On this final day of public comment on the Arkansas Highway
and Transportation Department's
plan to widen Interstate 30, Mayor Mark Stodola
and City Manager Bruce Moore
have provided the AHTD with recommendations based on an assumption the proposed alternatives — 8 lanes or 10 — will be acceptable to the city.
The letter is stronger, however, than some might expect. It includes many of the recommendations made by city consultant Nelson\Nygaard
and concludes that "based on our assessment, it is our determination that the proposed alternatives need further improvement so that they will not place a substantially negative impact on downtown; and, at a minimum, those alternatives must include the elements described above if a FONSI [Finding of No Significant Impact] is to be issued."
The AHTD cannot go forward with the project until the FONSI is issued.
City Director Kathy Webb,
however, in an attached letter, says the city is jumping the gun by saying its comments apply to the "environmental assessment" stage of the project, and suggests that the AHTD give attention to research by Norm Marshall
of Smart Mobility, which was paid for by a citizens' group.
Among the points made in the city letter are:
— The removal of the Second Street exit is an improvement over original plans.
— The 30 Crossing Project Purpose and Need should include "the needs of Downtown Little Rock" related to pedestrian safety and preservation of community character. (To my mind, that doesn't ask the AHTD to act on those needs; only to state them in the Purpose and Need.) The letter does, however, express concerns with the ATHD's failure to account for induced traffic, and says, "It is recommended that the analysis recognize that the programmed roadway changes will only help to manage (not solve) traffic congestion and that, as a result, driving toward an inaccurate level-of-service outcome will not achieve what is best for both 30 Crossing and Downtown." Will that catch the eye of the Federal Highway Administration in its review of the comments?
— The safety analysis should consider the project's impact on city streets. "It is recommended that the impacts to ALL system users be fully accounted for in selecting alternative design elements; and that elements such as high-speed, one-way surface streets be re-evaluated in light of the full needs of downtown." This in reference to the 10-lane plans to bring collector distributer lanes into the city at Fourth Street and make Fifth and Sixth major thoroughfares to access Cumberland to La Harpe. The letter says the C/D lanes should be designed as two-lane city streets, with no auxiliary lanes (which is how the interstate grows to 12 and 15 lanes at points), for safety reasons.
— The alternatives should be "sensitive to irreplaceable natural, historic and cultural resources and valued park space." I'm sure the AHTD Environmental Assessment will say they already do.
— The Sixth Street and Ninth Street bridges should be wider and deeper for landscaping to make the interstate disappear to pedestrians crossing the bridges. This, too, was a recommendation of Nelson\Nygaard.
You can read the full letter, plus Webb's attachment, here.
Webb has also posted on her Facebook page a letter she wrote independently to the AHTD. You can read it on the jump. She asks that additional alternatives to the 8-lane and 10-lane plans be considered, and says that the project deserves a full Environmental Impact Statement rather than an EA. She also quotes from Samuel Schwartz's "Street Smart":
“If you build more lanes on the expressway, more cars and trucks will use it. If you’re lucky, congestion remains as bad as it was before you spent $50 million trying to relieve it; if you’re not, it gets worse. It’s like the Red Queen from the other side of the looking glass, who tells Alice, “Here, you see, it takes all the running you can do, to keep the same place. If you want to get somewhere else, you must run at least twice as fast as that!"
Comments submitted to AHTD
Thank you for reading and considering the following comments. I appreciate the modifications you have made to the proposed project since it was first shown to the public, and urge you to consider additional alternatives rather than those presented at the April 26 meeting.
Like many citizens, I have attended a number of meetings, read numerous articles and reports, and visited with citizens who hold a wide range of perspectives. However, the more research I have done and the more I listen to experts, the more I am convinced the April 26 proposals are wrong for us. Hundreds of citizens have contacted me concerning the 30 Crossing Project, most opposed to the current options. Four neighborhood associations in Ward 3 passed resolutions opposing the project; Capitol View/Stifft Station, the Heights, Hillcrest, and Kingwood.
The needs of Downtown Little Rock are not sufficiently addressed as the project stands. As the group of consultants hired by the City state, the needs of downtown Little Rock are not sufficiently addressed in the proposal. The area studied by the AHTD should be expanded to include a larger geographic area of downtown, as well as the economic impact of the proposal. Knowing the traffic and congestion impacts are a “must.” Currently, the AHTD says one of five purposes of the project is to improve mobility on I-30 and I-40. That means, mobility anywhere else is the city's problem, leaving the city to deal with the impact. Paul Moore and Scott Polikov, part of the Nelson/Nygaard group of consultants hired by the city, stressed to the City Board that we should “push back” against the AHTD on the number of lanes, because of the potential impact on the city.
It is also critical that the Highway Department consider induced demand and factor that into the equation. Norm Marshall from Smart Mobility, hired by a group of concerned citizens (of which I was part), would be an excellent good resource for that. Samuel I Schwartz, in his book STREET SMART, says that “If you build more lanes on the expressway, more cars and trucks will use it. If you’re lucky, congestion remains as bad as it was before you spent $50 million trying to relieve it; if you’re not, it gets worse. It’s like the Red Queen from the other side of the looking glass, who tells Alice, “Here, you see, it takes all the running you can do, to keep the same place. If you want to get somewhere else, you must run at least twice as fast as that!" (page 45 STREET SMART)
Given the proposed scope of this project, I believe it will, with near certainty, require a full Environmental Impact Statement (EIS) not merely an EA. While I didn't live here in 1991, I know there was a federal lawsuit against the city on the issue of EIS and EA, as it pertained to Jimerson Creek and the widening of Rebsamen Park Road. The judge ruled against the city and the Army Corps of Engineers; the lower court was upheld when the city and Corps appealed to the 8th Circuit in St. Louis (note: this case is used in law schools around the country as a case study on when an EIS is required). The proposed 30 Crossing is a significantly larger project, with a significantly larger impact.
Citizens have donated 100’s of hours, attending meetings, coming up with ideas, all for no compensation. I applaud all of these individuals and groups, from Tom Fennell and Fennell Purifoy Architects, to the Arkansas Public Policy Panel, the Coalition of Little Rock Neighborhoods, StudioMain and others.
I hope that we will pursue alternatives to the current proposals. As the AHTD has met with citizens and listened to input, the current plan has evolved from what was presented last year. Optional plans, presented by citizens, have evolved as well. I hope the latest iteration of the Boulevard Plan is considered by the AHTD, along with bridge improvements or replacement and other safety enhancements. As Sam Schwartz points out, in order for a community to “be alive-its streets have to welcome the widest variety of people.” (page 215) Let’s improve I-30 and our city.
City Director Ward 3