Public Interest Transportation Forum, http://www.bettertransport.info/pitf
on Hazard Presented by the Central Link Light Rail At-Grade Alignment Through Rainier
|The commentary below is an excerpt from a Public Comment Letter to Sound Transit and the Federal Transit Administration dated March 7, 2002. Full text of letter in PDF is available here.|
|The willingness of the Sound
Transit Board to place at-grade rail in the Rainier Valley while adamantly opposing it in
other areas of the city clearly would indicate that this type of alignment is not
desirable in other communities. Residents and activists in almost every neighborhood where
it has been considered have opposed at-grade light rail. Some public support for the
transit mall concept in the University District has been the one exception to this. A plan
for at-grade light rail through the Roosevelt community on Roosevelt Way met with strong
opposition from community residents and business owners and was quickly removed from
consideration in about 1994. I know about this as I lived close to that neighborhood at
the time. A proposed at-grade alignment through the Eastlake neighborhood also was quickly
abandoned at about the same time.
Death certificates only await the names to be entered of those who will be killed by these trains and who are most likely to be members of a minority race. Sound Transit, in all of its environmental documents including the Environmental Assessment, has claimed Martin Luther King Jr. Way will be a safer street with a light rail running in the middle. They consistently cite the approximate 300 accidents a year that currently occur in the 4 mile section where at-grade light rail is planned. Those accidents that cause death and serious injury are a better measure of safety than the number of fender benders. In the six years from 1991 to 1996 there were seven fatalities along that same section of MLK Way, averaging just over one per year. Compare this to 54 deaths in 10 years as a result of light rail accidents along the at-grade Los Angeles Blue Line light rail alignment that goes through Watts and other minority neighborhoods. Compare this to the 5 pedestrians killed in at-grade segments in the first year of operation of Portlands West Side MAX light rail line. In addition there will continue to be traffic accidents on Martin Luther King Way, which will not be reduced, but increased with the addition of light rail. In spite of Sound Transits claims to the contrary there will most likely be many light rail accidents and more, not fewer traffic accidents as traffic patterns become more complex, population density increases, MLK Way is widened and the additional risk factor of light rail is added to the mix.
In a study of ten light rail systems statistics showed that 92% of all light rail accidents happened on alignments in shared rights of way with traffic and pedestrians at speeds at or under 35 MPH. This is precisely the type of alignment planned for over 4 miles in the Rainier Valley. This study titled, "TCRP Report 17 Integration of Light Rail Transit Into City Streets" was sponsored by the Federal Transit Administration. Korve Engineering did the research work. Korve is currently under contract with Sound Transit for services connected to the light rail project. The study also showed that in city after city, relatively small percentages of total light rail track at-grade and in shared rights of way was responsible for the overwhelming majority of light rail accidents. Sound Transits own Final Environmental Impact Study optimistically predicted that there would be an average of 29 train-auto accidents and 3 train-pedestrian accidents per year in the Rainier Valley in the year 2020, 14 years after the original project was to be completed. The figures for the pedestrian collisions, which are very often fatal, are based on averages from comparable light rail systems according to the footnote attached to the statistics. This comparison fails to consider greatly increased population densities in the two major public housing facilities that are currently being redeveloped or the planned increase in housing density and population density for the entire Rainier Valley by 2020. This will obviously be accompanied by increases in pedestrian and automobile traffic with a subsequent increase in accidents of all kinds.
The urban character of the area along Martin Luther King Way is being ignored in Sound Transits optimistic and understated accident predictions. They are also ignoring the fact that there are few light rail alignments in the United States that the current light rail alignment in the Rainier Valley could be compared to. The high frequency (5 minute headways placing a train on the street every 2 ½ minutes) of trains, length of trains (eventual 4 car trains-360 feet long) abundance of schools, recent immigrants, elderly, children and disabled in an urban neighborhood defies comparison with any at-grade light rail system in the country. No light rail train in the United States operates with 4 car trains in a shared right of way with traffic and pedestrians. These 360 foot long and 250 ton trains have an emergency stopping distance when traveling at 35 MPH of 282 feet on dry track and almost twice that distance on wet track. The Rainier Valley alignment has not changed nor have any significant new safety measures been incorporated into the plan presented in the FEIS. No fences along the track or crossing arms are currently planned as safety measures. Fencing is not at all desirable, it would divide the community in half. It may become a necessity and even be requested by the community if enough accidents occur. There is every reason to expect a much higher number of serious and fatal accidents than predicted by Sound Transit with both the original and the current plan.
Injuries and fatalities as a result of this project will fall disproportionately on the urban Rainier Valley community compared to all other portions of the alignment in this phase and future phases of light rail expansion. As the population of the Rainier Valley is about 67% minority it is also most likely that members of protected racial and ethnic minorities under numerous civil rights laws will be much more likely to be killed and injured by light rail trains. Sound Transits EA and other environmental studies fail to acknowledge that strong statistical as well as anecdotal information clearly indicating the danger of these trains. They also repeatedly deny that the danger disproportionately impacts minority and low-income residents of the Rainier Valley in their environmental justice analysis. They allege that Martin Luther King Way will be safer after they place light rail on it. This claim is false. Statistics from the Los Angeles Blue Line and the Portland West Side Max previously mentioned along with other evidence belies Sound Transits claims of a safer MLK Way. It is obvious that the proposed light rail presents a significant danger to residents in the community and this danger will be in addition to those posed by automobile traffic, wider streets and impatient drivers attempting to navigate through the few remaining intersections and avoid delays caused by trains. At-grade light rail is another significant risk factor along MLK Way and will be an element of confusion for pedestrians and automobiles.
In Los Angeles the at-grade Blue Line light rail has been responsible for 54 fatalities in just over 10 years of operation. In Portland the at-grade portion of the West Side Max light rail line killed 5 pedestrians in its first year of operation. The Rainier Valley neighborhoods along Martin Luther King Jr. Way are busy urban areas. Martin Luther King Way is a busy arterial street with high traffic volumes (between 25,000 to 32,000 vehicles per day depending on location) and a number of busy cross streets are located along the proposed light rail alignment. Martin Luther King Jr. Way and the cross streets will become more congested and dangerous if the light rail is built as planned. The center turn lane used by automobiles is also used extensively by emergency vehicles to circumvent traffic and will be eliminated for the entire length of MLK Way. Of the 54 streets that currently intersect with MLK Way 35 of these will become configured as to permit only right turns onto MLK Way and right turn off of MLK Way. This will cause additional traffic to be concentrated at the remaining 19 cross streets in order for automobiles to cross MLK Way or to make left turns. The new configuration will make U-turns necessary at the remaining intersections in order to gain access to homes and business on the opposite side of the street from the direction of travel along MLK Way. There has never been an analysis in any environmental document including the current insufficient EA indicating what the safety and traffic impacts will be of the U-turns that will be required at the remaining intersections. Sound Transit has been quick to claim that reduced left turn opportunities will reduce traffic accidents, but has never addressed the issue of safety impacts U-turns at the remaining busy intersections. This is even more dangerous with pedestrians present and light rail trains approaching from two directions. Sound Transit has focused one element they claim will reduce traffic accidents and chosen to ignore those that are likely to increase them.
In 1999 I spoke on the telephone with Harry Saporta who was at the time head of safety and risk management for the Portland MAX light rail system. He informed me that no matter how much they trained the drives of the trains to avoid accidents it took 2 to 3 years on the streets for them to learn to avoid them. He said that every time they increase the frequency of the trains and need to add new drivers there is a significant increase in accidents. It just cannot be avoided.
This new traffic pattern is likely to increase traffic congestion everywhere in the Rainier Valley and also significantly increase the variables and complexity for pedestrians and automobiles navigating throughout the community. This will also have an additional impact on the businesses that survive the property condemnation and three years of construction. The limited access to the remaining businesses after completion of the project will result in a significant loss of business for many of them. This new and more complex street configuration will have a significant impact on traffic and pedestrian safety not only along MLK Way, but elsewhere as well. Not only will automobile traffic patterns become more complicated and less safe, but added to that will be the additional risk factor of trains up to 360 feet long travelling through the community every 4 to 5 minutes in each direction during peak hours and every 10 minutes during off peak periods. As congestion increases and navigation through the community becomes more difficult on Martin Luther King Jr. Way, overflow traffic from Martin Luther King Jr. Way the communitys busiest arterial street, will end up on other arterial streets, especially Rainier Avenue which already has traffic volumes of between 19,000 and 27,000 vehicles per day, and on residential side streets near to MLK Way. This will make many of those streets more dangerous with an increase in the number of traffic accidents. No analysis has ever addressed the safety and traffic impacts on the community of the traffic that will overflow onto these other streets.
When the street is reconfigured to accommodate the at-grade light rail the curb to curb width along Martin Luther King Jr. Way will increase a minimum of 18 feet from the current 54 to 72 feet. This increased width of 18 feet will only account for about 40% of the length of MLK Way along the light rail alignment. The remaining 60% will be even wider especially in station areas and where turn lanes are required. Curb to curb width will be over 100 feet in some station areas and as wide as 120 feet at least one station area. This will be a formidable barrier to the community and will divide it in half. It will also make the crossing of MLK Way by pedestrians even more difficult and dangerous. This is particularly troubling as the Rainier Valley has the largest number of disabled, elderly and young children in the City of Seattle. This increased width makes crossing more dangerous for children from the many schools with walk routes and school bus routes that cross MLK Way. No realistic evaluation of the safety impacts has been done in the EA or any previous environmental document.
|There has been no public process in the selection of an at-grade light rail system in the Rainier Valley. In early 1994 the Regional Transit Authority (RTA) currently known as Sound Transit unilaterally decided on an at-grade alignment through the Rainier Valley with almost no public participation in the process. Prior to this time the community was informed they would get a subway system in tunnels or a hybrid of elevated and tunnels.|
|On September 6th and 13th
of that year Sound Transit held the only two meetings to reveal the new at-grade alignment
to the community. This most significant change in the alignment with profound impacts on
the community was made without community participation. The total process to inform and
discuss this very significant change consisted of these two meetings. Although attended by
a total of 45 people almost half were not Rainier Valley residents and only 16 lived in
the 98118 zip code where almost all of the Rainier Valley at-grade light rail would be
built. No business owner or resident living or doing business on Martin Luther King Way
South, the proposed route of the at-grade light rail, was present. No representatives from
the Vietnamese or other adversely impacted minority business communities along Martin
Luther King Jr. Way were present (see agenda and sign in sheets from "Southeast
Seattle Community Meeting" of September 6th and 13th 1994).
After these two meetings with minimal community participation or discussion the RTA
treated the at-grade alignment through the Rainier Valley as a foregone conclusion.
The RTA baited the community extolling the benefits of a subway system and then afterwards switched in two increments to the current at-grade alignment (see RTA flyer of August 5, 1994). According to the RTA this was done to save money. At about this same time proposed less expensive at-grade alignments were being proposed by staff and rejected by the Sound Transit (RTA) Board for several communities through north Seattle in favor of expensive tunnel alignments. Proposed expenditure in the FEIS for at-grade in the Rainier Valley was $47 million per mile. For tunnels north of downtown Seattle the amount was about $190 million per mile and probably will be that much or more in future phases if building tunnels through north Seattle continues to be the preference of the Sound Transit Board.
The unwillingness of the Sound Transit Board and Staff to work toward any reasonable compromise, even in the face of federal litigation and overwhelming community opposition leads me to strongly believe that at-grade light rail in the Rainier Valley is being driven by real estate acquisition and development not honest transportation planning. Elevated rail in the Rainier Valley would cost about the same as at-grade rail with many fewer destructive impacts. SCI Construction is building the extension to Vancouver, Canadas elevated Sky train for about $50 million per mile. Sound Transit has repeatedly refused to consider elevated or tunnel alignments as options.
Late in 1998 former Seattle Mayor and Sound Transit Board member Paul Schell had a meeting in his office with about 20 prominent Rainier Valley community members who strongly opposed the at-grade light rail in the community. Mayor Schell began the meeting by informing us that the kind of development he wanted in the Rainier Valley could only be achieved with an at-grade light rail alignment and that the Rainier Valley would get at-grade and only at-grade light rail, end of discussion. Intransigence such as we saw at that meeting and which has been the hallmark of Sound Transit in its response to the Rainier Valleys concerns for over three years. Such intransigence finds its source in motives not readily discerned. It makes no sense to build a train through a heavily trafficked community that will go at slow speeds and cause accidents when a fast regional rail system is the goal unless there are ulterior motives.
Only at-grade light rail can enable extensive property condemnation, destruction of the communitys economic base, general destabilization of the community and dislocation of current residents and businesses. I believe that there is a strong likelihood of collusion between Sound Transit Board members promoting the at-grade alignment and others who might profit in destroying the current community in the Rainier Valley. I do not believe this is beyond the realm of what is possible and we have already seen an example of Sound Transits willingness to defraud both the public and the federal government in the events surrounding the Full Funding Grant Agreement.
Signed this 7th day of March 2002