HomeMy WebLinkAbout13.A.2. Comment of Metropolitan Council Update of Transportation Policy Plan (TPP)i3. A•J~
CITY OF SHAKOPEE
Memorandum
TO: Honorable Mayor and City Council
Mark McNeill, City Administrator
FROM: R. Michael Leek, Community Development Director
RE: Comment on Metropolitan Council Update of Transportation Policy Plan (TPP)
MEETING DATE: October 5, 2010
INTRODUCTION:
~n September, the Metropolitan Council issued a proposed update to the regional TPP. Public comment
will be taken on the TPP until 5 p.m. on October 7, 2010. Because the TPP is the document which, in
many ways, determines what transportation and transit projects can compete for funding, staff believes
that it is important that the City of Shakopee comment on the draft and request that it be modified
significantly before it is adopted. The TPP in its current form ignores the need for roadway and transit
capacity investments that would serve not only the City of Shakopee, but residents and businesses on
either side of the Minnesota River. This need for these capacity investments is highlighted by the
regional impacts of both the current flooding and Spring flooding of the Minnesota, which has closed a
significant portion of the north-south transportation network from U.S. 169 to Scott CR 25 in Belle
Plaine.
ALTERNATIVES:
Offer and pass a motion directing staff to submit the attached comment letter as presented to the
Metropolitan Council by the October 7th deadline.
Offer and pass a motion directing staff to submit the attached comment letter with revisions to the
Metropolitan Council by the October 7th deadline.
RELATIONSHIP TO CITY GOALS:
This item relates to Goal B. Positively manage the challenges and opportunities presented by growth,
development and change, and D. Maintain, improve and create strong partnerships with other public
and private sector entities, to the extent that modification of the TPP in the manner requested will assist
the Metropolitan Council and cities and counties on both sides of the Minnesota River in the Region in
acting as partners in future transportation investments.
ACTION REQUESTED:
Offer and pass a motion directing staff to submit the attached comment letter, either as presented or as
revised, to the Metropolitan Council by the October 7th deadline.
_ ~~ y.~
R. Michael Leek
Community Development Director
TPP rpt_10052010
October 5, 2010
Peter Bell, Chair
Metropolitan Council of the Twin Cities
390 Robert St. N.
St. Paul, MN 55101
Dear Chair Bell:
on behalf of the Shakopee City Council, I express our appreciation for the opportunity to provide
comments on the proposed 2010 update of the Transportation Policy Plan (TPP). We offer these
comments because the TPP has significant impacts for transportation investment within the Region, and
believe that the TPP must take account of needed investments in the entire Region.
Like the Metropolitan CounciljMetro Transit, the City of Shakopee shares in the role of transportation
provider within the Region. Our City has played a significant role in the development of a portion of the
regional highway system (U.S. Hwy. 169 and the Bloomington Ferry Bridge), a provider of express bus
and local circulator transit service, and provider of local roads. We see the impacts of our (state, region,
local) decisions on the traveling public. We understand how interdependent we and the region are in
our actions. For all these reasons, our City is actively involved in transportation committees and
coalitions throughout the region and beyond. We support the importance of multi-modal system and
believe that transportation alternatives have to be provided to our entire citizenry.
Having said that, we are highly concerned about several policies in this draft plan, which we believe do
not serve the purposes outlined above.
A Vision for the Future of Transportation in the Region?
We understand that The TPP update has largely been developed with the principles enunciated in the
Council-Mn/DOT developed Metropolitan Highway System Investment Study (MHSIS) in mind, and as a
result asserts that it is a fiscally constrained plan.
The City of Shakopee has significant concerns that a TPP that fails to provide a complete vision for
transportation in the future is inadequate, and inconsistent with the Metropolitan Council's own
approach to regional land use. Under the Land Planning Act, the Metropolitan Council requires cities
and counties in the Region to provide an extensive long range comprehensive plan that will
accommodate the population, household and job growth that the Metropolitan Council projects for
them. In order to be able to accommodate the projected growth, there must be sufficient infrastructure
available, including transportation and transit investments. Under the proposed TPP update those
investments would not be made either in highway improvements or transit investment. We believe that
this will force communities in the Region on either side of the Minnesota to have to re-think whether
the population, household, employment and affordable housing projections contained in the recently
completed 2030 comprehensive plans are reasonable.
CC/0921_2010/TPP_10052014
are funded first, leaving whatever is left for highway expansion. For transit, a much different approach
is taken. The Motor Vehicle Sales Tax (MVST) is the principal source for transit operating funds, and has
declined by roughly a third from 2003 until today. Yet even though the major funding source for transit
operations has declined, the plan assumes that operating funding will be found to fund several new
transitways, an expanded base bus system and an express bus network. These two approaches, again,
yield very different results. The transit plan is shown to expand substantially while the highway system
expands very little. It would seem that in a truly fiscally constrained plan, transit operating funding for
new service would have to come from reprioritizing existing funding, something that occurred with the
beginning of Northstar service. In addition, at least with respect to bus based transit, significant
investments may be needed in, highways to accommodate the additional service called for in the transit
portion of the plan.
The question of apparently unconstrained funding for transit (especially new LRT and commuter rail) is
in conflict with policy 15h which requires operating funding being identified before transitway
investment is made.
Another issue is the question of financial balance to this plan that results from the two different
approaches to estimating future funding. The Highway plan assumes about $520 million for new
congestion mitigation projects from 2015 to 2030. The Transit section of the plan assumes somewhere
between $4,6 billion and $5.5 billion of funding for transit expansion. This is a policy choice that
Mn/DOT and the Metropolitan Council are making to favor a mode that carries 5% of the trips in the
region over a mode that carries over 90% of the trips that occurs as a result of how they choose to
estimate future revenues. One alternative would be to estimate future revenues for both systems the
same way. Another policy choice would be to reprioritize funds (CMAQ state bonds, etc) from transit to
highways to provide more opportunities to expand highway funding.
Major Projects vs. Small Projects
One of the results of the so-called low cost/high benefit approach in handling the question of fiscal
constraint is that major projects are forgone in favor of smaller projects with smaller benefits. Locations
that cause major problems for thousands of travelers every day are not resolved in favor of tweaks to
the system.
1n contrast to the approach taken relative to highways, the Transit section of the TPP assumes that a
number of very large projects will be constructed (principally light rail transit) as well as lower cost
projects (bus rapid transit, base bus system expansion}. It does so because it assumes that additional
resources will be secured beyond those that are currently available or can reasonably be anticipated to
be available.
By doing so, the TPP assumes the major highway infrastructure projects that have helped reduce
congestion and improve safety according to Mn/DOT's own data are not worthy of investment.
Projects such as the Wakota Bridge, "Un-Weave the Weave;' TH 212, I-494 (west), TH 169/CH 81 and
the Crosstown have provided tremendous relief to the commuters that use them everyday. Yet, this
new funding approach would ensure that projects like these would not occur.
The TPP Update Lacks Regional Balance
CC/0921 2010/TPP 10052010 3
There are issues of regional balance both in the Highway and in the Transit sections. When one looks at
the map of Low Cost/High Benefit Projects, there is only one project south of I-394/1-94 between now
and 2030. (See Fig 6-33 below) Of the 29 projects, five total were for areas south of the I-394/1-94 line.
The flooding of the Minnesota that has occurred twice 2010 has demonstrated that there are major
impacts to the regional system (not to mention the regional economy), and that as a result system and
capacity improvements are needed. As a result, in 2A better regional balance needs to be found before
the TPP is adopted.
Regional Balance -Transit
The Center of the Twin Cities region is downtown Minneapolis. This is despite the fact that our ring-
road (often referred to as the beltway), I-494/694, goes around both downtown Minneapolis and
downtown St Paul. On the following map, one can see that the southern equivalent of I-35E is TH169.
Each is roughly equidistant from downtown Minneapolis. Yet, even though this is true, the two roads
are not treated equally with respect to transit planning in the TPP. The map below shows express bus
service with transit advantages. From this map, one can see that I-35E has this service all along its
length while TH169 does not, even though it more directly serves downtown Minneapolis. TH169
should be identified as needing express bus service with transit advantages along its full length.
This issue is even more pronounced when one looks at the role that is conceived of for TH169 on the
Transitways map. I-35E north of downtown St Paul is identified as a transitway while TH169 is not, even
though TH169 serves an employment center (downtown Minneapolis) that is twice the size of the
employment center served by I-35E (downtown St Paul).
CC/0921_2010/TPP_10052010 4
It is clear that TH169 should be designated as a roadway that should be developed as a transitway,
similar to I-35E. This will provide persons on the western side of the region the travel benefits expected
to be provided to persons on the east side of the region.
CC/0921 2010/TPP 10052010 5
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Abandonment of River Crossings
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The Twin Cities Region is bounded or impacted by a number of significant rivers and one large lake,
which create barriers to development, transportation and commerce in the Region. When this happens,
development is "pushed" to other parts of the Region, or even outside the Region. The Region is
developing to the north (and to the north of the Region), in part because of the lack of river crossings to
the south. The result is that development is pushing out further and further, increasing VMT, increasing
travel and ultimately, increasing the cost of providing highway and transit capacity. It is more cost-
effective to provide adequate bridge capacity to the south than it is to expand further and further to the
north. Yet this appears to be the first regional plan that abandons the addition of new river crossings or
additional capacity on existing crossings except for a token amount of money for right-of-way
preservation. As has been amply demonstrated in the spring and fall of 2010, with the Region heavily
dependent on these crossings, and with the Region projecting significant population, household and
employment growth in the southwestern part of the region, there should be a stronger discussion in the
TPP on the need for new Minnesota River crossings and crossing capacity, and planning that reflects
contemplated future investment in those crossings and capacity.
CC/0921 2010/TPP_10052010 6
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There is a comment in the plan that there should be a reassessment of the new Minnesota River
Crossing. It is not clear what this means as the Region just spent seven years evaluating and preparing
an EIS for right-of-way preservation. This work has shown that this is amuch-needed river crossing.
Similarly, if there is to be no expansion of river crossing capacity with a new bridge, there needs to be in
the TPP a discussion of whether TH169, I-35W, TH101/CH 101 and TH 41 can meet growing needs. If
this doesn't happen, then there needs to be a discussion of the impacts on travel if development doesn't
occur south of the river but much further out in other parts of the region.
Improvements Inside 494f 694 and Outside 494j694
The approach to funding (constrained for highways, unconstrained for transit in some areas) and the
focus on low cost/high benefit small highway projects means that most of the spending in this plan
occurs within the so-called Beltway (commonly used to describe the I-495/1-694 ring) and not beyond it.
virtually all the transit money is for projects within the" beltway" as is much of the highway money. Yet
much of the future population growth is projected outside the beltway, using roadways and bridges that
have no contemplated capacity expansion in the TPP.
It seems a more reasonable approach to use the urbanized area as a definition of where improvements
are made instead of the road system, the need to focus beyond the beltway is even more pronounced.
It is a clear policy choice to improve transportation in locations that have congestion today rather than
ensuring that developing areas do not have these same problems. An alternative would be to focus
more on expanding the capacity of the highway system in developing areas rather than focus the vast
majority of funding in the "beltway." For example, rather than focusing all the transit funding on light
rail and base bus system expansion in the core, funding could be shifted to more commuter bus and
commuter rail service in the developing portions of the Region. Another alternative that should. be
considered in the TPP is extending the managed lanes further. For example, the managed lane on I-35W
should be extended to Northfield and to include the U.S. 169 corridor through the City of Shakopee.
In addition, the identified needs for interchanges in developing areas versus the developed parts of the
Region should be revised. The TPP states that outside of the beltway, interchanges should not be of a
frequency then less then 2 miles. Inside the beltway, they can be less than that due to existing
development and the grid system. Yet, most communities have already studied interchange issues and
existing plans address the individual needs of different locations. To make a blanket system standard of
2-mile spacing regarding interchanges that is not based on need, on location, connectivity, functional
class and good transportation planning is not useful for the Region or the cities and counties within the
Region.
The TPP contains a statement that indicates interchanges should be funded by any benefiting property
owners. Yet it is clear that the transportation system is a "system" and all persons within the Region
benefit from improvements to the system. It is inappropriate to burden property owners who are
primarily in the developing portions of the region with these costs when individuals beyond these
narrowly defined locations also benefit. It also seems inappropriate to "tax" developing areas while
much of the rest of the Region was able to develop using general tax revenues. Further, it is
inappropriate to treat the two modes, highways and transit, so differently. If it is appropriate to charge
benefitting property owners for interchanges, shouldn't benefitting property owners also pay for transit
projects such as light rail, commuter rail lines and bus rapid transit?
CC/0921 2010/TPP 10052010 7
The TPP acknowledges that transit can be a powerful force for reshaping land use. Yet it focuses almost
all of its transit funding into areas that are already developed. This clearly implies significant re-
development, which is very costly. This approach is not well-balanced. The Metropolitan Council has
for years sought to have cities in the Region develop at densities that could support transit. To
accomplish this objective, it would make more sense to refocus some of this effort into providing real
transit alternatives into developing areas and providing incentives for more compact, long-term
sustainable land use. The TPP should show more expansion of commuter rail, managed lanes and
express service from and into developing areas. It should also look at land use changes that could
increase ridership to make these alternatives more successful. If these land use changes can be
identified, they can be built into local land use plans to ensure the success of these projects.
This integration of land use and transit is critical because much of the housing that needs to be
developed in the next 20 years will be to house elderly baby boomers. Spreading this housing over a
wide geographic area will make it difficult to provide these individuals with needed services. Instead, it
makes more sense to increase transit investment into developing areas and provide an incentive to
create clustered, higher density development where they can receive needed services at a lower cost.
Highway Projects Do Provide Congestion Relief in the Region
Throughout the TPP, statements are made that highway improvements do not relieve congestion. Yet
Mn/DOT's own congestion analysis shows that highway projects do relieve congestion. For example,
the improvements made on I-94 N to remove the lane drop have clearly improved traffic flow and
reduced congestion. Clearly and logically, congestion can be improved with highway projects.
Moreover, improvements to highways are often needed to accommodate transit modes.
We are not contending that highway projects will do away with congestion. Indeed, it is reasonable to
expect that over time increases in travel and population will result in congestion issues somewhere in
the Region. It needs to be kept in mind that highway (and for that matter transit) projects are not built
to provide capacity infinitely into the future. It still makes sense to do highway improvements that
create benefits for many years.
Local Comprehensive Plans Guiding Regional Plan
In the Twin Cities Region, regional planning is always an on-going discussion between cities and counties
and the Metropolitan Council. Local comprehensive plans are to be in conformance with the regional
growth management plans and, especially when the local plans have been reviewed and accepted for
implementation by the Metropolitan Council, the regional plans should take account of, and not be
inconsistent with those local plans reviewed and accepted by the Metropolitan Council.
It was our City's understanding that the local comprehensive plans were to be completed in
conformance with the Region's current plan, and that the next regional TPP update would reflect
changes within the accepted local comprehensive plans. Our city partnered with Scott County and
Mn/DOT on a functional class study for the CH 17/TH 13 corridor. This study was done in conjunction
with Mn/DOT (funding and technical work) and Met Council staff participation. Scott County's 2030
plan identifies the "future [north-south principal arterial "in Scott County as CH 17/TH 13 beginning at
U.S. 169 in Shakopee, yet the TPP makes no acknowledgment of that designation that was accepted by
the Metropolitan Council in the County's 2030 plan update. The functional class map should be updated
to show CSAH 21 as the current principal arterial not CSAH 18 as it will be completed next year. The
CC/0921 2010/TPP 10052010 8
future principal arterial functional class map should show CSAH 17jTH 13 from TH 169 to TH 19 and CH
42 from CSAH 18 to CSAH 17. These two corridors are consistent with the Region's planning guidelines.
Use of RALF Funds
The policy plan states that "the Right-of-Way Acquisition Loan Fund will be used to preserve right-of-
way for the highway projects consistent with this update of the TPP. Yet this plan includes very little
need for right-of-way acquisition given that only low cost projects are included for highways. It would
make more sense to expand the definition of the usage of this fund to include acquisition for right-of-
waythat can be used to improve highway capacity, i.e. including transit projects that directly affect
highways. This would let developing areas set aside sites for future transit needs before the costs
escalate, similar to highways.
Role of the Suburban Transit Providers in the Region
Recently, the Star Tribune has reported increasing tension between the Metropolitan Council and
suburban transit providers, including the City of Shakopee. Much of this stems from insistence by
Metropolitan Council staff and officials that suburban services are too high in cost. Rather than being a
costly burden, the suburban transit providers have shown themselves to be innovators in the Region
{coach buses, strategically-placed park and rides, use of small buses, quality trip to attract non-
traditional riders, etc). The suburban transit providers have been very successful at competitive
processes and securing federal funding. The result is that they have grown their ridership substantially
faster than Metro Transit. In Scott County, when the Metropolitan Council in 2001 informed the cities
and county that it would not be undertaking transit planning for Scott County our city and others, along
with the County undertook a study that led in 2005 to the Scott County Unified Transit Management
Plan (UTMP); established a Transit Review Board and Transit Review Team that have met monthly since
it was formed; established expanded commuter service (BlueXpress) in 1997 that has grown ridership
dramatically; transitioned dial-a-ride within the entire county to Scott County; and identified and
constructed two {one under construction} very cost effective park and ride facilities, neither of which
has enclosed buildings on site.
Yet the Metropolitan Council has taken steps and is taking steps in the TPP which reduce the
independence of these innovators. For example, Strategy 14e would put the Metropolitan Council in
charge of decisions about fleet and faculty investment, rather than each organization. Likewise, 14c
states that the Council will prepare the regional investment strategy rather than letting each
organization determine its own priorities.
These policy statements should be removed and instead replaced with a statement that the region
supports the suburban transit model and the competition and innovation that results. This approach,
having more than one organization innovating and competing, will provide better results than one large
bureaucracy serving the whole region and the policy plan should support this approach.
Conclusion
The Shakopee City Council would suggest an immediate stop to the process of adopting the current draft
TPP Update until the appropriate leve{ of debate at the Transportation Advisory Board (TAB) and input
from local agencies can be evaluated, their comments and questions answered, and the TPP modified to
CC/0921 2010/TPP 10052010 9
adequately address the legitimate comments communicated in this letter. The modifications that
should be made to the TPP Update include;
• Revising the entire document so that it provides a real vision for balanced highway and transit
development throughout the Region for the long-term;
• Revising the entire document so that it consistently describes. potential fiscal constraints for
both highways and transit, but which does not base the TPP on these constraints for either.
Instead the reality of fiscal constraint should be used by the Metropolitan Council and local
governments on aday-to-day and year-to year basis for making specific funding investments;
• The TPP should be revised to reflect the long-range planning that was accepted in local 2030
comprehensive plans. For Shakopee specifically, and Scott County generally, this includes
reinstating plans for new river crossings and increased capacity for existing river crossings
serving cities and counties on both sides of the Minnesota River within the Region.
• Revising the TPP to eliminate the 2-mile spacing standard for interchanges on the regional
system outside the so-called beltway. Instead the TPP should acknowledge the need to evaluate
interchanges based on location, need, connectivity and other factors.
• Revising the TPP to eliminate the requirement that interchanges that will be located largely in
developing areas be paid for by adjoining properties. This requirement ignores that they are
part of a regional system and benefit the region, and thus the cost should be borne as it
historically has been. In the alternative, if the Metropolitan Council insists on this policy, then
the same approach should be taken to assessing property owners for the costs of major new
transit projects.
• The TPP should be revised so that it leaves behind the antiquated notion of only making
investments within the so-tailed beltway. Much of the existing urbanized area of the Region is
already outside the beltway, and deserves transportation and transit investments as well.
Perhaps more importantly, if the Metropolitan Council is serious about the notion that growth
will continue to occur in developing areas like Shakopee and Scott County, then the TPP must be
refocused so that investments can be made to accommodate the projected growth. Failure to
do so will inevitably lead to a reassessment of those growth projections on the local level.
• The TPP should expand the definition of the usage of RALF funds to include acquisition of right-
of-way that can be used to improve highway capacity, i.e. including transit projects that directly
affect highways. This would let developing areas set aside sites for future transit needs before
the costs escalate, similar to highways.
• The TPP should be revised to acknowledge the important roles that the suburban providers have
played as innovators, and should further be revised to return more discretion to them to make
service and management decisions related to the services they do or may in the future operate.
Sincerely,
John J. Schmitt, Mayor
City of Shakopee
Cc: Craig Peterson, Metropolitan Council Barbara Marschall, Scott County Bd. of Commissioners.
Senator Claire Robling, Representative Mike Beard
Scott McBride, Metro District Engineer Lynn Clarkowski, Metro Area Engineer
CC/0921 2010/TPP 10052010 10