per hour by the year 2020. In any case, the question seems worthy of a rigorous exploration and objective evaluation.

The last two ridership estimates summarized in Table 2-7 are based on recent experience with Salt Lake County's TRAX light-rail system. However, the first of these estimates, "TRAX minimum," is apparently an estimate of new ridership, not total ridership, and is therefore not directly comparable to the other numbers in the table.

Even the "TRAX maximum" estimate is hard to evaluate, however, because the assumptions behind it are either inconsistent or are not fully explained in the EIS. First of all, the projected ridership of 23,000 is for the year 2010, not 2020. Second, the uncertainty in this projected ridership is not stated; we are told only that current peak-hour ridership is "nearly equal to predictions," whatever that means. Third, it is not clear whether the "peak-hour factor" is based on actual ridership or is merely a guess. Fourth, it is not clear what region is considered to be the "TRAX corridor" in the estimate of vehicular travel. Finally, it is unclear what financial constraints (and hence, frequency of service) are assumed in the ridership estimate.

The current daily TRAX ridership, if I'm not mistaken, is 19,000. One might expect this number to increase by at least a few thousand after the planned extensions to the University of Utah and the airport are completed. Further increases over the next ten years would be expected due to growth in population and employment. Thus, it would seem that the estimate of 23,000 for the year 2010 is almost certainly too low.

On the basis of geography alone, one would expect a rail transit system in Davis and Weber Counties to be more successful than one in Salt Lake County. As the EIS repeatedly points out, southern Davis County is linear in shape, with a two-mile-wide bottleneck at Farmington-Centerville that everyone must pass through. This geographical arrangement is much more conducive to rail transit than Salt Lake County, where the urbanized area is more than ten miles wide. Furthermore, TRAX does not extend far enough south to be useful to those who commute from Utah County. By contrast, a commuter rail system extending into northern Weber County would cover essentially the entire region from which commuters enter the north corridor each morning. Supplemented by a light rail line in southeastern Davis County, such a system could easily attract far more than the ten percent portion of peak travel projected for TRAX.

Effects of Land Use Changes

In response to comments asking for an analysis of land use elements that would lessen travel demand, the FEIS states, "Because we have no authority over land use planning ..., it is difficult, if not impossible, for us to control what land uses will occur..." (page Q-70). However, the NEPA regulations in 40 CFR 1502 stipulate that an EIS must "include reasonable alternatives not within the jurisdiction of the lead agency." The EIS also argues that it is unforeseeable that any government entity would adopt such land use elements as policy. As a counter-example, I would like to point out that Mayor Godfrey of Ogden has recently announced a major initiative to bring more employment and more residential units to downtown Ogden. While it is too early to judge how successful this initiative will be, it is certainly within the realm of possibility that, within the next 20 years, not only Ogden but also many other communities along the Wasatch Front will decide to invest in their older, high-density neighborhoods rather than building only on the suburban fringe.

Even without a conscious effort on the part of planners to encourage land uses that would lessen travel demand, such land use changes will occur automatically once the planned commuter rail system is in place. Each commuter rail stop will inevitably become an economic center where land values increase and therefore higher-density development (both commercial and residential) takes over. Although it is possible that some local governments will actively oppose this kind of development, it would seem reasonable for the EIS to analyze a scenario in which they do not. Yet I can find no mention in the EIS of the effect of commuter rail on land use. Most of the planning studies listed in Section 1.1.4 date from a time when commuter rail seemed much more speculative. Furthermore, there is no mention in the EIS of local planning studies from Weber County or from municipalities in the northernmost part of Davis County, where many potential commuters live.

The analysis of the effects of the Legacy Parkway on land use (in Section 4.1.3) appears to be similarly limited to southern and central Davis County; there is no mention of consultation with any Weber County planners. Yet again, many of the potential users of the Legacy Parkway would live in Weber County. It would seem reasonable to suppose that development in Weber and north Davis Counties would occur farther west if Legacy is built and farther east if commuter rail is built, yet the EIS does not address this question. Even more significant may be the effects of Legacy vs. commuter rail on Salt Lake County. Legacy would provide easier access to the airport area, while commuter rail would provide easier access to the central business district. The rate of economic growth in these two areas will almost certainly be different depending on whether we build Legacy, commuter rail, or both.

Thus, even if (as the EIS claims) land use in the 14-mile corridor from Farmington to North Salt Lake is the same in all conceivable alternatives, this fact would not imply that travel demand in the year 2020 is the same in all alternatives. In an alternative that includes a major investment in transit and no Legacy Parkway, existing urban centers can be expected to grow faster while western Weber and Salt Lake Counties can be expected to grow more slowly. In such a scenario, an ever-greater percentage of commuters would find transit to be more convenient than driving. Furthermore, economic development near commuter rail stations (especially in downtown Ogden) may very well make more jobs available in these areas, thus lessening the need for residents to work in Salt Lake County.

Incidentally, the claim that the Legacy Parkway would have only a "minor" influence on commercial growth within the study area because it would be a limited-access highway (page 4-13) is obviously false. I-15 is a limited-access highway, yet there is a large commercial district at nearly every interchange in Davis County. Surely the proximity of these commercial districts to the freeway is not a coincidence. Similarly, the recently proposed "Grand Mall" would have been located at the planned intersection of I-80 with a future (proposed) segment of the Legacy Highway. Coincidence? I don't think so.

However, even if land use throughout the Wasatch Front would be exactly the same in all conceivable alternatives, people's choices of where to live and where to work would still be affected by the availability of transit, the availability of the Legacy Parkway, or both. If neither is built, it is likely that people would try to live nearer their jobs or to work nearer their homes. If a good transit system is built, people will be more likely to commute long distances if both home and work are near transit stops. And if the Legacy Parkway is built, people who work in western Salt Lake County will find it more attractive to live in Weber and north Davis Counties, and vice-versa. The vast majority of those who will be in the workforce in 2020 will be either choosing a first home or choosing to move to a different one between now and then. The way they make these choices will certainly have a significant effect on the travel demand estimates used in the EIS.

Yet the only attempt in the EIS to estimate how travel demand might depend on which alternative is realized is the two-page "latent demand analysis," Section 1.6.4.4. This section does not consider how different alternatives might affect land use, nor does it consider how different alternatives might affect people's choices of homes and workplaces. The section assumes that all these variables are fixed, and then calculates daily travel demand in a no-build scenario and in an "unrestrained" scenario. Neither scenario includes a major investment in transit; in fact, the results do not even report the variation in transit ridership between the two scenarios. Furthermore, the results are stated only in terms of total daily travel demand, not peak-hour demand, so it is very difficult to estimate the effect of "latent demand" on the peak-hour figures used elsewhere in the EIS.

Instead of this extremely superficial analysis, the EIS should rigorously explore and objectively evaluate how the total travel demand varies in all reasonable alternatives, including a transit-based alternative. The effects of alternatives on land use and choices of homes and workplaces should be included in this evaluation.

Criteria for Exclusion of Alternatives

In Chapter 2 of the EIS, several possible alternatives are briefly considered and rejected because they apparently cannot meet the projected unmet travel demand of 10,410 pceph (passenger car equivalents per hour) given in Figure 1-6. A transit-based alternative (instead of the Legacy Parkway) is rejected on page 2-16. An alternative including widening I-15 but not building Legacy is rejected on page 2-40. Alternatives based on land use are rejected for the same reason on page Q-6. I would like to make two comments on this general method of excluding alternatives from further study.

First, based on this criterion, all of the "build" alternatives should also have been excluded from further study, because none of them, according to Figure 2-4, meet the full projected peak-hour travel demand; all result in a remaining unmet demand of 2305 pceph. Thus, the true criterion used to exclude alternatives from further study seems not to be the ability to meet the full projected demand. It would be useful, I think, if the EIS included a clear statement of what the true criterion was.

Second, while transit, land use, and I-15 widening were each rejected individually based on their apparent inability to meet the full projected travel demand, combinations of two or all three are nowhere considered. For example, Table 2-3 calculates what percentage of people would have to ride transit if it were to fill the entire projected unmet demand by itself; there is no calculation of the comparable percentage if land use and/or I-15 widening were also included. Similarly, it is claimed on page 2-40 that widening I-15, by itself, would be "unlikely" to result in "any advantages whatsoever ... compared to the extreme cost to travelers," yet there is no discussion here of whether additional transit or better land use might change this conclusion.

The Legacy Parkway itself is only a minor component of the "shared solution" proposed in the EIS, with a full capacity, at LOS D, of only 3970 pceph (16.5% of the total projected demand). Based on the factors mentioned earlier in these comments, it seems quite likely that this 16.5% could be absorbed by better transit combined with better land use. Therefore it seems entirely reasonable for the EIS to consider an alternative that does not include the Legacy Parkway but does include a major investment in transit, a shift in land use toward higher density development around commuter rail stations, and (if necessary) widening I-15. Because the EIS does not include such an alternative, it appears to be in direct violation of the requirements stated in 40 CFR 1502.

[CFR = Code of Federal Regulations]
[LOS D = level of service D, at which there is little slowing due to congestion]

September, 2000.