Critical Care Report

WSDOT’s Invasive Surgery Plan for Blaine, WA

A stakeholder sponsored analysis of the State’s twin roundabouts proposed for Blaine

Introduction

The City of Blaine is about to receive two roundabouts from Washington State Department of Transportation (WSDOT). The community has been told they need this project because it fixes a “traffic problem” at the two intersections (Peace Portal Drive, D Street and I-5). The funding comes from the Federal Highways Administration (FHA), and is based on a need created by the United States General Services Adm inistration (USGSA) impact in our community as they rebuild the Peace Arch facility.[1]

We, the business owners and landowners of the effected area, have serious concerns about this project on several fronts:

  1. Was the analysis of the need for the project done correctly and logically?
  2. Should federal funding have been approved for the project?
  3. Was the process to our community and local government fair and reasonable?
  4. Will our community be harmed by the project’s current design?

The answers to these questions, explored below, cause us to request the project should be delayed for further study.

Faulty Analysis - Growth Rate

Justification for road projects generally comes from a need for decreased congestion. Studies are done that project into the future. In these studies, growth rates are determined, measures of existing traffic are done; these are then combined and analyzed. Conclusions based on these processes are often used to justify projects, obtain funding, and convince a community or other government of an action. There have been two traffic studies done on the intersections, which are variously known by the roads involved, Marine Drive, Second Ave, SR548, Peace Portal Drive, D Street, and I-5. The traffic studies were done by a USGSA consultant and by WSDOT.

Projections into the future are at best educated guesses. In order to hedge those bets, traffic engineers use conservative numbers in order to prove a project meets the needs of the future, as well as to identify issues that may develop in the near term. WSDOT’s 4.5% figure[2] for yearly compounded growth at these intersections is not consistent with other highly respected sources. USGSA has done extensive analysis of the area. They hired consultant firm CH2M Hill, who performed analysis on the growth rate (among other things) in the area. The final output of this study recommended long-term compounded rates in the 1.2-2% range.[3] 2% was selected by the authors of this report to be a “conservative” long-term percentage to describe the intersections in our area. The City of Blaine has not seen long-term growth in the 4.5% projected range for any sustained period. The current rate of growth for the City of Blaine for 2007-2009 is under 1%,[4] and the projected growth between 2005 and 2020 in Whatcom County is 1.72%.[5]

Anecdotal evidence in Blaine’s commercial district supports a lower growth rate. In fact, it suggests a negative one for this part of the community. It is common knowledge in Blaine’s downtown, adjacent to the D Street interchange that four of our major retail businesses have failed in the last year. One of these has been in continual operation since the 1920’s. Another icon, Wolten’s True Value Hardware will be closing soon, bring our loss to five major retailers. The recession has hit this area hard, and at least two businesses operating close to the proposed construction will go out of business with any significant negative change in their bottom line.[6], [7]

Faulty Analysis - Safety

A need for increased safety is also an excellent reason to reconfigure intersections. At the interchanges in question, WSDOT’s own reports shows only two non-injury accidents in a 5-year period.[8] A different period of study by CH2M Hill, states, “There were no injuries on the D Street interchange ramps or along Peace Portal Drive/D Street Corridor.”[9] “D Street” in this case means both intersections on either side of I-5. Neither study shows any pedestrian or bicycle involvements.

WSDOT officials have often cited increased safety as a reason to build this project in our public sessions. Additionally, Dustin Terpening writes, “Based on the statistics I've seen, roundabouts reduce collisions by 40 percent, reduce injury collisions by 70 percent and reduce fatal collisions by 90 percent.”[10] He adds, “Roundabouts naturally slow traffic down.” Indicating the slowing of traffic is a primary reason for those statistics. We agree, the slower the traffic, within reason, the less likely collisions are to take place. With slower velocity, there will be fewer fatalities and fewer injuries in the accidents that do occur.

We don’t know where these injury and crash reduction statistics come from, but we assume they come from the often-quoted source from the Insurance Institute for Highway Safety (IIHS). The IIHS study shows a reduction of 37% for reduction in collisions and a 75% reduction in injury crashes with roundabouts over signalized intersections.[11] It is important to note this is a hypothetical study, based on “standard traffic engineering algorithms … if these intersections had been constructed as roundabouts.”[12] This is not a before and after comparison in real life as has been represented by WSDOT to our community.

Additionally, the study targeted “urban sprawl” that is typical of an area in what was once rural, and is now, suburban. Northern Virginia, used in the study, typifies this type of growth. The Central Business District within the City of Blaine is not an urban sprawl and does not share similar traffic patterns with the study area. The speed limits on the study roads often have posted limits of 45mph or more. Given our current speed limit of 25mph at the intersections, and with the existing traffic light controls, our speed is already in the target range of “15 to 20 mph”[13] that is a primary factor in these safety gains. To our knowledge no study of intersections with speeds of 25mph or less has been performed with respect to roundabout safety, although we have looked extensively. We have asked WSDOT to provide us with an “apples to apples comparison.” So far, no such study has been provided.

Conflicting information about these safety numbers in real life versus in a study environment (no matter how accurate) is presented by the accident rates recently seen at the Kellog Road and Cordata Parkway. This roundabout controlled intersection posted the highest crash rate (per million vehicles) in the City of Bellingham in 2008.[14] This would seem to directly contravene the IIHS study with real life data in at least the accident rate category, showing that computer modeling is not an exact science.

Faulty Analysis - Conclusion

We have no problem with fixing problems. Fixing them does cost money. The whole basis of the project comes from WSDOT’s traffic study. Given the incorrect and exceedingly high figure for growth given, the contradictory current growth rate, and the actual negative growth in this section of town, the conclusion “dates” of “intersection failure” cited in the WSDOT study are incorrect. Based on correct growth rates, and the CH2M Hill study, we conclude there is no compelling need to build the proposed WSDOT roundabouts.

The potential gains WSDOT has claimed in safety are not proven: no study can be provided that provides clear insight into real comparisons of safety before and after this particular roundabout project. There are no significant injuries and no significant accidents currently at the site. Combined, these elements show increases in safety can be ruled out as a compelling need to build two roundabouts in Blaine at these intersections. These facts support what Blaine residents have often told us, “There are no problems at those intersections.”

Questioning Federal Funding

Why should federal tax dollars fund this project in Blaine? The USGSA is currently building a multi-million dollar facility at the Peace Arch border crossing. As part of the Environmental Impact Statement (EIS), the USGSA included studies of both “build” and “no build” scenarios at their site. (They are building a new facility and parking lot). This is done in order to make proper comparisons between action and no action on their part. In the EIS, they make several conclusions.

Firstly, the no build situation, “the analysis of the operation in the design year (2030, the design year is always projected out into the future to ensure the project will meet longevity standards) indicated increased delays at the intersections in the study area; however the overall intersection level of service would remain at acceptable levels.”[15] This conclusion is significantly different than the WSDOT study, which claims “failure” of the intersections (both of them) in 2022 and 2024 respectively.[16] The GSA study does mention issues with “specific turning movements.” That is, they predict minor issues with the intersections in question if the GSA were not to change the existing facility.

Secondly, the consultants calculated the “build” situation. To create the comparison scenario they chose “a full shift change of 91 employees … during the design hour to represent the worst-case scenario and the greatest potential impacts associated with access to the (new GSA proposed) parking lot.”[17] The “design hour” is calculated by dividing the entire year into one-hour increments. Traffic counts are assigned to these hours, and the hours are ranked highest flow to lowest. The “design hour” is the 30th worst hour in these rankings, indicating traffic flow will be better 99.7% of the time. Because of this, and the unlikely nature of all employees leaving and coming within the same hour the authors note, “the full traffic volume that was assumed … is unlikely to occur” and further, “the potential impacts are likely to be less than those described.” In spite of this worst case and unlikely scenario, the authors still conclude, “No significant operation impacts at the intersections and the D Street interchange are projected to occur in the design year (2030).”[18]

In layman’s terms this means the projected negative impacts on the turning movements at the D Street interchange have nothing to do with the development USGSA is doing at the Peace Arch. Instead, these impacts would occur naturally as traffic levels slowly increased over this extended period of time, and they would occur without USGSA involvement. This layman’s conclusion is backed by, “The forecasted 2030 traffic volumes would occur with or without the proposed improvements to the port of entry facility.”[19] Given the conclusions of the C2HM Hill consultants, we do not believe federal funds should be provided to build roundabouts at these intersections in Blaine.

We have no doubt the changes USGSA is making to their facilities does change the configuration of I-5 to a minor degree and in particular the southbound exit ramp into Blaine. WSDOT’s website says,”we will improve the I-5, D Street interchange to match the changes GSA is making.”[20] We believe it is appropriate to reconfigure the ramps as necessary to match the USGSA changes, which is what WSDOT means in this sentence. This is a separate issue from building roundabouts in the intersections.

Fair and Reasonable Public Process

Process elements, related to these proposed roundabouts, are numerous and flawed. These include the hearing on the limited access proposed, the public meetings attended by WSDOT officials, the public’s communication with those officials, and the Blaine Council Sessions that concluded in approving the project.

In the April 29th Hearing concerning the Limited Access, City of Blaine was represented and stated, “The City cannot concur with the report until it has a clear understanding of which private property owners are affected and the full extent of the effect.”[21] The full extent of the effects is still not clear today, have not been explored or explained to the property owners or to the community. In its response, the State assumes these effects will be negligible, but has not provided sufficient evidence to support that claim.[22] Michael McAuley and Kari Miller provided the panel with testimony, which resounds with many of the truths listed in this paper and include “the potential impact to the downtown.”[23] These comments were excluded because they “do not directly pertain to the current plans for the acquisition of new limited access.”[24] It appears those plans have changed. The current WSDOT project does indeed have such impacts.

As we have demonstrated within this paper, claims by WSDOT that the project is needed are not based on sound reasoning. Therefore statements by WSDOT or its officials, that the project meets needs such as improved safety or alleviating congestion, are misleading to our community, business owners and our local government. The usual response community members have received from WSDOT staff when first questioning various elements of the project is, “Why don’t you like roundabouts?”[25] What the public wants is straight answers to serious questions, not a sales pitch. The sales pitch, along with deflection tactics, is what we have received time and again. WSDOT staff, at meetings in Blaine and through telephone and email exchange, have further confused the issues with untruths and misleading comments. Here are a few examples:

  1. Chris Damitio claims, “Though we have been discussing this work with the community since 2006, including meetings with Port officials, two open houses in April last year and meetings with numerous owners last November, last Wednesday (Feb 3, 2010) is the first we heard of any concerns with oversize vehicles.”[26] In an email response written on July 24, 2009 Dustin Terpening writes, “You also mentioned that drivers hauling boats (the source of the oversize loads) will avoid the interchange.”[27] Therefore, WSDOT was aware of the marina and its special needs. As we have pointed out to Chris, it is not our responsibility to properly design roundabouts; we are not the ones getting paid. It is WSDOT’s responsibility to know there is a marina, and that our Wharf District has specific needs that may be different from general needs. Furthermore, there is no other access to Marine Drive other than through the proposed roundabouts. The entire health and well being of our Wharf District is at stake with this project. If the roundabouts even impinge on the functioning of this district, much of their business, which is highly mobile, will go elsewhere. The entire zoning of this area will then be unable to perform its function.
  1. On 3 February 2010, at a public meeting in Blaine, Dina Swires stated, “there is no need for this project.” Chris Damitio will not state the issue so simply but does comment, “Under the current prioritization scenario’s these intersections probably would not prioritize high enough to rate improvements with our limited budgets.”[28] In layman’s terms, this means, the need is not great enough to justify the money WSDOT will spend, especially when compared to other more needy, or justified, projects. Given that WSDOT has stated time and again Blaine needs these “improvements” to fix a “traffic problem” to increase “safety” or to relieve “congestion,” these revealing comments from the engineers closest to the project stand in direct conflict with the official WSDOT position. As engineer Swires is a specialist in traffic studies, we suspect her comments reveal the real truth.
  1. As if this isn’t bad enough, our community was promised on many occasions that “no construction” would happen during the Olympics or during the pre-Olympic build up (Blaine is the primary Port of Entry to Vancouver BC, currently hosting the 2010 Winter Olympics).[29] In particular, the world was watching Blaine on the 9th of February 2010, as the Olympic Torch crossed into the USA, the only place along our border with Canada this was done. It was a distinct honor, and various significant dignitaries were present. National and international media covered the event. Unfortunately, Cascade Natural Gas (CNG) was working in the area, directly impeding traffic flow into the Blaine Central Business District. They were repositioning their gas line in preparation for the roundabouts project. Chris Damitio, when confronted about the conflict stated, “the construction ongoing was not our construction. The movement of the utilities is their responsibility and is covered under our licensing agreement with them. We don’t control CNG’s workers or their schedule. It is their project, we don’t tell them when to work.”[30] Rick Kelln, General Manager of CNG disagrees: “I wanted to assure you our construction timeline was defined per the attached Facilities Relocation Advance Authorization from WSDOT. The notification was sent out Jan 25, 2010 and had a required completion date of Feb 12, 2010.”[31] We have seen the Authorization form and agree this is what it says. CNG workers were fully active at the site on Feb 9, 2010.
  1. There is a train crossing a short distance from the proposed roundabouts. This is not a new issue. Steve Banham, Public Works Director for the City of Blaine has reported, “There are still some concerns with how the rail crossing just west of this (roundabout) will work.”[32] This was on Aug 6, 2008. You will note that nothing was or has been done about this issue. Long closures, while not frequent, do happen here in a 20 to 40 minute time frame. Significant planning needs to be done in this area, as the WSDOT plan of passing on the left is illegal, and traffic backing up into a roundabout blocks all users. This is why the FHA recommends, “If blockage is anticipated then the designer should choose…closure at the rail crossing and closure at most entries to the roundabout.”[33]
  1. The project is known to be 118 days in duration, and cost at least $6.1 million dollars. However, in all recent public discussions, and media, your staff reports 50 days construction (this is only the full closure part), and $2.8 million (which does not include WSDOT’s design cost of $3.3 million, nor costs of right of way acquisition.) Thus the public is mislead again.

When Blaine City Council considered the WSDOT proposal, they did so with the understanding the information they got was truthful. They, like the public, do not get paid to investigate, follow up on confusing and contradictory information, check facts, do research, and contact other Government agencies and so on. As a result, when Council voted to approve the project, they did so under false pretenses. New information has been made public to Council and this is why the majority of Council now favors a delay of the project in order to further answer the many questions that have arisen and that remain unanswered. Given the damaged process, we think this is the only reasonable course of action at this point.