Sweet Streets Opposes UDOT’s I-15 Widening Plan
Below are comments from Sweet Streets opposing the Utah Department of Transportation’s plan to widen Interstate 15 through Salt Lake City and Davis County. The deadline to comment is Friday, Jan. 13, 2023. Consider copying part or all of the comments and send them to i15eis@utah.gov before the deadline.
January 13, 2023
i15eis@utah.gov
Tiffany Pocock, P.E.
Project Manager
I-15 EIS, Farmington to Salt Lake City
392 E Winchester St., Ste. 300
Salt Lake City, UT 84107
Subject: Comments to Alternatives Development and Screening Report (November 2022)
Dear Ms. Pocock:
Sweet Streets Salt Lake City is pleased to submit formal comments to UDOT on the I-15 Environmental Impact Statement Farmington to Salt Lake City project. We believe streets and public spaces that welcome all users are essential to a society and economy that is more connected, equitable and sustainable. Our organization educates and advocates for people-first planning, budgeting, implementation and operation of our streets and public spaces.
Sweet Streets is very supportive of the State and UDOT’s efforts to invest in transportation improvements that increase safety, enhance active transportation, better connect communities, and improve air quality. This letter contains Sweet Streets’ comments and suggestions to improve the Alternatives Development and Screening Report: November 2022 Preliminary Results prior to UDOT’s preparation of a draft EIS.
Although we recognize the need for transportation solutions as the Wasatch Front area continues to grow, the solution under consideration—expansion of I-15—shows a lack of innovation and is shortsighted. Sweet Streets does not support the proposed widening of the existing I-15 footprint.
The proposal has five purposes: “to improve safety, replace aging infrastructure, provide better mobility for all users, strengthen the state and local economy, and better connect communities along I-15 from Farmington to Salt Lake City.” Sweet Streets is concerned that the existing proposals, in many instances, fail to address these goals. Rather, the proposal seems primarily intended to address motor vehicle congestion concerns, often to the detriment of the five identified goals. In addition, Sweet Streets raises concerns related to public input, data reliability, and specific alternatives.
IMPROVE SAFETY
Utah has seen a significant rise in traffic violence and vehicle accident deaths. Sweet Streets is concerned that the proposed expansion will only exacerbate this trend by encouraging more private vehicle traffic at higher speeds.
Sweet Streets supports the removal of “free right-hand turn” movements to improve safety for pedestrians and bicyclists while encouraging drivers to be more aware. As UDOT notes, “[f]ree turning movements do not slow vehicles down as they enter the neighborhood streets and therefore reduce drivers’ ability to see slower-moving bicyclists and pedestrians.”
Sweet Streets also encourages UDOT to prioritize and incorporate raised pedestrian crossing across interchanges to improve driver visibility of pedestrians and provide a physical piece of infrastructure that requires vehicles to slow speeds.
The proposed expansion must also be considered in concert with the increased heavy-duty truck traffic anticipated from the inland port development. Sweet Streets is concerned that encouraging additional, higher-speed passenger vehicles alongside heavy-duty freight vehicles will exacerbate the increasing number of vehicle accident deaths in the last several years. It is worth highlighting a recent incident where a large heavy-duty vehicle accident closed the entirety of northbound traffic on I-15 for nearly twelve hours on December 8, 2022. Increased freight vehicle traffic could lead to an increase in such occurrences. While Sweet Streets understands that traffic engineers cannot predict or entirely prevent accidents, the Department of Transportation is required by Utah Code § 41-6a-602 (1) to “determine the reasonable and safe speed limit for each highway or section of the highway” by relying on safety studies that include “design speed; prevailing vehicle speeds; accident history; highway, traffic, and roadside conditions; and other highway safety factors.” It is the position of Sweet Streets that this increased freight traffic needs to be more heavily studied and considered, particularly in the reversible lane concept.
Items for Consideration:
Remove “free right-hand turn” movements
Prioritize and incorporate raised pedestrian crossing across interchanges
Consider the impacts of increased heavy-duty truck traffic anticipated from the inland port development throughout the project, including when conducting safety studies and establishing speed limits
REPLACE AGING INFRASTRUCTURE
Metropolitan areas across the country are moving away from highway expansion and are actively reducing highways. It is not clear from the Report whether UDOT considered potential improvements within the existing footprint beyond the proposal to make no changes. Sweet Streets supports the proposed investment in updating aging infrastructure. However, the need for substantial funding to maintain existing infrastructure both now and in the future will be exacerbated by expanding the existing footprint of I-15, creating ongoing repair and maintenance costs that are not currently funded nor considered in the proposal. Thus, Sweet Streets does not support the expansion of I-15 simultaneous to the updates that would not expand the highway.
Items for Consideration:
Consider potential improvements within the existing footprint beyond the proposal to make no changes
PROVIDE BETTER MOBILITY TO ALL USERS
Sweet Streets appreciates the consideration of modes of transportation beyond motor vehicle traffic in its proposed alternatives. However, the proposed expansion fails to adequately protect bicyclists, support the planned construction and execution of FrontRunner Double Track projects, and incentivize carpooling.
While Sweet Streets appreciates UDOT’s inclusion of buffered bike lanes in the alternatives, protected bike lanes are essential for areas where traffic travels at speeds greater than 20 miles per hour. UDOT proposes only buffered bike lanes and fails to explain why protected bike lanes were not considered in any locations. This is especially concerning given the recent preventable pedestrian injuries that have occurred in or near these locations. Sweet Streets supports efforts to prioritize protected bike lanes in place of the proposed buffered bike lanes as UDOT continues in this process.
In the event UDOT concludes the proposed expansion would be beneficial, final approval on the proposal should be delayed until full funding is allocated to expanding regional bus, light rail, and rail service and frequency. Sweet Streets does not support any construction of the I-15 project until after full funding for the completion of FrontRunner Double Track projects.
UDOT can also better support and encourage carpooling by altering the current and proposed HOV-lane structure. For example, Sweet Streets suggests that the HOV minimum passenger requirement be increased from 2 to 3 passengers and that the modeling be revisited to accommodate this assumption. We also suggest that UDOT implement physical separation for HOV lanes with more strategic enter/exit points. Finally, we agree and support other commenters’ suggestions to prioritize HOV enforcement.
Building additional highways leads to induced demand—encouraging more people to drive in the short-term and leading to identical congestion issues in the near future. Expansion projects “might offer faster travel for a year or two, but any time savings will prove fleeting.” The current right-of-way is sufficient to accommodate designs that would improve traffic flow, especially considering the larger transportation network including Legacy Parkway, the West Davis Corridor, and 215. Sweet Streets opposes the proposed expansion as a short-term solution that will not address long-term transportation concerns.
Items for Consideration:
Explain why UDOT considered only buffered bike lanes and not protected bike lanes
Prioritize protected bike lanes in place of proposed buffered bike lanes in areas where vehicle traffic travels at speeds greater than 20 miles per hour
Condition final approval upon allocation of full funding to expanded regional bus, light rail, and rail service and frequency
Increase the HOV minimum passenger requirement from 2 to 3 passengers and conduct modeling based on this assumption
Implement physical separation for HOV lines with more strategic enter and exit points
Prioritize HOV enforcement
Review whether the proposal is likely to result in induced demand
STRENGTHEN THE STATE AND LOCAL ECONOMY
Increasing vehicle traffic will negatively impact air quality in the region and will do so most acutely in a geographic area with historically worse air quality (the west side). “Estimates of the economic costs of air pollution in Utah totaled $0.75 to $3.3 billion annually, approximately 1.7% of the state’s gross domestic product.” Thus, Sweet Streets emphasizes the need to fully consider air quality impacts, including such impacts on the economy, to evaluate the impact of the proposal on this stated purpose of the project.
Items for Consideration:
Fully consider air quality impacts and resulting impacts on the economy
BETTER CONNECT COMMUNITIES
Widening I-15 will not better connect east-west communities. To the contrary, it further divides east and west communities while catering to commuters living outside areas where they work. In addition, the proposal does not support public transit projects and may disrupt communities by destroying homes.
UDOT recognizes the need to “[s]upport the planned FrontRunner Double Track projects and enhance access and connectivity to FrontRunner, to regional transit and rails, and across I-15.” However, a proposal that does not interfere with FrontRunner and other public transit uses is not necessarily one that supports such uses. Delaying the I-15 project until full funding allocation to the FrontRunner Double Track projects and Davis-Salt Lake bus service project will support those projects and such support may alter the projections upon which the I-15 project is based. The conditioning of highway construction on transit funding is well-recognized in our state.
Utah is currently experiencing a housing affordability crisis. Governor Spencer Cox has cited concerns for the shortage of housing and lack of affordable housing in his fiscal year 2024 proposed budget. The removal of housing to make room for roads is not a new phenomenon. However, given the need for housing, such actions are not justifiable in this case. Any use of eminent domain in particular to remove homes will immediately destroy community links, an outcome directly antagonistic to the project’s stated purpose. Sweet Streets opposes any proposals that would prioritize roadway expansion over existing housing.
Items for Consideration:
Delay final approval and construction until the FrontRunner Double Track projects and Davis-Salt Lake bus service project are fully funded through completion
Avoid any alterations that would remove existing housing structures
PUBLIC ENGAGEMENT
Sweet Streets appreciates UDOT’s decision to extend the public comment deadline and to provide additional public engagement opportunities. Given the substantial impacts of this project, Sweet Streets urges UDOT to engage in more frequent and widespread public engagement going forward. Outreach should include not only communities directly impacted by the redesign, but also those communities that will be indirectly impacted by the proposed expansion. The two equity outreach meetings that UDOT has conducted are not sufficient engagement to fully reach these communities. Sweet Streets appreciates the willingness of the UDOT project team to meet with any community group who requests a meeting, but it is critical that more additional outreach be conducted to disseminate project information in the community.
Sweet Streets has also been notified by a number of community members who were given inadequate notice for the public meetings and is concerned that many public meetings were held at times where low-income families may have been less able to participate in the public commenting process. Therefore, Sweet Streets encourages UDOT to continue its efforts to expand their community outreach process for this and future projects.
Items for Consideration:
Conduct a more robust public engagement process going forward
Communicate with communities that will be directly and indirectly impacted by the proposal
Expand equity outreach meetings
Provide as much notice as possible before public meetings
Schedule public meetings at various times to accommodate various schedules
DATA RELIABILITY
UDOT used 2019 as the benchmark year for comparing the project proposal during the proposed alternative phase. However, Sweet Streets is concerned that this modeling does not account for how commuting has changed post-pandemic. Many individuals continue to work from home or commute on alternate schedules, and these shifts are anticipated to be permanent. Thus, Sweet Streets questions the reliability of assumptions based on pre-pandemic usage without considering long-term changes to remote work.
Sweet Streets also requests additional transparency around UDOT’s assumed number of passengers per vehicle. Because the number used in the modeling for the proposed alternatives could have a large impact on the final outcome of the proposed design from even fractions of variations in numbers, Sweet Streets is concerned about how this decision impacts the speed and time modeling for travel.
The impetus for this project relies in part on growth projections from the Wasatch Front Regional Council. However, the assumptions on which these projections are based is not clear. Sweet Streets would like further clarity on whether the projections rely on pre-pandemic benchmarks and how those benchmarks and the projections have been updated to conform with the significant changes in work that are ongoing. Sweet Streets would also appreciate greater clarity on whether those projections take into account resource and water scarcity, housing scarcity, and other factors that are likely to constrain growth, but are not always considered in population projections. Because this infrastructure project is significant and will have long-range effects, it is vital that the projections upon which it is based are comprehensive.
The project screening assumes eight hours of peak periods per day, with a morning peak from 6–10 a.m. and an evening peak from 3–7 p.m. Greater clarity from UDOT is needed to explain these periods and their impact on modeling. Sweet Streets is concerned that such large “peaks” may be the driving force justifying the proposal to widen the highway and that the distinction between what constitutes a peak and non-peak period is not sufficiently clear to justify such a drastic proposed solution.
Sweet Streets also suggests that the cross-section drawings would be greatly improved if drawn to scale. For example, the renderings of 400 North label a six-foot sidewalk that is visually twice the size of the roadway surface.
Items for Consideration:
Update proposal assumptions based on long-term changes to remote work
Clarify UDOT’s assumed number of passengers per vehicle and the basis for such assumption
Clarify the basis for growth projections that UDOT relied upon, whether they have been updated from pre-pandemic information, and whether such projections include factors likely to constrain growth
Explain the basis for UDOT’s assumption of eight hours of peak periods
Provide definitions used for determining peak and non-peak periods
Correct renderings not drawn to scale
WARM SPRINGS ROAD
Sweet Streets supports the addition of a full-access interchange at Warm Springs Road to remove and reduce heavy duty vehicle traffic from entering and exiting I-15 on 600 N. It is critical that the new interchange be located as closely as possible to 600 N such that heavy-duty truck traffic from the industrial facilities along the east side of the highway will be inclined to use the new, full-access interchange as opposed to 600 N. This will reduce traffic of heavy-duty freight vehicles on 600 N and John Stockton Blvd (300 W), which will reduce heavy-duty vehicle travel through 600/700 N between 900 W and Redwood Road.
Items for Consideration:
Continue to include a full-access interchange at Warm Springs Road
600 NORTH
The tight diamond interchange option, that UDOT identifies as safest for pedestrians and cyclists, was eliminated from the options for 600 N because of “poor traffic operations compared to other options.” This seems to indicate that UDOT considers safety a lesser priority than moving vehicle traffic, although safety is a stated purpose of the project. Diverging diamond interchanges also force pedestrians and cyclists to cross traffic four times to make it across the highway on- and off-ramps, making this intersection option less comfortable for such users. Sweet Streets encourages UDOT to reconsider this decision.
In addition, Sweet Streets is concerned about how the proposed 600 North options will integrate with the proposed lane reduction being considered by Salt Lake City on 600 North. The proposals may still encourage additional vehicle traffic and speeds entering and exiting I-15, particularly westbound before 900 West. Sweet Streets encourages UDOT to further clarify how the I-15 proposal will integrate with the Salt Lake City proposal.
While the proposed design does not extend fully to 900 West, UDOT Sweet Streets urges UDOT to require that this redesign extend to 800 West. This intersection would benefit from a full stoplight that is triggered by a pedestrian crossing signal, similar to the one at 700 North and the Jordan River Trail. Such an addition would further the stated purposes by improving safety and providing better mobility to all users.
Sweet Streets is concerned that the proposal does not include UDOT’s plan for maintenance and improving trash pickup and snow clearing of the sidewalk and bike lane. Currently, the existing sidewalk on the south side of the 600 N overpass is often filled with trash and other debris. Sweet Streets is also concerned that wider sidewalks and other elements will not be adequately maintained to keep them safely free of debris.
Finally, Sweet Streets supports wider sidewalks with both option A and B.
Items for Consideration:
Reconsider a tight diamond interchange at 600 North
Clarify how the I-15 proposal will integrate with the Salt Lake City proposed lane reduction on 600 North
Extend the redesign to the intersection at 600 North and 800 West and consider a full stoplight triggered by pedestrian signal at that intersection
Clarify the entity responsible for maintenance, trash pickup, and snow clearing of sidewalk and bike line in project area
Include wider sidewalks in this area
Option A: 600 N Collector-Distributor and 2100 North Full Diamond Interchange
Speeds on this interchange see cars and other heavy trucks reaching greater than 40 miles per hour. At 39 miles per hour, “the average risk of severe injury for a pedestrian struck by a vehicle reaches . . . 75%” while the average risk of death reaches “50% at 42 mph.” Given these substantial risks, Sweet Streets urges UDOT to consider a physical bicycle lane barrier. This could be accomplished by moving the four-foot park strip to the outside of the bike lane or placing some other physical barrier.
Items for Consideration:
Consider moving the four-foot park strip outside the bike lane or placing some other physical barrier
Option B: 600 N SPUI and 1800 N Full Diamond Interchange (page 57)
This option eliminates the 1000 North southbound I-15 on-ramp. Sweet Streets is concerned that traffic will be diverted from 1000 North to 600 North through residential and collector streets to accommodate traffic flow to the southbound on-ramp. Sweet Streets requests greater clarification from UDOT as to what traffic studies have assessed how frequently the 1000 North southbound on-ramp is utilized during peak periods and how the change in this traffic flow will impact the surrounding residential, collector, and arterial streets.
Sweet Streets is concerned that the mixed-use path will be underutilized for the cost investment for several reasons. First, Sweet Streets has safety concerns that the pathway is separated far from the roadway in an area (800 West and 700 North) where there are community members have shared concerns about illicit activities and where unsheltered community members reside. To ensure that this path is maintained and fit for the proposed use, Sweet Streets requests that UDOT clarify various aspects of the path. First, Sweet Streets requests clarification about whether UDOT or SLC will be responsible for maintaining the pathway to ensure it is well-lit, receives regular maintenance to remain free from debris, and is cleared of snow in the winter. Second, Sweet Streets asks UDOT to identify how the increased travel distance for users will affect anticipated use. Third, Sweet Streets asks for greater clarity on the length of that distance and associated elevation change due to the routing of this pathway.
Items for Consideration:
Review how the elimination of the 1000 North southbound I-15 ramp will impact traffic diversion through residential and collector streets
Clarify what traffic studies have assessed how frequently the 1000 North southbound on-ramp is utilized
Clarify the entity responsible for lighting, maintenance, trash pickup, and snow clearing of the mixed-use path
Identify how the increased travel distance for users on the mixed-use path will affect anticipated use
Clarify the length of the mixed-use path detour and elevation change due to the routing of the path
400 NORTH
Sweet Streets supports the proposed new underpass for pedestrians, bicyclists, and vehicles so long as it is well-lit and promotes safety for pedestrians and cyclists. This underpass should also be accompanied by improved crossing of the Union Pacific railway to improve connectivity with businesses and services along 400 N and 400 W. Cyclists and pedestrians using this underpass will still be required to cross train tracks or to travel south to 300 North to use the pedestrian bridge, which may impact anticipated use. Finally, Sweet Streets seeks clarification about whether UDOT or Salt Lake City will be responsible for maintaining and keeping free of glass and other debris.
Items for Consideration:
Improve crossing of Union Pacific railway in project area
Clarify the entity responsible for lighting, maintenance, trash pickup, and snow clearing of sidewalk and bike line in project area
500 NORTH
Sweet Streets is concerned that the proposal will encourage unsheltered encampments that may impact surrounding communities. In addition, cyclists and pedestrians must still cross train tracks or travel south to 300 North to use the pedestrian bridge. Sweet Streets suggests that it may be more beneficial for UDOT to focus its financial investment on physically protected bike lanes on the 600 North overpass and on the safety of 400 North instead of this proposal.
Items for Consideration:
Consider prioritizing physically protected bike lanes on the 600 North overpass and safety of 400 North above this proposal
US-89 SHARED-USE PATH FROM EAGLE RIDGE DRIVE TO WALL STREET 200 W
Sweet Streets seeks clarification on the design of this shared-use path, especially whether and how it will be separated from roadway traffic and what entity will be responsible for maintenance once construction is complete.
Items for Consideration:
Clarify whether and how the shared-use path will be separated from roadway traffic
Clarify the entity responsible for maintenance, trash pickup, and snow clearing of sidewalk and bike line in project are
Sweet Streets values UDOT’s consideration of the future of our transportation system along the Wasatch front and appreciates the opportunity for public comment and engagement throughout this process.
Sincerely,
The Sweet Streets Board
The Sweet Streets Board
