HomeMy WebLinkAboutResolution No. 2016-43the cibai/
Suggested by: Administration
CITY OF KENAI
RESOLUTION NO. 2016 -43
A RESOLUTION OF THE COUNCIL OF THE CITY OF KENAI, ALASKA, OPPOSING THE
SELECTION OF G -SOUTH AS THE PREFERRED ALTERNATIVE FOR THE STERLING
HIGHWAY MP 45 -60 PROJECT AND SUPPORTING THE JUNEAU CREEK
ALTERNATIVE.
WHEREAS, the Sterling Highway MP 45 -60 (Cooper Landing Bypass) project has been
under consideration by the Alaska Department of Transportation and Public Facilities
( "DOT &PF") and Federal Highway Administration ( "FHWA ") for numerous years; and,
WHEREAS, a Draft Supplemental Environmental Impact Statement (SEIS) and Draft
Section 4(f) Evaluation were released for public review in April and May 2015 ; and,
WHEREAS, on December 11, 2015, DOT &PF and FHWA announced the identification
of the G -South Alternative as the preferred alternative for the project; and a final SEIS
and Record of Decision (ROD) are expected in 2016; and,
WHEREAS, the DOT &PF and FHWA recognized the importance of protecting the Kenai
River Corridor in the purpose of the project and included reduced risk of spills in the
Kenai River as a benefit of the project; and,
WHEREAS, the G -South alternative does not adequately protect the Kenai River
Corridor; and,
WHEREAS, the Juneau Creek Alternative bypasses all crossings of the Kenai River,
while the G -South route will require an additional crossing and replacement of an
existing bridge; and,
WHEREAS, a substantial portion of G -South would be built on the existing alignment
near the river, such that 45 percent of the G -South Alternative is within 500 feet of the
Kenai River or another Tier 1 stream, as opposed to 25 percent of the Juneau Creek
Alternative; and,
WHEREAS, a small portion of the congressionally - designated Mystery Creek
Wilderness Area and the southern end of the Resurrection Pass trail would be
impacted by the Juneau Creek Alternative; and,
WHEREAS, long -term protection of the Kenai River, the opportunity to prevent a major
chemical spill in the river, and the opportunity to significantly decrease traffic
adjacent to the river, should take priority in the selection of an alternative.
NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF KENAI,
ALASKA, that:
SECTION 1. That the Kenai City Council opposes the selection of the G -South
alternative as the preferred alternative for the Sterling Highway MP 45 -60
Project.
SECTION 2.That the Kenai City Council supports the selection of the Juneau Creek
Alternative as the preferred alternative for the Sterling Highway MP 45-
60 Project.
SECTION 3. That the Kenai City Council urges Governor Bill Walker, all state
legislators representing the City of Kenai, Marc Luiken, Commissioner of
DOT &PF and Sandra Garcia - Aline, the Division Administrator of the
FHWA to reevaluate the selection of G- South, and give adequate weight
to the protection of the Kenai River.
SECTION 4. That a copy of this resolution shall be provided to DOT &PF, FHWA.
SECTION 5. That this resolution takes effect immediately upon its adoption.
PASSED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA, this 5th day of October,
2016.
PORTER, PAT MAYOR
KENAI PENINSULA BOROUGH
144 North Binkley Street • Soldotna, Alaska 99669 -7520
pp Toll -free within the Borough: 1- 800 - 478 -4441 Ext. 2150
f� PHONE: (907) 714 -2150 • FAX: (907) 714 -2377
www. mayor. kenai. ak. us
Mike Navarre
Borough Mayor
September XX, 2016
Kelly Peterson, PE
Project Manager
Alaska Department of Transportation and Public Facilities
P.O Box 196900
Anchorage, AK 99519 -6900
RE: Sterling Highway Milepost 45 -60 Project
Dear Ms. Peterson:
We are writing this letter to request a delay of Record of Decision (ROD) on the Sterling
Highway MP45 -60 project until a determination is made on the prospective land exchange
between the Cook Inlet Region Inc. and the Kenai Wildlife Refuge. This exchange, authorized in
the Russian River Land Act', is currently under consideration and would result in a change in
land status of the potentially impacted portion of the Mystery Creek Wilderness Area.
Upon this determination, we request a reconsideration of the selection of G South Alternative as
the preferred alternative. We ask that this selection is reevaluated in consideration of both the
land exchange and the following comments in opposition to the selection of G South.
We have significant concerns regarding the analysis that led to the selection of the G South
alternative. There are three areas of concern this letter discusses.
1. Purpose and need: The DSEIS fails to recognize the long term protection of the Kenai River
as a key element of the purpose and need for this project.
2. Impacts of the G South alternative to the Kenai River: We have concerns that the
assessment does not fully consider the impacts to the Kenai River, and have concerns with
the relative lack of weight that these impacts were given in the selection of a preferred
alternative.
3. Lack of input on G South Alternative: A number of historical factors, including the
previous selection of different preferred alternatives and the length of time this project has
been ongoing, create a unique situation where stakeholders and the public were unlikely to
provide input specific to G South. As such, ADOT &PF and the FHWA should formally
solicit, consider, and respond to, comments on their selection prior to the ROD.
1 Russian River Land Act, Pub. L. No. 107 -362, 116 Stat. 3021
Page 1 of 5
If the Kenai River were given the proper weight in the analysis and if the protection of the Kenai
River were recognized as part of the purpose and need for this project, we believe a different
preferred alternative would have been selected.
1. Purpose and need
Draft SEIS 1.2.1 Project Purpose
"The purpose of the project is to bring the highway up to current standards
for a rural principal arterial to efficiently and safely serve through - traffic,
local community traffic, and traffic bound for recreational destinations in the
area, both now and in the future. In achieving this transportation purpose,
DOT &PF and FHWA recognize the importance of protecting the Kenai River
Corridor"
Although DOT &PF and the FHWA recognize the importance of protecting the Kenai River
Corridor in the overview of project purpose, this importance is not carried through to any of the
three listed needs. We believe that - although not explicitly stated as a need in this DSEIS -
protection of the Kenai River Corridor has historically been understood by the public and
stakeholders as an important reason for this project. Failing to move a substantial amount of
traffic away from the river and accepting the risk of a catastrophic hazardous spill in the Kenai
fails to realize a fundamental benefit of this project, We believe that an alternative that does not
move the highway off of the Kenai River Corridor does not meet the purpose and need of this
project. As such, regardless of the 4(f) analysis, G South should not be selected.
In addition inadequately protecting the Kenai River Corridor, G South Alternative does not meet
the stated purpose and need as well as the Juneau Creek Alternatives. While G South does
bypass Cooper Landing proper, it fails to bypass Segment 5 (MP 51.3 - 55.09), the section of the
project with the highest crash rate cited in the DSEIS. This area, particularly the segment
between the Russian River Ferry Entrance and Russian River Campground, is a frequently
congested area with multiple parked vehicles and pedestrians along the road during peak summer
fishing season.
Bringing the highway up to current design standards but failing to bypass this segment does not
improve safety for recreational users and pedestrians as well as moving the majority of traffic
away from the area. Many fishermen will continue to travel along and cross this section of the
road, and the higher traffic speeds may increase the potential severity of an accident if it does
occur.
II. Impacts to the Kenai River
We believe that, in the analysis that lead to the selection of G South as the preferred alternative,
impacts to the Kenai River were not given adequate weight. While we recognize the complexity
of this process, and are aware of the impacts each alternative will have on important habitat and
recreational opportunities, sustained impacts to the Kenai River were shown less concern in the
Page 2 of 5
selection process than impacts to the Mystery Creek Wilderness Area, Resurrection Pass Trail,
and the Juneau Falls Recreation Area.
Failure to Avoid Impacts of Potential Spills
Draft SEIS 3.17.2.4 G South Alternative P 2 Spill Risk
"Approximately 64 miles of the alignments (45 percent) would be within
500 feet of the Kenai River and other Tier I streams, of which about 4.7 miles
(33 percent of the total) would be within 300 feet. The G South Alternative
has moderate exposure to Tier II streams and wetlands that are
hydrologically connected to the Kenai River. A substantial portion of this
alternative would be built on the existing alignment near the Kenai River"
Draft SEIS 3.17.2.5 Juneau Creek and Juneau Creek Variant Alternatives
"Both of these alternatives have moderate exposure to steep side slopes and
high exposure to wetlands. However, these alternatives provide separation
from the Kenai River and other streams over the longest distance, likely
providing responders more time to protect the Kenai River in the event of a
Spill. "
Forty -five percent of the G South Alternative remains within 500ft of the Kenai River or other
Tier 1 Waterbodies, compared to 25% of the Juneau Creek Alternative. 33% of G South is within
300 feet of a Tier 1 stream, compared to 15% of Juneau Creek. The separation provided by the
Juneau Creek Alternative, which moves 75% of the route more than 500ft away from a Tier 1
waterbody, provides responders with extra time to protect the Kenai River in the event of a
hazardous spill. This difference is acknowledged within the DSEIS; however, these risks are
minimized citing that "the highway would be reconstructed throughout to meet current standards
and improve safety ". Improved safety along the corridor - while marginally decreasing the
likelihood of an accident - does not eliminate the risk nor does it mitigate the impact a spill will
have when it occurs. In order to mitigate ° the impact a hazardous spill will have, the road must be
moved away from the river to the maximum degree reasonably possible.
Limitations of Emergency Response and Cleanup Capabilities
Emergency Response Assessment Hazardous Materials Spills (HDR 2003b)
3.4 Constraints to Emergency Response and Cleanup
The distance over which some emergency response teams would have to
travel to reach a hazardous materials spill along the Sterling Highway
between MP 45 and MP 60 can increase the risk of release to resources
within the spill migration pathways. In addition, the ability of regional
responders to respond to and clean up an accidental spill can be impaired by
weather conditions and the accessibility of the spill. Temperatures along this
section of the Sterling Highway are often near freezing, which frequently
Page 3 of 5
causes "black ice " on the roadway surface, which creates hazardous driving
conditions. Snow on the roads can slow travel to the spill site, as well as
hinder spill control activities. Steep slopes can make access to the spill
difficult and impair the ability to set up spill control equipment.
Limited regional capability to respond to significant spills in this area, due to both the capacity of
local volunteer agencies and the geographic limitations of the area, considerably increase the risk
posed by failing to move the majority of traffic off of the Kenai River Corridor. The 2003 risk
evaluation, Emergency Response Assessment and Hazardous Material Spill Control lays out
these limitations in detail. Due to the constraints of the area, and the likelihood of a delayed
response to a spill, the additional response time that the Juneau Creek Alternative gives local
responding agencies is a crucial consideration and should be given high priority in the analysis.
Sustained impacts on the Kenai River and other Tier I Waterhodies.
In addition to the potential impact of hazardous spills, G South also sustains or increases a
number of existing impacts to the Kenai River and riparian habitat. -G South not only fails to
move the majority of traffic away from the corridor — maintaining current general runoff impacts
due to heavy traffic immediately adjacent to a Tier 1 waterbody — but also requires additional
river crossings. The Juneau Creek alternatives bypass all crossings of the Kenai River, whereas
the G South route will require an additional crossing and the replacement of the existing bridge
at Schooner Bend. Additionally, several more small stream and drainage crossings are required
under the G South alternative. We maintain that, by selecting G South as the preferred
alternative, DOT &PF and FHWA have highlighted the Juneau Creek alternatives' impact on
wetlands and human recreation, while showing less concern for these substantial encroachments
on the Kenai River.
Relative weight of the Kenai River compared to other elements
Protecting the Kenai - a resource crucial to the environmental, cultural, recreational, and
economic health of this region - should receive as much, if not more, weight in the decision
making process as an administrative boundary such as the Mystery Creek Wilderness Area. The
Mystery Creek wilderness area is an extremely small portion of this project, yet carries an
outsized weight due to the administratively complex process needed to build in the area.
Conversely, moving the road away from the Kenai River - an important resource heavily
impacted by a large portion of the project area - is not being given high priority consideration in
this project.
Additionally, we recognize that the Juneau Creek Alternative will bisect the south end of the
Resurrection Pass Trail and the Juneau Falls Recreation area. We recognize that planning efforts
and restraint in development are necessary to mitigate the impacts of the Juneau Creek
Alternative to this area. However, we are confident that, were the Kenai River given the
appropriate consideration in this analysis, the value of long term protection of the Kenai River
would outweigh the impacts of shortening the trail.
Should an accident due to the location of the road negatively impact the health of the Kenai
River, the environmental impacts would be extensive and the economic wellbeing and livelihood
of borough residents would be significantly impacted. Although the impacts of the Juneau Creek
Page 4 of 5
routes are concerning, they do not outweigh the opportunity to prevent a major chemical spill or
the opportunity to dramatically decrease general traffic adjacent to the river.
III. Lack of Agency and Public Comments on G South Alterative
This project has been ongoing in some form since the early 1980's. There have been multiple
DEISs, scoping periods, and public comment periods. It is not practical to assume continuous
extensive public engagement with the process over such a long time period. Upon DOT &PF and
FHWA making a noteworthy announcement about the preferred route, numerous stakeholders
that were otherwise disengaged voiced significant concerns. Given that it failed to meet a
perceived need of the project, many of these stakeholders did not consider G South a likely
option and therefore, did not submit comments specifically regarding this alternative. As such,
comments focused on the impacts of the other options and the necessity for further study and
mitigation of those impacts. Given the unique history and the likelihood of public disengagement
over such a lengthy project period, we believe that ADOT &PF and the FHWA should solicit and
respond to comments on their preferred alternative before a final decision is made.
We recognize there are numerous concerning impacts of all alternatives that need to be
addressed. We request awareness of those issues and that mitigating steps are taken to minimize
impacts on wildlife for all of the alternatives. However, we strongly oppose the selection of any
alternative that fails to protect the Kenai River and believe.that the protection of such a crucial
resource should receive the highest priority in the decision making process.
Please consider these comments in your reconsideration of the alternative.
Sincerely,
Mike Navarre
Kenai Peninsula Borough Mayor
Page 5 of 5
From:
Jack Sinclair
To:
Ramooni Angela
Subject:
Cooper Landing Bypass
Date:
Wednesday, August 24, 2016 9:02:12 AM
Angela,
The Kenai Watershed Forum urges the Kenai Peninsula Borough to seek a reconsideration of
the State of Alaska DOT's decision to move forward with the G South Alternative for the
Cooper Landing Bypass project, MP 45 -60 of the Sterling Highway.
From an environmental perspective, there are no ideal options offered by any of the alternatives. Each will have its own
impact on important habitat for a variety of plant, fish, and wildlife species. An argument can be made for each one being
better than the other depending on how you prioritize brown bear and moose habitat versus fish habitat, or loss of wetlands
versus potential water quality degradation etc. The fact is that each alternative will result in negative environmental
consequences. That being the case, the DOT highlights the Juneau Creek altematives' impact on wetlands and human
recreation, while showing less concern for the fact that the G South route will sustain substantial encroachments on the Kenai
River and other noted Tier I Waterbodies.
The key difference between the G South and Juneau Creek alternatives is that the Juneau Creek Alt has the ability to direct
major traffic flow (especially commercial vehicles transporting hazardous materials) away from the river. With 75% of the
Juneau Creek alternatives being 500 ft or more from the river, response personnel will have additional time to contain
potential HAZMAT spills before they cause serious harm to the Kenai River and its tributaries. The Juneau Creek alternatives
bypass all crossings of the Kenai River, whereas the G South route will require an additional crossing and the replacement of
the existing bridge at Schooner Bend.
Additionally, several more small stream and drainage crossings are required under the G South alternative. Although the
greater percentage of wetlands and wildlife habitat impacted by the Juneau Creek routes are conceming, it does not outweigh
the opportunity to prevent a major chemical spill or the opportunity to dramatically decrease general traffic adjacent to the
river.
A possible compromise that needs to be investigated further is to extend the western end of the G South Alternative out to MP
55 to avoid a longer portion of the Kenai River AND do away with the building of an additional bridge across the Kenai
River, perhaps saving $50 million from this alternative.
It is unfortunate that every alternative to this point has its shortcomings where challenges must
be faced regarding sensitive cultural resources, wildlife habitat and congressionally - designated
Wilderness. Weighing the potential impacts to each of these against those to the Kenai River
and other Tier I Waterbodies is a difficult but necessary task from which we must now make a
decision.
Thanks for allowing Kenai Watershed Forum to provide our input.
Sincerely,
Jack Sinclair
Jack Sinclair
Executive Director
Kenai Watershed Forum
44129 Sterling Highway
Soldotna, AK 99669
KENAI PENINSULA BOROUGH
144 North Binkley Street • Soldotna, Alaska 99669 -7520
a Toll -free within the Borough: 1- 800 - 478 -4441 Ex. 2150
y� PHONE: (907) 714 -2150 • FAX: (907) 714 -2377
J( www.kpb.us
MIKE NAVARRE
BOROUGH MAYOR
MEMORANDUM
TO: Blaine Gilman, Assembly President
Members, Kenai Peninsula Borough Assembly
FROM: Mike Navarre, Mayor
DATE: August 25, 2016
SUBJECT: Resolution 2016- , A Resolution Opposing the Selection of G -South as the
Preferred Alternative for the Sterling Highway MP 45 -60 Project and Supporting
the Juneau Creek Alternative (Mayor)
This resolution opposes the selection of G -South as the preferred alternative for the Sterling
Highway MP 45 -60 project, and supports the selection of Juneau Creek Alternative as the
preferred route.
The Sterling Highway MP 45 -60 Project, commonly referred to as the Cooper Landing Bypass,
has been under consideration by the Alaska Department of Transportation and Public Facilities
( "DOT &PF ") since the early 1980's. The current Supplemental Environmental Impact Statement
( "SEIS ") process for the highway was initiated in 2000.
The purpose of the project is to bring the Sterling Highway through MP 45 -60 up to current
design standards, reduce highway congestion, and improve highway safety. In achieving this
purpose, DOT &PF and the Federal Highway Administration ( "FHWA ") recognized the
importance of protecting the Kenai River corridor. Benefits of the project include increased
safety for motorists and pedestrians; improved access to local properties and recreation
opportunities along the existing highway; improved travel time through the area; reduced noise,
dust, and traffic in Cooper Landing proper; and reduced risk of spills in the Kenai River.
After the assessment of various alternative routes for the highway throughout the years, four
build alternatives were analyzed in detail in the 2015 Draft SEIS: G -South Alternative, Juneau
Creek Alternative, Juneau Creek Variant, and Cooper Creek Alternative. The Draft SEIS was
released in April 2015, and DOT &PF and the FHWA announced the selection of G -South as a
preferred alternative in December 2015. A Final SEIS and Record of Decision ( "ROD ") are
expected before the end of 2016. There will not be a formal comment period after the release of
the Final SEIS before a ROD on the route.
August 25, 2016
Page Two
Attached to this memo is the DOT &PF project overview, which outlines the costs and proposed
routes of each of the considered alternatives. Of particular note, the G -South Alternative has an
estimated construction cost that is almost $54 million more than the Juneau Creek Alternative.
Concerns with G South Alternative
There are significant concerns with the selection of the G -South Alternative and the continued
risk that it poses to the Kenai River. While it is recognized that this is a complicated process and
that each alternative will have an impact on important habitat and recreational opportunities,
sustained impacts to the Kenai River were shown less concern in the selection process than
impacts to the Mystery Creek Wilderness Area, Resurrection Pass Trail, and the Juneau Falls
Recreation Area. The selection process also failed to recognize long term protection of the Kenai
River Corridor as a key element of the purpose of this project.
Comments from the Kenai Watershed Forum concerning the impacts of G -South are attached to
this memo. The G -South Alternative maintains substantial encroachments on the Kenai River
Corridor, and does not significantly decrease traffic immediately adjacent to the river. A
significant portion of this alternative would be built on the existing alignment near the river, and
an additional bridge would be built over the Kenai River. Forty -five percent of the G -South
Alternative remains within 500 feet of the Kenai River or other Tier 1 Waterbody, compared to
25 percent of the Juneau Creek Alternative. The separation provided by 75 percent of the Juneau
Creek Alternative gives first responders more time to protect the Kenai River in the event of a
hazardous spill.
When the Kenai River is given as much emphasis as other significant areas along the proposed
route, the G -South Alternative is neither the least harmful nor does it achieve one main purpose
of the project — moving traffic away from the Kenai River. The benefit that G -South does offer
over other alternatives is an easier path to completion due to avoiding administrative boundaries
associated with the congressionally - designated Wilderness.
Your consideration is appreciated.