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Comments on the Interstate 5 HOV Tacoma Project

Below are my comments on the NEPA (National Environmental Policy Act) review of the current Tacoma I5 project, from August.


To: Carrie Berry, Environmental Manager I-5 HOV Team

CC: Multiple

Re: Tacoma I-5 HOV NEPA Comments

Some 2 years ago I was walking my dog near my residence, less than 2 blocks from this WSDOT project’s stretch of I-5, and noticed the almost natural grading suitable for a bike trail on the recently completed I-5 projects just to the South. As such I was inspired to restart my civic involvement starting with the analysis of the feasibility of a local connector bike trail at the periphery of I-5 between S. 38th Street and McKinley Avenue.

Presidents Ridge Bike/Pedestrian Trail

This trail concept was added to the Tacoma Comprehensive plan last year, preliminarily called ‘Presidents Ridge’ for the 3 neighborhoods it would connect, Lincoln, McKinley, and Roosevelt.(Citizen Graphic Attached) Funding for this project should come from local sources, however there are critical design and legal issues that should be addressed in the scope of this project – including one minor modification to the Pacific Avenue Bridge design, a shelf on the highway median under the bridge to accommodate trail construction.

The alignment for this trail is proposed at roughly the boundary of the controlled access area. It would be **nice** if this alignment could be justified as a maintenance access road within the scope of your current project. In any case a legal review of this route is appropriate at this time. Please note that alternative routings do exist and that these might be preserved in any enabling documents – and that any possible need for modification likely extends beyond the 2030 analysis envelope.

Pacific Avenue/Dome District Interchange/Access Point Design

The study of the Pacific Avenue interchange is completely missing from all project documents available to the commenter. This interchange is admittedly ‘supplementary’ to the I-705 access system which overshadows it, but is nonetheless still important. For framing purposes I have added access to the Tacoma Dome and Dome Business District to the suggested scope of this needed analysis. Since 1999 the 34th and Pacific area has been designated for additional density, something that will realistically occur within the temporal envelope of this analysis, as will substantial redevelopment of the Dome District itself.

I believe that left turn access should be provided from Pacific to both the North bound (‘A’ Street) and South bound ramps – this can be justified via transportation, environmental justice, and social/economic arguments.

Sound Transit has proposed blocking off one of these access points for its Sounder Lakewood extension as part of their ‘Berm’ proposal, the intersection of ‘A’ Street and 26th. I believe this ST proposal requires access modification approval and this process provides a timely way to accomplish that review. Please note also that additional delay of this ST project may have construction timing impact benefits should the two disruptions of Pacific Avenue overlap. The benefits of this overlap should be studied.

I also believe an additional off ramp should be provided just to the North of McKinley Avenue providing direct access to Tacoma Dome parking, mitigating on street congestion created through existing in-direct routes. I also believe it **may** be feasible to create a northbound on-ramp at McKinley Avenue, depending in large part upon neighborhood opinion on the balance of costs and benefits.

This sub I-705 access area of the Dome District and the 34th and Pacific Mixed Use Center definitely needs further work, including possible additional alternatives. How this particular issue escaped under the radar of both WSDOT and the City of Tacoma is mystifying – I’ll chalk it up to vagaries of political negligence and underfunding over a period of decades.

Direct HOV Access to Downtown Tacoma

Since the 1999 date of the original project configuration direct access HOV ramps have become more of a standard best practice. Their omission from this project is a glaring omission – not providing direct access to the largest employment center in the entire County, as well as residential areas further North, is ‘shocking’. Upon my initial review I would suggest a ‘Texas T’ configuration couplet at Portland (north connecting) and Pacific Avenue (south connecting) during the reconstruction of these interchanges. The McKinley and ‘L’ street bridges do offer additional opportunities for this absolutely necessary project component. Please note that closure of Wiley would be acceptable, if an additional access point to Dome parking was created.

Compatibility of Design With Expedited Sound Transit Link Completion

With the passage of Sound Transit 2 last Fall completion of the north Link connection is possible within the 2030 temporal envelope of this analysis. At this point the current alignment is thought to be along the I-5 corridor from the Federal Way Transit Center at 317th. This may not be feasible from the Port of Tacoma road south. A final decision cannot likely be made on this issue at this time, however a preliminary determination of inappropriate access might be issued. Alternatively, the HOV and light rail system could be designed for joint operation as in the Seattle Bus Tunnel. The limits of this joint operation are not understood at this time, but should be relatively soon, just as direct access HOV practice has evolved.

Toward that end I have attached a conceptual proposal for a direct access HOV/light rail alignment that accesses both the Puyallup Tribal areas and Downtown/North Tacoma (Dome Transit2.Pdf). Costs on this proposal would be high and would not be expected to occur at this time for either project component, however corridor design should be accommodated, even if it means closing Wiley Street or taking a small amount of additional land from McKinley Park.

Wetland/Flood Plain Mitigation

Mitigation alternatives for this project are incomplete through the omission of a First Creek mitigation option within the jurisdiction of the City of Tacoma. It is my understanding that the justification for this decision was based on the potential for salmon habitat in First Creek by the Puyallup Tribe, a valid, but incomplete decision point. Additionally it has come to my attention that additional stream flow to this area is possible and relatively simple from a Ms. Cindy Beckett (email contact above), a property owner in the headwaters of this area just South of Tacoma City limits affected by a historical kludge of aquifer mismanagement. A ‘daylighting’ of First Creek has additional recreational benefits which should be considered in addition to an updated Salmon habitat study. The final decision on this should be made considering the decision of the Tacoma City Council first. I also believe this alternative may be at less cost, given that the only significant construction item is an additional pipeline under the railway right of way.

Catastrophic Event Analysis

The construction of Berms along this corridor have strong risk components given the natural path of floodwaters. The First Creek sight is one of these, under the direct control of WSDOT. Sound Transit is proposing another at the ‘B’ Street gulch which may impact I-5 operations. Both of these gulches would become the target of stormwater from a large area given stormwater system failure from either a massive flood event, or, more likely, seismic event. I’m not sure of the exact legal way to make this argument, especially as stream delineation information is missing from the published document. This may be an area for legal improvement and I would suggest that the project team look at the HAZUS effort of the Federal government which is specifically designed to study many such scenarios.

Traffic Camera Placement

Please consider public safety in the placement of traffic cameras so that adjoining ‘jungle’ areas can be monitored with traffic resources. Please note that this same justification goes to the requested trail access proposal at the beginning of this comment document.


Thank you for the opportunity to comment on this project at a time when it is still possible to effect the design based on your environmental analysis. I look forward to the City of Tacoma being served by a state of the art HOV system. If you have any questions, please feel free to contact me via email or at my home:

Douglas Tooley
422 S. Wright Avenue
Tacoma, WA 98418


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