Thanks to RLB for returning to the issue of the city’s examination of alternatives in a comment a couple of days ago. He wrote, in part:
I don’t pretend to understand the ins & outs of the Environmental Impact Statement planning and implementation, but I don’t see how your statements are supported by publicly available documents.
For example, in the City’s Alternatives Analysis, Chapter 2 has a section called “Alternatives Considered.” It says:
“The alternatives considered during screening included a No Build Alternative, a Transportation System Management Alternative, and a number of ‘build’ alternatives.Transit technologies that were examined included conventional bus, guided bus, LIGHT RAIL TRANSIT [emphasis mine], personal rapid transit, people mover, monorail, magnetic levitation, rapid rail,”
I appreciate the reference back to source documents, and I think RLB is right in saying that it is hard to understand how the light rail alternative could not have been evaluated. So let’s take a closer look.
Light rail, being the dominant form of new or planned urban rail transit systems over the past twenty years, was necessarily the most obvious alternative technology.
Beginning in the fall of 2005, the city did the preliminary screening of alternatives that RLB refers to, and published the “Alternatives Screening Memo” in October 2006. Several different alternatives were rated. Light rail was called “a strongly recommended technology“.
Recommendation – Light Rail is a strongly recommended technology for alternatives with limited portions of mixed traffic and predominately exclusive right-of-way, although the transition between the two types of service will pose technical challenges (power collection and visual impact). This technology is also recommended for analysis for alternatives with exclusive right-of-way.”
The alternatives screening memo concluded by recommending that light rail should be included among several technologies to be further considered.
But when the Alternatives Screening Report followed just a month later, several technologies had been dropped after further consideration, and just four alternatives were included in the analysis.
Transportation System Management
Light rail was not neither rejected nor included for any additional analysis. It was essentially ignored, although it could have been assumed to be included in the “fixed guideway” option.
This is suggested by a list of issues that remained “unresolved” after the Alternatives Analysis had been completed, which included: “Selection of transit technology for the Fixed Guideway Alternative (if selected)”.
Supporting this view was the city’s official response to those who commented on specific types of transit technologies during the screening analysis:
“Vehicle and system technologies will not be selected prior to the draft Environmental Impact Statement. Comments about issues related to vehicle and system technologies will be considered when specifications are developed.”
In December 2006, the Honolulu City Council adopted a “locally preferred alternative” by passing Bill 79 (2006).
In Part III of the bill, the council reserved the right to select the technology to be used, clearly indicating that the choice of a particular fixed-guideway technology was still in the future.
The council reserves the right to select the technology of the fixed guideway system for the locally preferred alternative.
AIA testified in favor of Bill 79.
AIA supports the fixed-guideway alternative…We strongly support the implementationof this system.
And, at the beginning of 2007, when Honolulu architects began pressing for a dialog on design issues, including alternatives to an all-elevated system, the city rejected their requests, saying it was too early for such discussions.
According to PBN (2/23/2007):
oru Hamayasu, chief planner for the city and county’s Department of Transportation Services, said it’s too early in the process for architects to get involved. The city’s consultant, New York-based Parsons Brinckerhoff Inc., has its own architects working on the project.
“We are sensitive to design details and we certainly would welcome the help from the AIA in the next phase when we get into design elements,” Hamayasu said. “I understand AIA’s desire to get involved early, but right now it’s really, really early.”
This view was reiterated in the legal notice published in the Federal Register announcing the city’s intent to do an EIS for its rail project (3/15/2007).
In a section on “Alternatives”, the legal notice stated:
The draft EIS would consider five distinct transit technologies: Light rail transit, rapid rail transit, rubber-tired guided vehicles, a magnetic levitation system, and a monorail system.
It went on to describe alternative alignments that would be considered. It is interesting to note that both were described as including elevated as well as at-grade sections.
The legal notice then specifically provided:
At this time, comments should focus on the scope of the NEPA review and should not state a preference for a particular alternative. The best opportunity for that type of input will be after teh release of the draft EIS. [page 12255]
The subsequent NEPA Scoping Report, published in May 2007, appeared to confirm that light rail was still an option.
Comments were received in favor of monorail, light rail, and rapid rail…No information was received that would eliminate one or more of the transit technologies currently under consideration.”
But later in 2007, more than a year before the draft EIS would be published, AIA protested to Mayor Hannemann that a “request for information” sent to rail manufacturers contained specifications that would preclude any at-grade option.
In a December 28, 2007 letter from AIA Honolulu President Peter Vincent to Mayor Hannemann, it was pointed out that the specifications were imposed by the city and were not at the suggestion of the city’s consultants.
According to comments made by the City’s transportation consultants, the decision to design an elevated system was mandated by the City and was not the result of the recommendations of industry experts.
This letter drew a heated response from the mayor, essentially telling AIA that it was too late to discuss technology choices, contrary to repeated public reassurances, legal notices, and explicit instructions over the prior two years.
Mayor Hannemann dismissed the AIA’s concerns as “11th hour opposition”.
Publication of the draft EIS and its presentation of the impacts of various alternatives, which was supposed to be the starting point for discussion of particular technologies, was still more than ten months away.
And when the draft EIS was issued, light rail was not one of the alternatives considered. It simply disappeared, without comment.
RLB is right. It’s hard to see how this could have happened, given all of those references including light rail among the alternatives to be studied. But light rail, the most widely used urban transit technology and the most obvious alternative, was ultimately ignored and dismissed without comment or explanation.