US Department of Transportation
Federal Transit Administration

Region X
Alaska, Idaho, Oregon, Washington
910 Second Avenue
Federal Bldg. Suite 2142
Seattle, WA 98174-1--2
206-220-7855 (fax)

October 15, 2001

Re: Environmental Review of Changes to Central Link Light Rail

Dear Ms. Earl:

This responds to your letter of August 31, 2001, submitting for Federal Transit Administration (FTA) review an environmental re-evaluation for the Central Link light rail (LRT) project. This re-evaluation was submitted on proposed changes to the preferred alternative that is the subject of an FTA final environmental impact statement (FEIS), and on redesignation of the first Minimum Operable Segment (MOS-1) that is the subject of a full funding grant agreement (FFGA) between FTA and Sound Transit (ST). FTA is also aware of the relevant actions of September 27, 2001, by the Sound Transit Board. This letter addresses only the environmental process implications of the Sound Transit proposal.

FTA has reviewed your submittal and has determined that, in accordance with 23 CFR sections 771.129 and 771.130 of the FTA regulation implementing the National Environmental Policy Act (NEPA), a supplemental environmental assessment (EA) of limited scope is needed. The purpose of this EA would be to detail the proposed changes to the new MOS-1 from what was presented as the preferred alternative in the FEIS, and to evaluate the significance of the new and changed impacts that would result from the proposed changes. The supplemental EA is not intended to reconsider the important decisions already made on the basis of the existing FEIS, such as the purpose and need for the project, the primary modal decision, the alignment and station location decisions, the railyard location decision, etc.

The EA should be focused strictly on the new MOS-1. It should cover how the new MOS-1 is changed from the corresponding segment of the preferred alternative in the FEIS and what the social, economic, environmental, and transportation impacts of the new MOS-1 would be compared to the impacts of the corresponding segment in the FEIS. Ultimately, a supplemental EIS may be required if the EA does identify significant new or significant changed impacts.

In what follows, FTA assumes that the Tukwila supplemental FEIS will be completed and released to the public prior to the public release of the supplemental EA on the new MOS-1. Accordingly, "FEIS" should be understood to mean the 1999 FEIS as supplemented by the forthcoming Tukwila supplemental FEIS.

The limited scope of the supplemental EA on the new MOS-1 should include the following:

1. The study area covered by the supplemental EA should be the new MOS-1 area of influence between the existing Convention Place Station (CPS) in the Downtown Seattle Transit Tunnel (DSTT) and South 154th Street, including any area where temporary rail tracks or other end-of-line facilities would be located. The EA should describe two alternatives within this study area: the FEIS (as supplemented) version of the LRT and the new MOS-1 version with shared rail/bus use of the tunnel. (The no-build alternative is not under consideration; it was covered in the FEIS and need not be included in the supplemental EA.) For the new MOS-1 alternative, the EA should explicitly identify any proposed change from what was described in the FEIS, including any operational changes, mitigation changes, alignment changes, and any other changes with potentially different impacts.

2. For each of these project changes, the EA should present the associated changes in social, economic, environmental, and transportation impacts that will result. As with project changes, the evaluation of impacts presented in the FEIS (as supplemented) is the basis for determining whether a change in impact will occur and how significant any changes in the impacts may be.

3. The EA should describe the changes in sufficient detail to enable FTA, the public, and resource agencies to understand what will be constructed and what impacts will result. For example, the EA should clearly present the facilities at the terminal stations, including the tail tracks and other layover and turnback features, the bus staging area, the sizes and configurations of the passenger terminals and parking lots, and any other changes. The level of detail provided should be consistent with the level of detail normally found in Preliminary Engineering.

4. The joint bus and light rail use of the Downtown Seattle Transit Tunnel (DSTT) proposed in the new MOS-1 alternative is a change that raises numerous issues that the supplemental EA should address. They include:

a. The FEIS did not include joint use of the tunnel because at the time joint use was considered to be inefficient from a transit perspective. Now joint use is being considered to minimize the downtown business disruption and traffic impacts on the surface streets. The EA should address the circumstances, conditions, and considerations that have changed to make joint use a reasonable option.
b. The transportation impacts of this change in the use of the tunnel should be covered, including any reductions in the rail capacity of the tunnel due to the reduced speeds and limited total vehicle capacity in a joint use mode. A comparative evaluation of the transportation impacts of the joint use and the original FEIS use of the tunnel is needed in the EA. That comparative evaluation should consider the impacts both on the performance of the tunnel and on the performance of surface streets where the diverted tunnel buses would have gone.
c. The full implications of the joint use for future extensions to the University District should be covered. The EA should estimate the length of time that the joint use would be in operation if the future northern extension does come to pass. The EA should estimate the incremental costs of designing the tunnel and tunnel stations for joint use and compare it to the cost of the originally planned LRT_only use.
d. The EA should cover all the implication of joint use for Seattle Metro. It should state what the bus fleet technology will be, whether hybrid buses, if selected, can operate in the tunnel end-to-end only on battery power, and how the buses would be purchased and maintained. It the new buses will require a new or rehabilitated bus base for storage and maintenance, then the EA should cover the environmental impacts of that bus base.
e. The EA should address safety issues in the shared tunnel, including a hazard analysis and the position of the Seattle Fire Department on evacuations.

5. The change in the use of the Westlake station as the temporary northern terminus for passengers should be covered in the EA. The following items regarding this change be should addressed:

a. The issues that are normally of concern at a terminus, such as were considered with the terminus at NE 45th street, should be covered. For example, what will the traffic impacts, passenger drop-offs and parking effects be with the light rail ending and starting at Westlake?
b. The EA should cover the LRT operational issues that accompany a northern terminus at Westlake and indicate how the trains will be turned back be stored during layover, etc. The staging of buses and turnback of trains at roughly the same location should be addressed in terms of potential conflicts and the resulting impacts on operations.
c. The EA should cover the construction impacts associated with the changed plans for CPS and Westlake, including the duration of the construction period and the associated business disruption and any other impact changes.

6. With respect to each of the changes associated with the new MOS-1, the EA should evaluate the changed impacts, if any, on endangered species and include a new Biological Assessment (BA) if, in light of the changed impacts, a new BA is required under the Endangered Species Act.

7. If there are any changes to the project or to the mitigation in Rainier Valley from what was presented in the FEIS that would affect the previously conducted environmental justice (EJ) analysis, then an updated EJ analysis should be included in the EA. If the proposed changes point to the need for an updated EJ analysis, the 2000 Federal Census data should be used in performing that analysis. (The most recent data officially available must be used whenever any NEPA document is prepared.)

8. The EA should cover any changes to the affected environment within the MOS-1 study area, and any new circumstances or new information that is not available that would result in new or different impacts not already evaluated in the FEIS. If any such changes are found, the EA should describe the new or changed impacts that result.

The decision to terminate temporarily at Westlake and to have joint use of the DSTT has generated significant public interest. The EA will provide an opportunity for formal public comment on these proposed changes by a fully informed public. After the supplemental EA has been completed and made available for public and resource agency comment, FTA will consider the evaluation in the EA and the comments received in deciding whether significant impacts not already evaluated in the FEIS would result. IF FTA determines on the basis of the EA that a supplemental EIS is not needed, FTA will issue a revised record of decision for the project.

That you for the opportunity to provide input as you consider project changes.


Helen M. Knoll
Regional Administrator