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Procedural Comments on the Tacoma I5 Environmental Impact Statement

Below are procedural comments on the I5 Tacoma HOV project, including a description of my own interests.


Date: August 29, 2009

To: Carrie Berry, Tacoma HOV Environmental Coordinator

CC: Claudia Cornish, Communications Manager

RE: Tacoma/Pierce County HOV Program Supplemental Environmental Assessment

The following comments go to procedural issues concerning your current Tacoma HOV environmental review. My substantive comments will follow shortly.

I have received and preliminarily reviewed the IJR report for the Tacoma HOV projects. I had assumed that a report describing the WSDOT analyses direct access HOV ramps for Freighthouse Square and Downtown Tacoma would be included, apparently incorrectly.

Additionally appendix ‘E’, the Wetland and Stream assessment is missing from both the distributed CD and the website for the NEPA assessment. Lastly, please note that although I have lay qualifications read the environmental appendices associated with this project there is too much material to reasonably review in the time allotted.

I am also concerned about the timing of the review of State environmental procedures. Though I have not confirmed exact dates it does appear that the determination of non-significance was issued concurrently with Governor Gregoire’s budget delaying the project funding beyond available monies – hopefully not with the intent of pressuring local governments to accept the SEPA findings. Most significantly SEPA allows for greater analysis of alternatives than does the NEPA and the project plan has substantial gaps in this regard. Similarly, the ten years that have elapsed since original planning, design and review was done limit the relevance of current documents.

On a similar note I consider the actions of the City of Tacoma insufficient in regards to feedback on this project. I understand that the cause of this is poor funding, but that may also be bad budgetary judgment on the part of those that control this City. In any case it would best if it was clear WSDOT encouraged active involvement in project planning and avoid any appearance of the opposite. I have noticed that WSDOT has ample staff and would suggest consideration of assigning some of this funding to local jurisdictions to fund their participation.

You may be aware that there are currently personal accusations floating around regarding my behavior in civic issues related to this matter. Please be assured that these are false. Please be warned that I allege these to be intentional with the intent to control public expenditures through techniques which amount to second degree extortion, even if executed under apparent legal authority.

I have been subject to and used in such a manner for a period of 20 years that has resulted in my current disabled status. This does allow me the time to review these projects but also limits my ability to respond. The exact delineation between these disabling effects and the extortionary harassment creating some has not yet been determined.

Please note that although I do not comment for any organization I do believe I have established informal relations with all groups that do have an interest in this project and should be aware of all public position statements that would effect this project. As an individual I can hopefully address all of these concerns in a balanced fashion, though at definite risk of retaliation from polarized special interests.

Please note I also have an associated professional interest in this matter – as a GIS professional I found that responsible community involvement was a great way to obtain the level of knowledge needed to effectively manage geographic data in the public interest – an area where I **was** a State pioneer.

I am currently seeking to re-establish that career as well as gain recompense for the damages that have been done to that career over 15-20 years per the above. It is my perception that WSDOT has the organizational ability to withstand at least some of these pressures, albeit at the expense associated with large organizations.

It is my belief that my flexibility as an individual can strengthen the effectiveness of WSDOT practices and all that they impact and look forward to a continued association – perhaps even as part of my return to the GIS profession. At this time though I am strictly a solo practitioner within that field and very much out of date regarding technical practice.

Lastly, the City of Tacoma through its Police Department has begun a pioneering effort at creating a ‘code of conduct’ for our community. As a document on the shelf this will not mean much, cognizance of the conversation will mean much and would encourage the familiarity of this to you Ms. Berry as well as Ms. Cornish.


-Douglas Tooley


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