12 September 2003
Skagit County Planning Commission
Skagit County Planning and Permit Center
200 West Washington Street
Mount Vernon, WA 98273
Re: Comments on the Draft Skagit County Transportation Systems Plan including the Non-motorized Transportation Plan
Dear Commission Members,
Part of the work that Friends of Skagit County does is promoting issues that improve the livability of our communities. Our members come from all across the county and beyond and we are concerned about quality of life in all parts of the county, including issues and policies that make our roads and trails safer and more accessible for bikers, hikers, joggers and walkers.
We have had a long-standing concern about the lack of adequate non-motorized transportation (NMT) planning in Skagit County. In 1997 the Western Washington Growth Management Hearings Board agreed with us that Skagit County needs to complete a NMT Plan, and the County has been under orders to develop a NMT plan since then. The County and their consultants published a very good plan in 2001/02. We dropped the ball by not speaking out in support of it at the 2002 hearing. We felt it was a plan we would support and that it did not need defending. That was our misconception because you ordered the Planning staff to substantially rework that plan. Chapter 10 of this draft Transportation Systems Plan is the County’s current attempt to comply with the Hearings Board order to develop a NMT plan and we believe that the bulk of the most useful material from the 2002 Plan has been removed.
At present pedestrians and bicyclists are forced into harms way on many of our city and county roads. That is unacceptable and must change. We wholeheartedly disagree with the assumption that “Skagit County does not need more then (sic) two or three county roads to serve as non-motorized transportation routes” (Planning Commission Recorded Motion, August 14, 2002). We believe the County NMT Plan should operate under the assumption that the ENTIRE road network is of value to non-motorized users.
We also feel that the County trail system should be expanded and improved to encourage all county residents to get more healthy physical exercise. The existing trails are very popular, and we believe that there will be increased demand for more trails as our population continues to grow. Survey data collected in Skagit County indicate that more than 70% of Skagit County adults ride a bike at least occasionally (see p. 26 of the 2002 NMT Plan) and that there is a high demand for pedestrian facilities, both recreational and for transportation (see p. 60 – 62 of the 2002 NMT Plan).
The 2002 plan proposed many specific actions and identified priorities that would move us along in the process toward improving conditions for non-motorized users county-wide. This current draft has no specifics or recommendations. Where are the protections for non-motorized users of our public roads and streets in this current plan? This document provides interesting background information, but it is not a plan. And it is certainly not a NMT Plan that we will be able to support.
The draft 2002 Plan identified concerns that pedestrians and cyclists raised during the public involvement process that went into preparation of that document (see p. 33 of the 2002 Draft NMT Plan). Issues of HIGH concern to both pedestrians and cyclists included: Lack of Facilities; Roads Unfriendly; Accidents/Hazards/Safety; Barriers/Physical Constraints; and Lack of Funding. A good NMT Plan should address these issues and pose some solutions. This document does neither.
One of the changes proposed in this current draft is to switch methods (i.e. computer simulation models) for computing the “Level of Service” (LOS) standards for roads. The County wants to switch from the “Birdsall” method to the “HCM” method. The main reason given is because the cities use the HCM method, and the County wishes to have consistency between their calculations and the cities’. We do not dispute the merits of having multiple jurisdictions use the same modeling tools. However, the HCM model does not have any algorithm for computing LOS for bicycles (whereas the Birdsall method took bicyclists’ perceptions of safety into consideration). If the County is going to switch computer models, then an alternative way of computing LOS for bicyclists needs to be adopted. The 2002 NMT Plan identified the “Bicycle Compatibility Index” (BCI) as a good tool for computing LOS for bicyclists. It also recommended that the BCI be used in Skagit County and that bicycle LOS standards be adopted in future road projects. We are dismayed to observe that bicycle LOS standards are not mentioned in this current plan. They should be and we request that bicycle LOS standards be put back into the plan and adopted for county-wide application.
We respectfully disagree with the Commission’s finding that “The Draft NMTP identifies priority non-motorized routes and since desired routes and population changes may occur in the future, the routes should be eliminated and only policy direction should be implemented as to how to choose a route at a later date” (Skagit County Planning Commission August 14, 2002 Recorded Motion). We believe that this plan should not only identify a long-term vision but also set some near-term priorities. This plan, like other major plans, will need to be revised in the future as individual projects are completed and new priorities are identified. We believe that, at a minimum, the County’s NMT plan should 1) review supporting policies (which this draft does); 2) identify short-term and long-term goals (which this draft does in part); 3) identify projects that can be undertaken to help meet the goals (which this draft does not do but the 2002 draft did in great detail); 4) identify policies that do and do not support the goals of the plan (which this draft does in part); 5) identify funding sources that could be accessed to execute the projects (which this draft does not do but the 2002 draft did in great detail). In short, this current plan absolves the County of having to implement any on-the-ground projects to improve bicycle and pedestrian safety and/or promote non-motorized transport, including simple things like sweeping existing road shoulders.
We are mystified by concerns that the County’s own Public Works Department raised regarding un-funded mandates during the review of the 2002 plan (see Finding #6 in the August 14, 2002 recorded motion). Obviously NMT projects will cost money. However, the draft 2002 NMT Plan identified 45 potential funding sources that Skagit County could attempt to access to support NMT projects. That information appears nowhere in the current NMT chapter, and we feel that it should be included in the final NMT Plan.
Mandates in the Growth Management Act include adoption of 6-year transportation plans that should specifically reference how Skagit County will expend money, including funds for non-motorized transportation (RCW 36.81.121 and Chapter 47.30 RCW). We do not believe that this current transportation plan addresses this issue adequately.
In summary, we do not believe that Chapter 10 of this Draft TSP contains the basic elements of a “plan”. We believe it is an inadequate substitute for a true Non-motorized Transportation Plan, and we assume that the Hearings Board will agree with us. The TSP needs to cover NMT issues, and a revised version of the text presented to you may suffice to fill that need. However, a separate SUBSTANTIVE NMT Plan needs to be adopted. We recommend the Planning Commission to revisit the 2002 NMT Plan and reconsider adopting that document.
Please keep us informed of additional opportunities to participate in the public process regarding Non-motorized Transportation Planning in Skagit County.
Sincerely,
June Kite, President