| I-69 Draft Environmental Impact Statement
Indianapolis MPO Comments INTRODUCTION Thank you for providing the Indianapolis MPO the opportunity to comment on the I-69 Draft Environmental Impact Statement. The MPO will limit its comments to those alternatives shown in the DEIS as being preferred, as well as the no-build alternative. Further, the MPO will confine its comments to the area within the MPA boundary and will focus its comments primarily on the regional transportation network, air quality impacts and social and environmental considerations should a build alternative be selected. The recommendations at the conclusion of this transmittal are not intended
to be an endorsement for any of the alternatives presented in the DEIS.
Endorsements would come from the Indianapolis Regional Transportation Council
once a project has been submitted to the MPO for inclusion in the Indianapolis
Regional Transportation Plan and Indianapolis Regional Transportation Improvement
Program and detailed analysis has identified impacts and recommended appropriate
mitigation measures.
NETWORK AND TRAFFIC IMPACTS The traffic impacts discussed below are consistent with the level of analysis contained in the DEIS. Until detailed alignments and modeling are conducted of the regional transportation plan, only broad examination of network and traffic operations are possible. Alternative 4B Alternative 4B utilizes I-70 west from I-465 to a new interchange in western Morgan County where I-69 would then travel south on new alignment to an intersection with existing State Road 67 near Paragon. Because Alternative 4B is the only alternative that would not use the SR 37 corridor, there are no network impacts associated with this alternative. Even with the increased traffic volumes projected on I-70 of roughly 10%, no changes to the regional or local network would be required. Capacity on I-70 west would be sufficient to adequately handle the increased traffic without additional changes to the network, over and above what is already planned. It is important that close coordination occur with the planned north-south corridor in Hendricks County, the planned Six Points Road/Airport interchange and the Suburban Mobility Study when considering this alternative. I-465 Alternative 4B, which utilizes I-70 from the west to access I-465 has the least impact on I-465, with minor increases in VMT (vehicle miles of travel) of up to 5%. All of the other alternatives that utilize the SR 37 corridor to access I-465 would have significant impacts on I-465. These range from 1% to 34% increase in VMT on I-465 between Airport Expressway and I-65. I-70 Corridor Alternative 4B would increase traffic on I-70 within the MPA by roughly 10%. However, the DEIS indicates that levels of service would remain acceptable. Alternatives 2C, 3B, 3C, and 4C Each of these alternatives includes the option of using Mann Road or
SR 37 to reach I-465. The impacts to the regional and local network
differ depending on which corridor is used to reach I-465.
This option would follow the existing SR 37 corridor into Marion County to Edgewood Avenue where it would then proceed north on new alignment to I-465 just west of the existing SR 37/Harding Street interchange. This option could have significant impacts on the local arterial street network and would require modifications to insure that the local arterial system and local circulation systems remained viable. This would presumably include existing SR 37 as a collector distributor in some fashion, collecting traffic to and from I-69 to the regional and local street network. This option does not include any interchanges north of the Marion/Johnson County line other than at I-465. Depending on the function of the C-D system along SR 37, this could be a significant concern. SR 37 plays a significant role in funneling north-south traffic to and from I-465 as well as into downtown Indianapolis. Any alternative that would disrupt this flow of traffic would have potentially significant impacts to regional travel. SR 37 also provides significant access to local residential subdivisions as well as large amounts of commercial and industrial development. Of great importance to the regional network would be the intersection of Southport Road and SR 37. Southport Road is a cross-county primary arterial connecting I-65, SR 37, SR 67 and the proposed Six Points Road interchange with I-70. This arterial also provides the only crossing of White River south of I-465. The DEIS does not show an interchange at this location, nor does it elaborate on how the important arterial functions of these facilities will be handled. It is important to insure that either an interchange is provide at this location or alternatives are provided that allow Southport and SR 37 to function as the important regional arterials that they are. Also of great importance would be the maintenance of access from Harding
Street to I-465. Because this option includes a new interchange west
of the current I-465/Harding Street N SR 37 interchange there is concern
that local access, not only to commercial establishments in the immediate
vicinity, but also to Harding Street might be disrupted.
There are also a number of important local collectors and thoroughfares that intersect with or cross SR 37 currently that would have to be maintained in order to continue to serve the developed and developing commercial, industrial and residential areas along the SR 37 corridor. Thoroughfares include Thompson Road, Edgewood Avenue, Stop 11 (proposed connection to SR 37) and County Line Road. Important local collector streets include Epler Avenue, Banta Road and Wicker Road. In addition, Blemont Avenue runs parallel to SR 37 between Southport Road and Epler Avenue, providing access to local development west of SR 37. Another important consideration is the intersection of Bluff Road with SR 37. Bluff Road is an important primary arterial that runs from near downtown Indianapolis southwest to an intersection with SR 37 just north of the Marion/Johnson County line. Bluff Road not only serves as an important regional arterial for residential development in Marion County, but it also provides an alternative corridor for commuters to and from downtown Indianapolis. It will be important to maintain access to Bluff Road regardless of which build alternative might be selected. Mann Road corridor option The second possible option would include a new terrain route through relatively undeveloped agricultural land to an intersection with Mann Road at the Morgan/Marion County line. This option would then run north roughly along Mann Road to a proposed interchange at Southport Road. A proposed interchange with I-465 would be located at the existing Mann Road interchange with I-465. The existing interchange would have to be reconfigured to accommodate interstate to interstate traffic. This option could have significant impacts on the local arterial street network and would require modifications to ensure that the local arterial system and local circulation systems remained viable. It is unlikely that Mann Road would exist in its current form and thus significant changes to local access and commuting patterns would result. Mann Road is a primary arterial running from its intersection with Kentucky Avenue north of I-465 south well into Morgan County. While Mann Road functionally is not as important to the regional transportation network as SR 67 to the west and SR 37 to the east, it is an important corridor for distribution of trips into and out of Marion County, as well as for localized travel within Decatur Township. The DEIS indicates that this option would have an interchange at Southport Road. Southport Road is an important east-west cross-county primary arterial. It is important that primary arterials feed the interstate system, particularly Southport Road in that there are no other east-west primary arterials in Decatur Township. There are however, secondary arterials that connect to Mann Road that would potentially be limited by the presence of an interstate highway in this corridor. Those arterials are Thompson Road, Milhouse Road and Ralston Road. Of most concern to the MPO would be the interchange at I-465, if the Mann Road option were selected. This interchange as it currently exists is only a partial interchange with ramps to and from the east. This is due primarily to its close proximity to the interchange just west of Mann Road at SR 67/Kentucky Avenue. The interchange at SR 67/Kentucky Avenue is limited due to its close proximity to the I-70/I-465 interchange and the presence of a railroad corridor parallel to SR 67 which further limits the flexibility of this interchange. Significant changes at the Mann Road interchange made to accommodate interstate to interstate traffic could have significant impacts on the SR 67/Kentucky Avenue interchange and possibly the I-465/I-70 interchange. Because these three interchanges would be so closely linked and could significantly impact one another, the MPO would require additional detailed study of how these three interchanges interrelate in the context of the improvements currently being developed to relocate and lower I-70, as well as those related to the new mid-field terminal interchange. The efficient operation of these two down stream interchanges related to access to the airport is paramount in importance to the MPO and the entire region. I-465 The current Indianapolis Regional Transportation Plan (IRTP)includes a proposed improvement to I-465 from the Airport Expressway to I-65. The specific improvements between Airport Expressway and SR 67 are being determined by INDOT as part of the planned widening of the west leg of I-465. It is not clear from the DEIS if these improvements were taken into consideration and if so, what level of service would result. Between SR 67 and I-65 the IRTP proposes a widening from 6 to 8 lanes. If a build alternative were selected that utilizes either Mann Road or SR 37, the DEIS indicates that I-465 would have to be widened to 10 lanes to adequately accommodate the projected increases in traffic. The impact of the I-69 extension on the southeast, east and northeast sides of I-465 is not specifically mentioned in the DEIS. Additional detailed analysis would need to be undertaken before specific impacts to other parts of the regional system could be determined. SR 37 Corridor Those alternatives that utilize the SR 37 corridor, increase VMT on the corridor by significant amounts. Increases in VMT in the SR 37 corridor range from 2% with Alternative 2C to 355% with alternative 3C. It is important to note however, that these increases do not necessarily translate into poor levels of service since interstate highways can carry significantly more traffic than local or regional arterial streets. Each alternative assumed the number of lanes necessary for the new interstate to maintain an acceptable level of service. Eight travel lanes would be required from SR 144 to I-465. I-65 Corridor A new north-south interstate highway from I-465 south roughly parallel to the I-65 corridor could result in some diversion of traffic away from I-65. The DEIS indicates the diversion of traffic is relatively insignificant. Decreases in traffic on I-65 from I-465 south to the County Line Road interchange would be in the range of 3% to 4% for those alternatives that make use of the SR 37 corridor. I-70 Corridor Four of the five alternatives utilize the SR 37 corridor in some fashion. As a result, traffic would be diverted from I-70 west of I-465 in the range of 18% to 26%. Conversely, alternative 4B which utilizes I-70 from western Morgan County to I-465 would increase traffic on I-70 within the MPA by roughly 10%. However, the DEIS indicates that levels of service would remain acceptable. AIR QUALITY IMPACTS Marion County is classified as a maintenance area for the ozone pollutant. As such, capacity expansion projects considered 'regionally significant' proposed within the MPA must be analyzed using an approved methodology and computer model developed by the US EPA. The model measures the amount of pollutants that will be emitted as a result of implementing a project. The emissions cannot exceed the emissions budget specified in the State Implementation Plan (SIP) and the Indianapolis-Marion County Redesignation Maintenance Plan. Further, 'regionally significant' projects must be included in a Regional Transportation Plan and Transportation Improvement Program that have undergone a conformity determination. One of the primary objectives of the air quality analysis in the DEIS, is to identify any alternatives that would have a high likelihood of placing conformity status in Marion County in jeopardy. Final conformity of a preferred alternative would be determined in the Final EIS. Alternative 4B According to the analysis in the DEIS, of the preferred alternatives, 4B increases emissions in both VOC and CO the most over that of the no-build alternative. Emission rates per Vehicle Miles of Travel (VMT) for VOC and CO increase as one moves from the highest to lowest roadway functional classifications. Because Alternative 4B does not propose additional interstate facilities, it is logical to expect this increase. It is important to note however, that even with the increases in VOC and CO, the SIP budgets are not exceeded with this alternative. Alternatives 2C, 3B, 3C, and 4C All alternatives other than the no-build increase VMT in the MPA. This results in changes in the emissions over that of the no-build alternative. In this case, the no-build alternative would be the Indianapolis Regional Transportation Plan. Alternative 3B increases NOX emissions the most over that of the no-build alternative. The DEIS concludes that 'Because all alternatives fall under the SIP emissions budgets when added to the Indianapolis Long-Range Transportation Plan, the addition of any alternative to the Long-Range Transportation Plan would not jeopardize conformity with the SIP'. However, analysis conducted by the MPO at the request of Bernardin-Lochmueller & Associates of a worst case scenario that utilizes SR 37 to I-465 shows NOX emissions would be exceeded in the 2025 time period. Therefore, further detailed examination of these alternatives is recommended before the project can proceed as proposed. It is important to note again, that until a more detailed alignment
is determined and a project is proposed for inclusion in the Indianapolis
Regional Transportation Plan and TIP, a conformity determination cannot
be made.
Alternative 4B Because Alternative 4B does not include any new transportation facilities within the Indianapolis MPA, the environmental and social impacts would be minimal. The increase in traffic could result in increases of highway noise along existing interstates I-70 and I-465 within the MPA. However, these noise impacts will be examined and where appropriate mitigated as a part of already planned and in some cases programmed improvements to these facilities. Further, since traffic generated by Alternative 4B would be accommodated by existing facilities and improvements already in the Indianapolis Regional Transportation Plan, no additional environmental or social impacts would be anticipated over and above what is assumed in the Plan. Alternative 4B does not require the relocation of any homes or businesses
within the MPA, nor does it impact park land, historic properties or wellfield
areas over and above those improvements already planned along this route.
Any of the above alternatives will have environmental and social impacts within the Indianapolis MPA depending on which corridor option is used to access I-465. The option that utilizes SR 37 north into Marion County at Edgewood Avenue would utilize a well established major transportation corridor, where as the Mann Road option would develop an interstate highway along a two-lane rural and low density suburban corridor. The current and future land uses along the SR 37 corridor tend to be more appropriate for a major transportation facility where as those along the Mann Road corridor are less compatible. Alternative 4C requires the lowest possible number of relocations in the Indianapolis MPA, with 114 to 181, where as the remaining three alternatives (2C, 3B, 3C) require 139 to 230 relocations. All of these alternatives include the option of using the Mann Road corridor to access I-465. Use of this corridor would also impact several historic properties and churches. Mann Road option
There are also a number of parks existing or recommended along the corridor that could be impacted. Of special note is Southwestway Park south and east of the intersection of Mann Road and Southport Road. This park is one of few park areas in Decatur Township and was just recently doubled in size through significant efforts of local citizens, Indy Parks and developers to make it second in size only to Eagle Creek Park in northwest Marion County. The Mann Road option would potentially impact this park due to corridor right-of-way needs, as well as additional right-of-way needed to accommodate the proposed interchange at Southport Road. SR 37option
The Comprehensive Plan for Perry Township, recommends a mixture of light industrial, commercial and medium to low density residential along the SR 37 corridor. Most of these are land uses that are generally more compatible with a major transportation facility. This corridor has also developed in the presence of an existing expressway and has developed in some cases, more densely than recommended by the Comprehensive Plan with additional multi-family developments, as well as significant commercial developments. Nevertheless, this alternative would require the relocation of 139 to 208 residences and businesses. Several historic structures and churches could also be impacted. It is important as well, to note that existing SR 37 passes through a protected wellfield area. Any alternative that utilizes SR 37 would increase the likelihood of further impacts to this wellfield area. Noise impacts could be significant given the number and density of residential units existing and planned along SR 37. RECOMMENDATIONS The MPO recommends that if a build alternative is deemed necessary, that Alternative 4B that utilizes I-70 from I-465 west to western Morgan County and then south, be selected. Should any of the other build alternatives be selected, the MPO would recommend that the Mann Road corridor option be eliminated from consideration. The MPO recommends that if a build alternative is deemed necessary, that it not compete with I-465 and other important state facilities in the MPA for limited funding. The MPO recommends that if a build alternative is deemed necessary, additional detailed analysis in close cooperation with the MPO to insure that the MPA's transportation network and air quality status are not jeopardized and that all quality of life impacts are appropriately addressed. The MPOís recommendation is based on the following considerations: The no-build alternative and alternative 4B have the least impact on the regionís transportation network, particularly I-465. All of the remaining preferred alternatives have potentially significant impacts to the regional transportation network. The impacts range from potential impacts to interchanges important to efficient access to the new mid-field terminal, significant local access impacts along SR 37, to the need for additional travel lanes on I-465 over and above what is currently shown in the Indianapolis Regional Transportation Plan. All alternatives other than the no-build increase VMT in the MPA and thus increase emissions over those of the no-build alternative. Based on the information contained in the DEIS, non of the alternatives exceed the State Implementation Plan emission budgets. Alternative 4B does not require the relocation of any homes or businesses within the MPA. Of the other build alternatives, Alternative 4C requires the lowest possible number of relocations in the Indianapolis MPA, with 114 to 181 where as the remaining three alternatives (2C, 3B, 3C) require 139 to 230 relocations. All of the build alternatives would result in varying degrees of travel time savings between Indianapolis and Evansville. Alternative 4B results in a travel time savings of 27 minutes. Alternative 2C realizes the least travel time savings at 19 minutes, where as Alternative 3B would realize the most at 29 minutes. Alternative 4B does not impact park land, historic properties or wellfield areas over and above those improvements already planned along this route. All of the other build alternatives impact park land, historic properties and wellfield areas. |