August 26, 2019
Mr. Roger Millar
Secretary of Transportation
310 Maple Park Ave. SE
Olympia, WA 98504
Dear Secretary Millar:
We are writing this letter to call your attention to issues, concerns and findings regarding traffic management plans on the SR162 corridor.
Over the past several months, the SR162 Community Group has met with City Council members in Orting and Sumner, Pierce County Public Works, Pierce County Executive Bruce Dammeier, and Council members Pam Roach and Dave Morrell. There have been additional face-to-face meetings with elected state representatives in Legislative Districts 2, 25, and 31.
During this time, our group has created a website summarizing how the new Tehaleh access corridor will impact SR162, offering solutions to this impending traffic crisis. There was a feature article in the News Tribune describing a “roundabout kerfuffle” between the community and WSDOT. The SR162 Community Group’s work resulted in a proposal being included in the 2019 Transportation Bill directing WSDOT to follow Pierce County’s EIS for a traffic signal in lieu of a roundabout at the SR162/128th St. E. intersection. This inclusion was an indication of the strength of the County’s EIS and the validity of the community’s concerns. This portion of the transportation bill was vetoed by Governor Inslee.
Governor Inslee’s Veto:
While we recognize that WSDOT has authority over the county on state highways, it seems the strength of the legislature’s inclusion of this recommendation in the Transportation Bill would indicate the need for further study. The SR162 Community Group has concluded that Governor Inslee’s veto was based on inaccurate and incomplete information. This view is shared by the community leaders and elected officials cited above.
Examples of issues and fact findings relating to this assertion are as follows:
The WSDOT perspective was skewed because key stakeholders were not included or involved. Not one single valley resident, business owner, farmer or Alderton-McMillin Community Planning Board member was invited. Furthermore, just two open houses were conducted and both were held at inopportune times.
Required SEPA/EIS reviews were not conducted by WSDOT. EIS reviews provided by Tehaleh and Pierce County are irrelevant because the former calls for only an improved intersection while the latter calls for a traffic signal at the intersection of SR162 and 128th Street E.
Without an EIS, WSDOT failed to fully consider the Rural Neighborhood Center designated at the 128th St. E. Intersection. (Because the roundabout footprint is much larger than the traffic signal, the RNC is all but eliminated.)
The Alderton-McMillin Community Plan (an approved part of the County and State Plan) states that the “overall aim and vision for the valley is to retain its rural character in building and development.” A roundabout of this magnitude is in direct conflict with that plan.
The impact of a roundabout on the uncontrolled access points to SR162 has not been considered. There are approximately 140 such access points between Orting and Sumner. Eighteen of those access points serve 518 residences. By allowing traffic flow without the breaks a traffic signal provides, access to SR162 – already difficult and dangerous – becomes almost impossible.
There has been no request for a technical analysis on left turns and access from the south during PM commute hours at the 128th St. E. intersection. WSDOT representatives have been unable to identify an example of a roundabout that offers a viable solution when traffic is heavy from all directions with a predominant left turn during PM commute hours (WSDOT documents about 2000 vehicles per hour.)
WSDOT analysis did not include a specific truck or school bus count. (There is a nearby rock quarry where up to 90 trucks per hour with trailers up to 90-feet long will need access via the proposed roundabout during business hours, 6:00 a.m. to 4:00 p.m. There are two school districts that have many stops along this corridor.)
Regarding safety, the volume of traffic mixing 90-foot long gravel trucks, semis, box trucks and cars at this intersection executing a full left turn (2000 per hour) from SR162 to 128th St. E., is far more likely to cause more accidents, not fewer. There are only 3.4 minor accidents at this signal-controlled intersection per year. There have been no fatalities in the past 10 years. Safety improvements claimed are only true for single lane roundabouts while this one will be at least two lanes with an additional third lane for through traffic southbound.
Summary and Request for Action:
By failing to conduct an EIS, including “Context Sensitive Design” as described on the WSDOT website, or consider issues and facts outlined above, WSDOT’s actions coupled with the Governor’s veto, constitute a direct override of citizen involvement, input, and legislative intent.
As we move forward, it is the sincere hope of the SR162 Community Group that our efforts will result in a mutually cooperative and productive relationship with WSDOT as we continue to work with affected valley stakeholders and our legislative and community leaders at all levels. Because the vision of WSDOT stated for this corridor and the vision stated in the Community Plan are in complete harmony, we believe we can work together to find the best solutions to the difficult problems of traffic management on the SR162 corridor.
Thank you in advance for your consideration of the issues outlined above. The courtesy of a reply is requested to acknowledge receipt of these concerns and a statement of the action steps you will initiate and authorize to address them.
The SR162 Community Group
September 24, 2019
Dear Ms. Herbert-Hill:
Thank you for contacting Washington State Department of Transportation Secretary Roger Millar. I am the Regional Administrator for WSDOT’s Olympic Region, which includes Pierce County, and I have been asked to respond to your recent letter on behalf of Secretary Millar. My apologies for the delay in responding.
First of all, I would like to commend your group for its energy and dedication towards the wellbeing and preservation of your community. From the number of times WSDOT staff have been invited to and attended local meetings, coupled with the number of letters and emails we have received and responded to, I believe that our previous communications have answered the technical questions you raised in your August 26 letter. With that in mind, I would like to focus this message on WSDOT’s role on SR 162 as it relates to recent development in the Sumner and Orting area.
Pierce County is responsible for making land use decisions and determining the levels for allowable development in your community. Because of this, it is their responsibility to work with their developer to perform the necessary analysis and environmental documentation to approve the new Rhodes Lake Road corridor and make the needed improvements to connect it up to SR 162. The State Legislature has not provided funds to make improvements to the highway, other than for the two planning studies, which means that WSDOT is not the agency leading the planned improvement projects you reference. WSDOT’s only role has been review and approval of the plans submitted by Pierce County and the developer, and to verify the appropriateness of the traffic mitigation.
I would like to take this opportunity to clear up any confusion regarding an Environmental Impact Statement (EIS): the State Environmental Policy Act (SEPA) is the framework for environmental review of projects that may result in adverse environmental impacts. Out of the SEPA review, an environmental document, such as an EIS, is required and is the responsibility of the lead agency reviewing the project. In the case of improvements to the SR 162 and 128th Street East intersection, Pierce County has a project proposal and therefore is the lead agency tasked with completing the SEPA EIS. Pierce County completed SEPA review with the New Rhodes Lake Road East Final EIS in May of 2018. While the roundabout design may result in a slightly different footprint, we expect it will fall well within the overall scope of impacts analyzed for the New Rhodes Lake Road East project proposal.
An Intersection Control Evaluation was jointly prepared by WSDOT, Pierce County and the New Rhodes Lake Road developer in July 2018. The evaluation results showed that a roundabout significantly outperforms a traffic signal at this location with increased throughput and shortened queue lengths. WSDOT will require the installation of a roundabout for this intersection to best address the impacts to the state highway system. The modification to intersection treatment and overall new arterial road proposal would be within the scope of the May 2018 SEPA analysis completed by Pierce County. WSDOT does not expect extensive SEPA documentation to be required for this design revision. We are having conversations with the County to resolve the issue at 128th Street to best addresses the inconsistency between the County’s SEPA document and the approved Intersection Control Evaluation to best serve the needs of both the County and State system.
Again, thank you for your interest and engagement on this issue.
John Wynands, P.E.