Record of Decision Attachment C -Agency Comment and Responses <br />3. ODOT comments -Springfield <br />Ye ~n Department of Transportation <br />1 1 ~ .. . :. .... .: ... _ .. Region2 <br />f <br />.. ... -IohnA:iGiihnnn.M..a.Go°emar ._..... ..: _. ..:.... ' 455Airpq[tltd.SE,BIdgB <br />- : ~ Sa1emOR9 73 01-5 395- <br />- FAX(503798&2fi30' <br />February 26, 2001 rnxcooe <br />Michael I.cvine (1 "~ 6 ~ ~~~ <br />U 3 Oencral Services Adminfstrauon ~J <br />400 15~h Street 3W ~ ) ~) { <br />Auburn; Washtngton98001=6599 ' ' "' " ~~ <br />311BJECT::..New.FedexalCourthouseFinalEnvironmentalimpactStatement. ' .,........_. <br />_.....:. :. , ...:...: Eugene/Springfield, Izne:County, Oregon. . .:..... <br />Dear Mr. I,evitte:" " <br />My Febtuary 2, 2001 letter was confined to comments on the Eugene locations. <br />As we riiscuseed during our February 20; 20D I meeting, this°ktter iacludes <br />commemt on the, proposed Springfield:l2iverfrtmt site. S The Oregon Department <br />,.::tit Transportation's: (O.DOT1. rev,ew of. data for-fho Springfield ~jte shows Issues <br />similar to those identified by ODOT for the Eugene locations. ODOT therefore <br />continues to have concerns regarding the documentation axing used to justify <br />the federal decision conaietent with rife Natiorial'Eriviroamental'Pglicy Act. <br />ODOT's concerns forthe Springfield site rotate'to'tha operation `of the"' ' ` ' `"" " <br />transportation system aniipublic safety impacts::ODOT does not agree that.the <br />impacts of:anewFederal Courthouse have:beenadequately~titdied and <br />declared;:or that-mitigation is not required: Analysis thetas more-complete <br />should be uadertalten before a final decision is made. <br />Sunilar Ito the Eugene locations; access io the Springfield site is dependent <br />upon state highways. In Springfield; the state highway most-impacted by the <br />proposed'site is the McKenzie Highway (OR-126 Business), a componemt of the <br />- Naticnei Highway System. Asecond-highway, the Springfield-Highway (also <br />known as the Pioneer Parkway); slew fie impacted. Access to the Courthouse via <br />privatevehide, public transit orby foot wiU" atfect the operation and safety of <br />- these facilities. <br />ODOT has identified-the following: <br />1.: TcafiiaSafety/Crash Data: -The Draft Environmental Impact8tatement <br />s.t (DE1S) states, 'Traffic accident information provided by the Department of <br />Transportation for the City of Springfield (Alternatives 1'and 3) indicates <br />" that aU of the intersections reviewed in.Springfield for~his project have, low <br />accidenttatea (page 176; paragraph 2);" ODOT disagrees with this <br />r«mzwansra taus, : ~ " - - <br />: - PedenlCourttieinat:PB19 <br />- - - - - - 3prinalieW Rrvesfmne site .. <br />: Papa 4 <br />ranclusion: ODOT'a two primary data sources far crash information, the <br />` Safety Priority Indent System (SP13), and tho State of Oregon's Crash <br />Database show there are traffic safety issues in"alosa.proximity to. tbs. <br />proposed Courthouse ovation. <br />' Between the Willamette River Bridges and the Springfield Highway, the <br />MaICeuzie Highway is an urban section operating on sons-way couplet. The <br />crash history between January i, 1995 and December 1999 shows'6$ <br />crashes involving 32 injuries. "There were no fatalities:. Angle, turning and <br />yearend incideata account for 929'0 oC the crashes; and abnnat half (47°1oj of <br />s.i fife total crashes were eagle accidents with concentrations at the signalized <br />intersections of Main street/southbound Spring4eldHigltway (1Veat Leg,- <br />: Pioneer Parkway) and Main Strest/MillBtreet. The eight SPIS aitesput.this <br />highway section among she worst ten percent of all:crasit locations in <br />Oregon. This demonstrates that this highway section has trattic ea[oty <br />problems and"contradicts the conclusion reached in-the DEf$. -The potcutiei <br />far crashes at these intersections can be expected W increase with increased <br />traffic volume, particularly with di9'erential increases in tumirtg vehicle <br />volumes associated with travel to end-from the proposed Riverfront site. <br />These circvmatsnces also wniradict fife conclttnion readied in the FEi3 <br />that'witfgauon rcieasures arc not required (page 1361 <br />2. Traffic Oaergtions. "As stated in OD(yfh February 2, 20011etter, Oregon <br />managsea its state Highway system using the policies and standards adopted <br />aspart of the 1949 Oregon Hi¢ttwnv Plan. This:plantatablislies standards <br />W mafritaiit acceptable lovela of mobility on the state highway system ueutg <br />volume/capacirysatios. Within the $ttgetto-3pringGeld area; the mobility <br />standard fox statewide highway$ is 0.85 through the planning hoxtum <br />eetabltslscd in the Regwnal Transportation Plan: 2018. The Vafftc study" : <br />prepared. for the DEIS should havo addressed"thin standard on ODOT- <br />m~naged facilities. Also stated in ODOT's earlier letter; the operations <br />analysis aooomp&ahed during development of the DEIS used-the delay <br />method of:analysi~a technique not acceptable for the Oregon Highway .. <br />System. <br />3.2 The required technique whr:tt anatyung eigctaUred intersections on the state <br />highway system is SIOCAP2. ODOT conducteei a 3IGCAP2 analysis of the <br />Mafia Strext/Mill Street intersection using the 2003 traffic volume <br />information provided in the Dratt Envlronmentnl ImpactStatetnent <br />(AppaneliatB, Figure 6ff. Mobility at thin intersection is expected to be: 0..83 <br />m 2003-close to the mobility standard"for 2018:. In addition, the calculated <br />storage distances forwestbound traffic on Mom Street show that velticJe <br />queues wilt extend through-the Main 9[mt/Southbound Springfield <br />Highway (West leg,. Pioneer Parkway) intersection. Queued southbotmd <br />traffic ttoxth o[ the Main Stteet/MiU Streit intersection extends. almost the i <br />entire block. Northbound traffic demand on Mitl Street wiU exceed the block <br />length btkwcen Main Street and Yt' Street, causing vehicle queuing to extend <br />onto A' Street. While the lctt turn lane on A` Street appears to be of <br />adequate length to accommodate 2003 vehicle queuing, movement. of <br />