The net result is that by 2010, we will be making the best and most efficient use possible of the existing four lane I-70 facility in the Mountain Corridor.  Front Range residents' lifestyles will have become more reliant than ever before on maintaining this operational efficiency to provide some minimum level of access to the mountains.  There will be no viable option to mainline I-70 travel when highway construction begins. 

Any highway expansion construction is likely to severely compromise access to the mountains for Front Range residents and visitors, no matter when the highway construction occurs. CDOT officials should not minimize the economic and lifestyle impacts that this will have on Colorado. 

The outcome of this PEIS will have the greatest impact on those Colorado residents and visitors in their 40’s, 50’s and older.  Many of these folks are Baby Boomers who make up the primary consumer base for the western slope resort communities.  The 20 year PEIS time frame would suggest that we will not derive any substantial transportation benefit in the mountain corridor until the construction of the selected alternative is completed.  Those younger may be able to take advantage of these improvements, while those in their 40’s and 50’s will be more concerned about the next 20 years.  Their primary experience with the I-70 West PEIS will be in the next five years as congestion increases prior to major construction and then the fifteen year construction period.  Mobility during the next 20 years will be a critical factor in their lifestyles and may ultimately determine whether or not they stay in or visit Colorado.  It may also have a serious impact on the state's tourism driven economy.

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Additional Construction Impacts

The I-70 Mountain Corridor provides critical mobility for corridor residents including commuting, shopping, school, business, commerce, fire protection, medical service, police, local government and recreational access.  Lengthy periods of construction congestion and delays could cripple corridor residents, businesses and emergency services.   

While other jurisdictions are pushing for increased throughput in the Corridor to boost their resort economies, Clear Creek County and its municipalities will be trying to find a way to survive the highway construction period.  Clear Creek is not a wealthy county and its municipalities continue to struggle economically.  Clear Creek County will not likely see the economic benefits of increasing throughput to Summit, Eagle and Grand Counties, but will suffer the consequences of highway construction. 

The best PEIS solution will have as little construction disruption as possible which would rule out highway widening.

Construction in the Mountain Corridor is different than it might be in Metro Denver or other places in the country, since there are in places no viable alternative routes, (no side streets, no frontage roads, no other routes).
 

In Clear Creek County there is no alternative to I-70 between Bakerville and the Eisenhower Tunnel, between Silver Plume and Georgetown and between Hidden Valley and Kermitt's, (Exit 244).

The Draft PEIS states specifically that the residents of Clear Creek County, their visitors, businesses, governments and other institutions, and the people traveling through the county (all of them) will be affected by construction work associated with project alternatives.  It also states that localized impacts are expected to be most prominent in Clear Creek County. 

DRAFT PEIS DOCUMENT Problems

1.  Vision

The PEIS vision should produce a sustainable solution that supports the level of growth and development desired by Corridor Jurisdictions.  Corridor communities have a critical role in determining this vision as transportation capacity can stimulate or suppress growth and place greater or lesser demands on local infrastructure, (including local roads, schools, law enforcement, emergency services, physical and legal water supply, water treatment and sewer treatment facilities).  Corridor growth will also influence community character and resident’s quality of life.  The transportation solution should minimize disruption through the construction period, minimize the disturbance footprint and environmental impacts and fully utilize technology and incentives to create a viable long term solution. 

The Draft PEIS “Preferred” alternatives limit their scope to the next 20 years and do not provide a practical course for I-70 mountain corridor improvements for the next 50 years. 

Each of the “Preferred” alternatives has a larger footprint than the current highway and has a corresponding larger environmental impact.  Each of the “Preferred” alternatives is completed by 2025 and accommodates network capacity until 2030, providing only a five year effective life beyond completion. 

Each “Preferred” alternative is also based in large part on petroleum based technology that will be affected by world market oil prices.  Each of these alternatives also relies heavily on internal combustion engines that currently have very low energy efficiency rates, (20% typical).  Sustainability of these solutions will require substantial improvements in highway technology, vehicle technology and efficiency, as well as a stable world oil market to be cost effective and practical solutions throughout a 50 year period.

Our vision should provide a high level course of action for improvements over the next 50 years including alternate route development and transit and highway components.  Included in this vision should be a number of reassessment points that allow the Coalition to meet with CDOT/FHWA to review project progress, evaluate current conditions and use adaptive management techniques to reshape the vision if necessary.   

Changes in Front Range and Corridor growth, water availability and supply, development, recreation locations, traffic patterns and travel behavior will need to be evaluated to make sure that our implementation plan is still on target.  In addition, new vehicle, highway, transit, excavation, boring, or other construction or tunnel technologies may need to be considered as we review the implementation plan.  Changes in vehicle, fuel, highway, transit or other transportation or construction costs, or changes in available funding may require additional consideration.  If necessary, the Coalition and CDOT/FHWA may agree to reshape the vision based on unanticipated events or unexpected shifts in travel patterns, costs, technology, funding availability and travel behavior.    

2.  Selection Criteria used for the Preferred Group of Alternatives

The two primary selection criteria used in determining the “Preferred” group of alternatives are the following:

A. The alternative’s ability to meet the project need, (increase capacity,

     improve accessibility and mobility, and decrease congestion) which is measured by

     the alternative’s ability to accommodate projected 2025 baseline travel demand.

B.  The alternative’s ability to meet economic reasonableness as defined by a capital

     cost equal to or less than $4 billion.

The alternative’s ability to address Safety issues, Community Values, and Environmental Sensitivity were not given the same weight in the selection of the “Preferred” group of alternatives as the ability to accommodate projected 2025 baseline travel demand and capital cost equal to or less than $4 billion.  In addition, the alternative’s Environmental, Economic, Social and Mobility impacts during the Construction period and the alternative’s Health impacts to adjacent communities were not considered as selection criteria for the selection of the “Preferred” group of alternatives. 

Clear Creek County would suggest that the alternative’s Health impacts on adjacent communities, ability to address Safety issues, Community Values and Environmental Sensitivity, and the alternative’s Environmental, Economic, Social and Mobility impacts during the Construction period are just as important to the selection of the “Preferred” group of alternatives as the alternative’s ability to meet the project need and the alternative’s ability to meet economic reasonableness. 

We would suggest that this Environmental Impact Statement consider each of these items as a valid measure in determining the “Preferred” group of alternatives. 

3.  Selection Criteria needing further evaluation in Tier 1, prior to the selection

     of the Preferred Alternative

A.  Health Impacts to the I-70 Adjacent Communities for each alternative

B.  Environmental Impacts relating to each alternative during and after the construction

     period

C.  Alternative Speed, Capacity and Reliability in Adverse Weather Conditions

D.  The potential disturbance of heavy metals from 23 Historic Mill Sites within the I-70

      Right of Way in Clear Creek County

E.  Potential Impact to Section 106, (historic) & 4F (recreation & park) Properties in the

     Corridor

F.  Mobility Restrictions and related social impacts during the Construction Period for

     each Alternative

G.  Economic Impacts for each County during and after the construction period

H.  Determination of Transit Preservation Inclusion or Transit Preservation

      Nonpreclusion prior to Tier 2

4.  Transportation Planning

Transportation planning is a crucial tool for managing growth and development, however specific growth objectives are not provided by Corridor communities in the PEIS.  Instead of the Corridor communities clearly defining the type and amount of growth and development that they desire and then pursuing transportation alternatives to meet their growth objectives; the PEIS selects alternatives based on their ability to meet 2025 projected travel demand with only some general assumptions for Corridor community growth goals.

Regional Planning Organizations such as the Denver Region Council of Governments include transportation planning in their Metro Vision Plans in order to keep transportation planning in sync with growth objectives.  This does not appear to be happening in the mountain corridor.  Some communities may be looking to stimulate growth, while others may be looking to manage and control growth, and a regional consensus on growth management has not yet been determined.  Without a clear objective for regional growth management, alternative selection is difficult as each alternative differs in terms of managing, suppressing or inducing growth. 

5.  Construction Concerns

Although the Draft PEIS identifies Clear Creek County as being the most affected by the construction of the alternatives, construction impacts are still not used as a measure for determining the “Preferred” group of alternatives. In fact, all CDOT "Preferred" alternatives are in the Greatest Construction Impact group. 

In addition, there is no suggestion as to how construction of the “Preferred” group of alternatives will be scheduled.  Will construction occur year round, (except for peak travel periods) or just from May through October similar to the project schedule for the US 40 work on Berthoud Pass (to provide some relief during the ski season)?  The Draft PEIS does not even suggest any alternate means of transportation through or around the Corridor during the construction period, so it is assumed that everyone traveling to the mountains will continue to use I-70 and suffer through construction congestion and delays.

We would recommend that construction impact and mitigation strategies be disclosed in Tier 1 and included in the selection criteria for the “Preferred” group of alternatives.

6.  Bias against Transit Systems

CDOT officials have repeatedly stated that CDOT is not in the transit business.  They will not take on the operation of a transit system or pursue funding mechanisms for the operation of transit.  The title would imply that CDOT is the Colorado Department of Transportation; however they operate and determine funding streams for highway construction and maintenance, not the operation of transit solutions.  

PREFFERRED ALTERNATIVE OBJECTIVES

1.  Safety

A. The preferred alternative should make the I-70 Corridor through Clear Creek County safer, reduce the number and frequency of traffic incidents and provide improved incident management.

Clear Creek County currently contains some of the most dangerous portions of I-70 through the state of Colorado.  The county is concerned for the safety of our residents and visitors and the increasing frequency of incidents in the Corridor.  Traffic incidents overburden our emergency service resources and infrastructure and can gridlock the I-70 Corridor for hours.  Traffic incidents have a greater overall affect on I-70 congestion in the county than vehicle traffic volumes alone due to their severity and unpredictability.  Decreasing incidents may have greater potential for reducing congestion and delays than any single alternative. 

Improved incident mitigation through safety improvements and improved incident management should be a clear priority for any preferred alternative.  

B.  The preferred alternative should not overly burden county emergency resources.

I-70 incidents continue to place a significant burden on county emergency services including staff, resources, equipment and communications infrastructure.  At great expense to the county, we are in the process of expanding our 911 communications infrastructure and staff largely due to increases in I-70 incidents.  We continue to struggle to find an appropriate funding mechanism for our Fire Authority and Ambulance Department since nearly 50 percent of their calls are on I-70 and not in our communities. 

The preferred alternative must address current safety concerns and provide a potential reduction in annual emergency incidents.  A state funded reimbursement mechanism for I-70 incidents would also be desirable.

2.  Economic Impact

The preferred alternative should have a positive impact on Clear Creek County's economy. 

The initial construction of I-70 allowed travelers to bypass Clear Creek County on their way to more distant locations, (which were made closer by the new interstate highway).  With fewer visitors, Clear Creek County's economy suffered.  The new I-70 solution should contribute to Clear Creek County’s economy by providing positive views, good access to our towns and attractions including Clear Creek for rafting and fishing, the Georgetown Loop Railroad, Herman Gulch, Bakerville/Stevens Gulch and Loveland Ski Area.  It should also protect our waterways and minimize footprint expansion to protect private property in our towns and the Dumont/Lawson/Downieville area. 

3.  Protection of the Natural Environment of Clear Creek County

A.  The preferred alternative should improve water quality.

Silver Plume, Black Hawk, Golden and other Front Range Communities use Clear Creek as their water supply.  Traction sand, chemical deicers and copper from vehicle brake linings migrate into the creek and impact water quality.  Water quality can be degraded by increased highway runoff as additional highway surface is added and by construction disturbance in mineralized areas, (especially on abandoned mill sites).  Those alternatives that add highway lanes and increase vehicle traffic will have a greater impact on water quality than those alternatives that do not.

Georgetown, Idaho Springs, Silver Plume, Empire and the Clear Creek Sanitation District all discharge effluent into the creek and any increase in metal loading from highway runoff or highway construction may place greater and very expensive performance requirements on these facilities.  Increased metal loading from runoff and construction may impact Clear Creek fisheries and have a negative impact on our angler tourists.  Increased use of chemical deicers may kill surrounding vegetation and increase erosion.  The preferred alternative should require less excavation in mineralized areas for construction, less sand and chemical deicers for winter use, and utilize improved sediment control measures.

B.  The preferred alternative should minimize highway expansion outside of the current I-70.

We have waterways, residences, businesses, bike paths, parks, recreational facilities, fire stations, historic sites, wildlife areas and municipal facilities located very near the current I-70 footprint.  We also have desirable land in the corridor for future commercial, residential and Greenway growth, again located close to the I-70 footprint.  Any expansion of the current highway footprint could have a negative impact on the county and its municipalities and require the acquisition of private property.  

C.  The preferred alternative should create less Carbon Monoxide, Entrained Dust, PM-10, PM-2.5 and Air Toxics.

Residents in Clear Creek communities that surround the I-70 Corridor have been exposed to potential health risks due to entrained dust, PM10, PM2.5 and air toxics in the past.  The current I-70 highway is a significant contributor of entrained dust.  We would like to mitigate these potential health risks in the future by selecting a preferred alternative that minimizes these airborne contaminants.

D.  The preferred alternative should create less noise in Clear Creek County communities.

Noise mitigation walls on I-70 through the county would have a huge negative visual impact.  Restricting the motorists’ view of the county may also have a negative affect on visitors and tourism.  The best solution for Clear Creek county would be an alternative that simply creates less noise.  Ideally this would be less noise than exists today in the Corridor.

E.  The preferred alternative should mitigate impact to county wildlife and provide wildlife crossing areas.

A portion of I-70 in Clear Creek County borders Clear Creek Open Space Land that is home to a large population of Big Horn Sheep.  In addition to the Big Horn Sheep, the county also has large elk and deer populations that have seasonal migration patterns that cross I-70.  The preferred alternative needs to have adequate crossing areas to accommodate seasonal migration patterns for our wildlife and minimize vehicle/animal conflicts. 

4.  Downieville Weigh Station / Ports

Relocation of the eastbound and westbound ports is desirable.  Entering and exiting trucks on short entrance and exit ramps slow traffic and promote congestion.  Westbound, (uphill) trucks leaving the port create moving road blocks and a serious pinch point as they enter I-70 at significantly lower speeds than mainline westbound traffic.  Extended periods of idling trucks in and around the ports also create air quality problems in the narrow constrained Downieville canyon which creates a health concern for area residents.

5.  Greenway Inclusion

Any major construction activity in the I-70 Corridor in Clear Creek County should not only facilitate the Clear Creek County Greenway as defined in the Greenway Master Plan, but integrate it into the final solution.

6.  Rockfall Protection of Highway Lanes on Georgetown Incline