Washington DOT's Corridor Program
The I-405 Corridor Program was led by Washington State DOT (WSDOT) with four other "co-lead" agencies — FTA, FHWA, King County (representing both King County Metro, the county-wide bus transit operator, and the county highway department), and Sound Transit, the regional transit agency. A formal organization was established, with a three-level committee structure composed of political, citizen and technical (transportation and resource agency) representatives.
The intent was to combine planning for corridor-wide transit and highway improvements with the preparation of a "programmatic" or first-tier EIS meeting requirements both for NEPA and for SEPA (the Washington State Environmental Policy Act). It was understood that the program would result in definition of a "preferred" set of highway and transit "projects." These individual projects could then proceed to project development, including preparation of second-tier, project-level EIS documents as needed and appropriate. The state and federal resource agencies would sign off on the preferred set of projects, but would still be able to comment on the second-tier EIS documents before issuing permits for individual projects later on, when greater design detail was known.
The Corridor Program, now complete, had a specific set of goals including products, time-schedule for completion, and budget, but was undertaken in the context of a longer-term intent to enhance cooperation among transportation and resource agencies in an improved decision-making process.
Challenging corridor. The I-405 Corridor is a 30-mile long, highly developed urban-suburban corridor on either side of the existing I-405 freeway. The I-405 freeway was originally built to the east of Lake Washington to bypass the congested I-5 freeway, which runs through the heart of Seattle on the west side of Lake Washington. The corridor is topographically constrained by Lake Washington, by high and long glacial ridges, and by the urban development already in place. I-405 has some of the highest congestion levels in the state, lasting 8-12 hours per day, and traffic is projected to grow 56% by 2020, driven by densification within the corridor and suburban growth to the east. The corridor passes through two major watersheds and some smaller ones, each with lakes and streams containing fish species recently listed under the Endangered Species Act. There is great public debate about solutions to the congestion, and even more controversy and doubt about funding for possible solutions.
Formal structure to manage the technical Work, public involvement and decision process. Oversight of the I-405 Program work effort was established through a three-level committee structure:
- An "Executive Committee," made up of elected officials from the local jurisdictions and the State Legislature; and meeting about quarterly throughout the three-year process.
- A "Citizens Committee," composed of appointed individuals representing business, neighborhood and special interest organizations; and meeting about every two months. Many of the individuals on this committee were politically powerful.
- A "Technical Steering Committee" composed of staff representatives from the five co-lead agencies, local governments in the corridor, and the state and federal resource agencies.
The technical work of preparing alternative long-term programs of highway and transit improvements for the corridor for evaluation by the committees, and preparing the programmatic EIS documents, was accomplished by a combination of WSDOT staff and consultants. This work was overseen at weekly meetings of the Project Management Team, composed of staff representatives from the five co-lead agencies — WSDOT, FTA, FHWA, King County and Sound Transit.
Structured public involvement program. Over the course of the three-year effort, the I-405 Corridor Program conducted 95 formal committee meetings (which were open to the public); held 9 special public meetings, (including open houses and public hearings on the EIS); published and distributed 8 program newsletters to residents of the corridor; had almost 150 speaking engagements with public groups; published news monthly on the program web-site; had more than 100 news stories in the print and broadcast media about the program efforts; conducted a 1200-person public opinion survey; and sent regular program updates to city, neighborhood, business and special interest groups. About 25% of the $7 million budget for consultant services went to public involvement activities.
Environmental goals. In response to the community's strong environmental ethic, broad environmental goals were established to:
- Integrate transportation and environmental (habitat protection) investments;
- Use a watershed-based strategy to achieve the greatest environmental benefit; and
- Support Washington Growth Management Act objectives.
To achieve these goals, the Corridor Program determined that it would need to:
- Work closely with partners from the resource agencies, tribes and local governments;
- Identify environmental resource protection needs and issues;
- Look for opportunities to address/avoid project impacts in advance of construction; and
- Where possible, remedy previous actions having negative impacts on the environment.
In response to those goals, the "preferred alternative" included projects to restore fish habitat in a number of major streams previously hurt by development, as well as inclusion of habitat protection actions as part of any new construction projects.
Multi-modal alternatives. Both transit and highway agencies were involved as co-lead agencies, and a broad range of highway and transit alternatives to meet the corridor's travel needs were explored.
The final set of projects that were selected as the "preferred alternative" included not only construction of 170 new lane-miles of highway, but bus rapid transit (BRT) through the major north-south portion of the corridor, with 11 BRT stations, 400,000 additional annual hours of bus service, completion of the existing planned HOV system on I-405, funding for a transportation demand management (TDM) program, construction of 5000 new park and ride spaces and 6 transit centers, funding of 1700 new van pools, construction of 11 direct access ramps to facilitate bus and HOV access to HOV lanes, and consideration of congestion pricing actions.
Concurrence and consensus points. The I-405 Corridor Program required 24 "concurrence agencies," including the state and federal resource agencies, to formally sign their agreement at three "concurrence" points. Those points were the final Purpose and Need document, the list of alternatives to be included in the EIS, and the preferred alternative and mitigation concept. In addition, all 35 agencies were asked to informally give agreement at another nine "consensus" points, which were typically draft chapters of the EIS, approval to publish the Draft EIS, etc. Not all of the consensus points were approved unanimously.
WSDOT had previously undertaken corridor studies involving alternative highway investment strategies, with some consideration of HOV and transit, and generally in connection with a project-level EIS. However, this was the first effort to truly evaluate alternative long-term, multi-modal transportation investment programs at a programmatic EIS level. This was also the first effort at full partnering with the resource agencies during the corridor planning process, rather than at the project development stage.
The primary motivation was to find a way to get decisions made. In a corridor with high and growing congestion levels, great controversy among elected officials and the business community about the best solution, and divided responsibility for decision-making among even the transportation agencies, something different was called for. This corridor includes the high density of downtown Bellevue, with a regional mall and several major high-rise office buildings; the office-park development of Microsoft; the office, commercial and light industrial developments in Redmond, Renton and Kirkland; and some new and growing communities to the east. No agreement existed on how to approach decisions, and when the new Endangered Species Act listings included a number of fish species indigenous to the corridor, another layer of complexity was added. The result was "Reinventing NEPA" in the form of the I-405 Corridor Program.
In just under three years, the I-405 Corridor Program developed alternative multi-modal investment strategies; evaluated their impacts, costs and feasibility with the resource agencies, local governments and the public; prepared a programmatic EIS; held public hearings and adopted a preferred alternative; established a tentative approach for funding of (some) of the program; reached agreement with the resource agencies, including a new mitigation concept that involves restoration of fish habitat in advance of construction; made commitments to tribal agencies on fishing rights; and achieved a Record of Decision on the first tier EIS.
How Change Was Achieved
WSDOT believes that the formal organization and public involvement was critical to the process. Without that organization and public scrutiny, it would have been more difficult to gain the timely actions and approvals of the 24 "concurrence" organizations and the 35 involved agencies. When faced with the "immense political importance" of the program, agencies assigned the appropriate high-level staff needed to get work done and decisions made.
Another major factor for the resource agencies was the commitment of WSDOT to fund mitigations, not only for the new program, but also for restoration of some key habitat lost in urban development and transportation projects during years past. The opportunity to achieve those benefits eventually outweighed initial concerns that giving concurrence to the total program now would undermine their ability to fairly assess project level EIS documents in the future. The resource agencies also liked the early involvement, and the direct contact with the local government representatives.
Because of the special nature of this program, there is still some question about how much real, long-term change will occur in the transportation agencies, including WSDOT, with resource protection at the forefront during transportation planning. Current funding shortfalls mean that the transportation development programs of most agencies have slowed or stopped, and so it is difficult to gauge how much carry-through (and carryover to other projects) will occur.
One of the challenges grew out of the formal organizational structure — there were many complaints by participants about the number of meetings. Some participants, including the resource agencies, complained that it was too time-consuming, too "top-heavy" with meetings, too politicized, and not technically rigorous enough. While granting that there were a lot of meetings, WSDOT felt that the formal organization and the resulting public spotlight is what kept the process moving and ultimately got decisions made. WSDOT also acknowledged that the design level achieved for the program of projects was "less than 1%" but felt that was appropriate for the first tier, programmatic EIS.
Getting unanimous agreement from the resource agencies at the three concurrence points proved to be a major challenge. For example, there was great concern that approval of the program of projects would bias future evaluation of project level environmental analyses. They were also asked to agree to not re-visit any of the concurrences unless there is substantial new information or substantial changes in the program. There were "some white knuckles" for resource agency staff members who had to sign their name with only limited direction/approval from their policy boards (or from their top agency appointed heads, in the case of the federal agencies).
"The costs of delay are enormous! Get the key people, including the resource agencies to the table as early as possible."
Mike Cummings, Environmental Planning Manager
Getting decisions on a multi-modal transportation development program for the I-405 Corridor was the major aim, and it was achieved — a great benefit to all of the agencies affected.
Another benefit was the agreement to include habitat protection and other environmental resource protection actions within the overall program, after looking at the needs on an area-wide and programmatic level, well before project level decisions begin.
"The process shouldn't be so politicized that legislators are giving direction before the technical analysis has been completed."
Virginia Gunby, Board Member,
1000 Friends of Washington
Some environmental public interest groups were critical of the I-405 Program process, claiming that WSDOT did not involve them in the way they involved other community members, such as influential business people. They also contended that elected officials on the committees used their position to overrule the resource agency staff, and that the level of technical analysis was insufficient. They were concerned that WSDOT might give only lip service to the follow-on project level environmental documents, and will implement a many projects with only an EA. They feared that the agreements on advance habitat protection would be the first to go due to funding shortfalls.
WSDOT asked the formal committee members about their thoughts on the lessons learned, and the members offered the following suggestions:
- Resource agencies would like to see a better balance of early involvement and the draw-down on agency staff time (content and volume). They questioned whether there was value added throughout the entire three-year process. They would like to see agency issues prioritized better.
- Some on the Technical Steering Committee would like to see the concurrence points require only a super-majority, not be unanimous. They also felt that it took too long to get the right people to the table. Top-level involvement and support throughout would have avoided some problems near the end.
- It was strongly suggested that someone to represent the resource agencies sitting on the Project Management Team would have helped communications.
WSDOT staff said:
- Keep it simple
- Do it as fast as you can, so that the people assigned don't change
- Get the right people to the table to begin with
- Personal relationships matter a lot
- Have some fun along the way
The next step for the I-405 Program depends upon the programming of funds for the individual projects, and moving into the project level EIS and design work.
A question remains about the status of the overall approach used in the I-405 Program — will it be applied in a broader way to other transportation planning programs being used by WSDOT and the other agencies? The answer to that question is not clear because of the financial uncertainties currently surrounding the entire WSDOT program.
For further information
WSDOT Urban Mobility Office
401 Second Avenue South, Suite 300
Seattle, WA 98104-2887
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For questions or feedback on this subject matter content, please contact Jody McCullough, Dave Harris, or Bruce Bender.