Thanks for the opportunity to comment on the draft 2015 – 2018 Transportation Improvement Program (TIP).  Through this process approximately $25 million per year of Federal transportation dollars will be allocated to road, non-motorized, and congestion/air quality improvement projects in Anchorage and Eagle River.   As an organization whose mission is to make Anchorage more bicycle friendly, we find a lot to like in the proposed allocation:

April 25, 2014

Mr. Craig Lyon, AMATS Coordinator

Municipality of Anchorage

Community Development Department

4700 Elmore Road

Anchorage, Alaska  99507

[email protected]

Dear Mr. Lyon,

Thanks for the opportunity to comment on the draft 2015 – 2018 Transportation Improvement Program (TIP).  Through this process approximately $25 million per year of Federal transportation dollars will be allocated to road, non-motorized, and congestion/air quality improvement projects in Anchorage and Eagle River.   As an organization whose mission is to make Anchorage more bicycle friendly, we find a lot to like in the proposed allocation:

• Overall proposed funding levels for  “Non-Motorized” projects (formerly called Transportation Alternatives) for 2015-18 are $3.3M, $3.7M, $2.4M, $2.4M, or 14%, 16%, 10%, 10% of total allocation.  This is consistent with the AMATS policy of allocating 10 to 15 percent of the total allocation on a 4-year average to these types of projects.
• The 2010 Anchorage Bicycle Plan rightly identified the striping and signing of bike lanes and paved shoulder bikeways on our “core bicycle network” to be the top implementation priority.  This draft TIP proposes to allocate $2.35 million ($650K + $1M + $500K + $200K for years 2015-18 respectively) for such work.
• This draft TIP includes $1.5 million in 2016 for much needed “areawide trail rehabilitation.”  All users will benefit from repaving and other improvements to our existing multi-use paths.
• Funding is proposed to design and construct two new multi-use path segments: (1) a path along Benson Blvd. between Lois Dr. and Minnesota Blvd ($1.2 million in 2016-17), and (2) a path along O’Malley Rd. between Old Seward Highway and C St. ($1.2 million in 2017-18).  These will eliminate missing links in our existing or soon-to-be-constructed biking and walking network.
• The Bike Plan identifies the need to properly mark and sign our extensive existing bicycle network.  The draft TIP proposes $1.2 million for this work in 2017-18.
• Lastly, four proposed-to-be-funded road projects include significant bike infrastructure: (1) the O’Malley upgrade from Seward Hwy to Hillside Drive should include full-fledged bike lanes and a new multi-use path on at least one side, (2) the Abbot Road upgrade from Lake Otis to Birch will include widened “paved shoulder bikeways” and the existing adjacent multi-use path will be resurfaced and sweeps installed at side-street intersections, (3) Spenard road work from Minnesota Dr. to Hillcrest Dr. should include some yet-to-be-defined bike and pedestrian improvements, and (4) we understand that the “Birch Road rehab” project will include rehabilitation of the adjacent multi-use path between Abbott Rd. and Huffman Rd.

Considering all of the above, we congratulate the municipal and state employees who developed the draft TIP for a great start.  We have only one criticism, and we feel it is significant.   The AMATS TIP was previously updated via a similar public process two years ago.  Unlike now, the initially proposed funding levels for bicycle infrastructure was very poor.  But dozens of people showed up at meetings, and hundreds wrote comments, asking for a better allocation.   The residents of Anchorage want a more bicycle friendly city.  As a result, the funding allocated for Bike Plan Implementation in the 2013-2014 TIP went from a proposed $1M to a final $2.3 million.   During the past two years, we’ve waited to see the results of that funding.  We still wait.  While we know that the federal process for spending transportation dollars can be complex and time consuming, it can be done.  Months, and now years, have gone by.  Deadlines have come and gone.  Most recently staff decided that the entire hard-earned $2.3 million in Bike Plan Implementation funds, as well as an additional $1 million in Pedestrian Plan Implementation funds, would be dedicated entirely to “project design” and none would be spent for on-the-ground project work.  My reaction, and that of many others, is simply dismay.  The NEPA regulations clarify that construction of bicycle and pedestrian lanes, paths and facilities, as well as installation of signs and pavement markings, are categorically excluded from NEPA review. See 23 C.F.R. § 771.117(c)(3) and (c)(8).  The projects needing “design” are almost exclusively the striping, marking, and signing of bike lanes and shoulder pathways on existing asphalt on existing streets, all of which are categorically excluded from NEPA review.  No “turning of dirt” is planned or needed. The Anchorage Bicycle Plan has already identified the “where” and “what.”  The accepted ASHTO and NACTO bicycle infrastructure manuals clearly define the “how.”  All that’s now left is “when.”   Using the funds allocated via the TIP nearly two years ago, we will soon have $2.3 million worth of detailed bike lane and shoulder bikeway designs, all focused on how to stripe, mark, and sign existing asphalt on existing roadways.  This massive expenditure only makes sense if followed by timely and substantial implementation.  We thus believe that the $2.35 million proposed for 2015 – 2018 to implement the $2.3 million in planning and design funded in 2013 – 2014 is inadequate.  Plans get stale.  Priorities sometimes change.  We need to fully leverage the previously allocated design dollars by better funding levels for follow through – actual paint on the streets and signs on the shoulders.   As such we request the following change to the draft TIP:

• Increase the “non-motorized” allocation to at least a full 15 percent of the total allocation for each of the four years of this planning cycle.  Funding non-motorized projects at $3.75 million per year would increase the 4-year non-motorized allocation by $3.2 million above the current draft.  Dedicate this additional funding to put on-the-ground the results of all the extensive core bicycle network design work already funded and soon-to-be completed.

If, and only if, the above change is not attainable, then we propose the following changes to existing non-motorized projects.    We relish none of these, but believe that if the above requested increase in the overall non-motorized allocation cannot be accommodated, then reducing or delaying several non-motorized projects would be prudent.  This would allow additional on-the-ground implementation of the extensive bike lane design effort already funded:

• Reduce trail rehabilitation funding from $1.5 million to $1 million (2016).  It is indeed important to take care of what we have.  However, it is at least equally important to implement the top priorities in the Bike Plan and fully utilize the detailed designs already completed.
• Delay the planning, design, and construction of the Benson Blvd. multi-use path ($1.2 million in 2016 – 2017) until in 2019 – 2020.

Thanks for all the hard work done, and yet to be done, on revising the draft 2015 – 2018 Transportation Improvement Program.  Based on the thoughtful analysis we share here, we hope to see an increased emphasis on Bike Plan implementation in the final document.   Sincerely, /s Brian Litmans Brian Litmans President Bicycle Commuters of Anchorage