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  • Marie McKinsey

My Comments on Sound Transit's Draft Environmental Impact Statement (DEIS)

Updated: Apr 18, 2023

USGS map of Seattle seismic hazards
The West Seattle light rail extension will be built in one of the highest risk areas of Seattle.

I am posting my comments here for two reasons:

1) According to "the rules," comments submitted by April 28th that address specific sections of the statement have to be included in the final Environmental Impact Statement (EIS) and addressed in that document.

I'm making my comments public so we can see how they are addressed in the final EIS.

2) Many people I've talked to are overwhelmed by the size of the DEIS and haven't read much, if any of it. They aren't sure they will find the time to get familiar and make comments in time. I hope that reading my comments will help them locate sections of the document that are of concern to them. And if they choose to do so, they can copy parts of my comments. It's totally OK to do that.

My comments to Sound Transit on the DEIS:

Section Overview

Population growth estimates need to be revised. People are moving out of King County.

Ridership estimates need to be revised taking into account work changes because of the pandemic. Many people work from home now and will continue to work at least partly from home into the future. People moved out of West Seattle when the WS Bridge closed because their commutes became unbearable. The people who replaced them aren’t necessarily commuters.

Riders = revenue. If you can’t justify this project economically, perhaps it shouldn’t go forward.

By law, the state of Washington is required to lower CO2 emissions by 45% below 1990 levels by 2030.

A project this massive, requiring enormous amount of concrete, will actually increase emissions until the end of the 2030s, and most likely beyond. How specifically do you propose to mitigate the effects of construction? That plan should be described in detail in the final EIS.


The DEIS states: “The City of Seattle Transit Master Plan (City of Seattle 2016) identified extension of light rail to West Seattle as a top-priority project and included it in the long-range high-capacity transit vision. The plan specifically calls for a mixed surface and elevated alignment connecting to Alaska Junction or High Point, with the possibility for future phases to extend farther south.”

Why was the High Point option dropped? There doesn’t seem to be any explanation offered. From an equity standpoint, High Point is a much better choice. It would provide easier access to light rail for low income and POC residents in West Seattle. Why choose the affluent Alaska Junction for light rail instead? Why weren’t High Point alternatives given in the DEIS? That needs to be explained in the final EIS.

Also, High Point is more centrally located in West Seattle. Creating a transit hub there just makes sense. For too long, the majority of peninsula traffic, including transit, has been funneled through the Alaska Junction area to get to a bridge of one sort or another. That has created a bottleneck for generations. Why keep doing that?

A big lesson from the West Seattle Bridge closure is that residents need MULTIPLE ways in and out of the neighborhood. That includes multiple corridors. Show us some alternatives to the Spokane St. corridor in the final EIS.

Don't say you don't have the money for this. In August of last year, you awarded HNTB an additional $4.2 million to: "… support the upcoming efforts to identify capital cost estimate reductions and would include a review of project design and construction efficiencies as well as potential major project definition changes for Board consideration."

Please ask HNTB to show us how High Point can be connected to the light rail spine without having to come through the Junction. Alternatives

If you must bring light rail to the West Seattle Junction, one of the tunnel alternatives should be used. The elevated options are too destructive to be considered. Residents here are just beginning to realize how many homes and businesses we will lose. We are in shock.

Also, the bridge from SODO should follow the route north of the West Seattle Bridge. Pigeon Point is a sensitive area in terms of Tribal rights, green space, salmon runs and wildlife. Running a rail bridge over that area will be destructive, regardless of what it done to mitigate effects. Seattle has lost enough green space as it is. It isn’t necessary to damage this natural area permanently.

The proposed route north of the West Seattle Bridge is quite rightly situated over an industrial area. That is where light rail belongs.

Also, building the route north of the WS Bridge makes it less likely that the bridge will have to be closed during construction. Both of the southern alternatives cross the car bridge. It will not be safe to build that section of the rail bridge with cars using it. West Seattle has suffered enough with that bridge being closed. We aren’t going to be happy if you close it again.

4.2.3 Economics

The economics of bringing light rail to the Junction needs further examination in the EIS.

The land the light rail project will occupy will be permanently lost to economic development and revenue generation. It doesn’t matter if the businesses relocate and pay taxes elsewhere. That land has permanently lost its economic value. It will take years for transit-oriented development, if indeed that happens, to begin to offset that lost revenue. If interest rates continue to climb, and even if they stay where they are now, redevelopment will be slow.

When an alternative is chosen, the EIS should provide a list of all properties, business and residential, along with the amounts of sales and property taxes that will be lost with their removal. The DEIS tries to ignore this responsibility, saying it is impossible to tell. But it IS possible. How much revenue did that land generate in the past year? That is an indicator of how much economic value is gone forever.

Sound Transit is dependent on property taxes, sales taxes, and RTA fees on car tabs for funding. This project will result in what amounts to a significant cut in pay. Therefore, the final EIS should give residents an estimate of what ongoing maintenance of the system is expected to cost and how Sound Transit will pay for it.

Sound Transit has a terrible reputation when it comes to the reliability of escalators and elevators. Stations in West Seattle, whether elevated or deep underground, will be dependent on these systems to get people on and off trains. If they don’t work, we’ll have a giant broken system, and we’ll be worse off than if we never had a train.

Again, where will the money come from to maintain these systems? What plan does Sound Transit have to reduce downtime? The final EIS should explain.

Furthermore, with construction planned to begin in 2025 and continue until 2032, existing businesses will struggle. Detours, road closures and other difficulties involved with this project will mean loss of revenue for businesses for years, and thus loss of revenue for Sound Transit.

One of the things we’ve learned from the WS Bridge closure is that as things drag on, people change their habits. If it is too difficult, for too long, to shop somewhere, they will try different businesses, or order online. In time, those work-arounds become routine. When the train is operational, how many shoppers will come back? How many businesses will have survived?

The claim that light rail will lead to more dense and mixed-use projects in West Seattle seems overly optimistic. West Seattle is primarily zoned for single family residences. Most of the land zoned for commercial and multi-family purposes has already been developed, especially in the Junction. Light rail will demolish some fairly new apartment buildings. We have a housing shortage as it is, and with zoning what it is, we don’t have much room to add new homes.

High interest rates coupled with lack of room to build are more likely to lead to stagnation of the economy in the Junction, not growth.

4.2.5 Visual Effects

From an aesthetic point of view, the elevated alternatives for this project are way out of scale with the neighborhood, more likely to destroy the “small town charm,” that has drawn people for generations, than it is to attract new residents or businesses.

The DEIS doesn’t provide many renderings that give us an idea of what critical areas will look like. This is particularly true of the bridge coming from SODO to West Seattle. Few residents realize that the train will go over the top of the east end of the West Seattle Bridge. There should be a rendering showing what it will be like to drive under that bridge heading eastbound on the WS Bridge. (Also, how long will the bridge have to be closed during construction of the light rail bridge?)

A rendering showing what the bridge will look like from Pigeon Point would be helpful. And another one showing what it will look like coming off Pigeon Point and over Delridge Way.

Also, where are the renderings of what the stations will look like. A graphic showing the plan view doesn’t give people a sense of scale. We need to be able to picture what the neighborhood will look like when this is done. The final EIS should have a series of architectural renderings of key elements so we know what to expect. Greenhouse Gas Emissions

Table 4.2.6-3 gives a range of CO2 emissions during construction from 158,067 – 614,461 metric tons. However, this is just from equipment and vehicles.

This does not include the amount of CO2 produced in the manufacture of concrete required to build this massive bridge and other structures. The cement industry is a major producer of CO2.

How many cubic yards of concrete will be required for this project? You must know or you wouldn’t have been able to calculate cost estimates.

It seems strange to leave something this critical out of an environmental impact statement! The final EIS should account for the total amount of CO2 the project will generate and a plan for mitigating that impact.

4.2.9 Ecosystems

From the DEIS: “The West Duwamish Greenbelt is within the Duwamish Segment. The greenbelt stretches4 miles south from the West Seattle Bridge along the western side of the Duwamish Waterway. The Washington Department of Fish and Wildlife designates the greenbelt as a Biodiversity Area and Corridor (a priority habitat). It is primarily deciduous forest with bigleaf maples and red alders, and provides habitat elements such as mixed forest snags, downed woody debris, and areas with multi-layered canopy. The Delridge Segment includes the greenbelt around Longfellow Creek (also a Washington Department of Fish and Wildlife-designated Biodiversity Area and Corridor), as well as developed open space in the West Seattle Golf Course and the Delridge Playfield and Community Center park.”

This description explains why light rail should be directed north of the West Seattle Bridge. There is no way to bring light rail over and through this area without seriously compromising the environment. Many species of birds and fish, already endangered, will have their homes threatened.

Construction for all alternatives will last 5 – 6 years, meaning ongoing disruption to natural areas and wildlife habitats. It is concerning that “Preferred Alternative WSJ-3a* and Preferred Option WSJ-3b* would include construction staging at the edge of a wetland buffer on existing paved surfaces that do not provide buffer functions or would occur in unpaved areas separated from the wetland by a paved road.”

Will those wetlands recover after years of construction?

4.2.11 Geology and Soils

The location of the light rail system should be reevaluated on this basis alone.

This USGS seismic hazard map shows how likely we are to suffer serious damage in an earthquake. The light rail bridge, starting in SODO, will be built in an area of highest risk. No one wants to be on a train, on a 150-foot tall bridge, in an earthquake!

This was the reason we tore down the Alaskan Way viaduct. We were afraid that an earthquake would cause it to collapse. Why are we building an even bigger bridge in the same area?

This map from the DEIS shows light rail crossing Pigeon Point. The bright red areas are known landslide areas. The pink slanted striped sections are potential landslide areas.

Geotechnical engineering methods can keep structures stable in slide-prone areas, but they are no match for earthquakes.

Appendix L.4.1 Supporting Information on Affected Environment and Environmental Impacts

This section contains some of the most important information for West Seattle residents. This is where we find the addresses of properties that may be affected. This includes businesses, single-family homes, apartments, condos, and organizations that make up the fabric and character of our community.

Sadly, this document is a perfect example of observing the letter, not the spirit, of the law. Light rail is a public project and therefore the names and addresses of those affected should be public information. Sound Transit is required to disclose that information, and you can say that you have.

But instead of full disclosure, you BURIED those addresses in an appendix with a vague title. This appendix is like a mass grave: A collection of faceless, nameless properties piled into an unmarked document. No one would guess the contents of this appendix from the title. And that doesn’t appear to be an accident. Is this an attempt to hide the impact this project will have on the lives of West Seattle residents?

Because the names of businesses and apartment buildings are left out of the listings, we can’t tell which ones are affected. To determine whether a business or apartment building might be lost, we have to google the property to get its address, and then refer to pages and pages of addresses to see if that property is there.

To be fair, you do mention names of some properties in the main text of the DEIS, but even that is deceptive. You say that a Safeway store might be eliminated, but fail to say that along with it will go the entirety of Jefferson Square – all of the businesses, all of the parking, all of the housing.

The final EIS should have a clearly marked section titled “Affected Properties,” that gives the names of ALL businesses, non-profits, and multi-family buildings that will be lost. For most people on the list, and those who have relationships with them, this will be like learning that they have a terminal illness. Please have respect for the lives involved.

Reminder: You have until April 28th to comment on Sound Transit's DEIS. By law, your comments have to be entered into the public record, and ST is required to address them in the final draft of the Environmental Statement. But there's a catch! You must address each of your comments to a specific section of the DEIS document. Otherwise your comments won't count.

Here's info on submission. And here's the full document.


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