BELLEVIEW AVENUE CORRIDOR STUDY

EXISTING TRANSPORTATION CONDITIONS

Prepared for:

Arapahoe County Public Works Department Lima Plaza 6924 S. Lima St. Centennial, CO 80112

Prepared by:

Felsburg Holt & Ullevig 6300 South Syracuse Way, Suite 600 Centennial, CO 80111 303/721-1440

Project Manager: Christopher J. Fasching, PE

FHU Reference No. 12-069-01 September 2015

Existing Transportation Conditions Draft Report

TABLE OF CONTENTS Page List of Abbreviations and Acronyms ------iii 1.0 Introduction ------1 2.0 Roadway Network ------3 2.1 Vehicular Traffic Operations ------3 Demands ------3 Operations ------6 Accidents ------9 3.0 Alternative Transportation Modes ------12 3.1 Transit ------12 3.2 Pedestrian and Bicycle Facilities ------15 3.3 Transportation Demand Management ------15 3.4 Intelligent Transportation Systems ------18 4.0 Surrounding Land Use ------19 5.0 Environmental Considerations ------23 5.1 Biological Resources ------25 Wetlands ------25 Noxious Weeds ------26 Wildlife Habitat ------26 Special Status Species ------27 5.2 Water Resources ------29 5.3 Air Quality ------29 Carbon Monoxide ------30 Particulate Matter ------30 Ozone ------30 Mobile Source Air Toxic Pollutants ------31 Mitigation and Best Management Practices ------31 5.4 Environmental Contamination Issues ------32 5.5 Noise ------33 5.6 Cultural Resources ------36 5.7 Parks and Recreational Trails ------39 6.0 References ------42

LIST OF APPENDICES Appendix A Traffic Count Data Appendix B Level of Service Calculations Appendix C Crash Data

Page i Existing Transportation Conditions Draft Report

LIST OF FIGURES Page Figure 1.1 Belleview Corridor Study Area ------2 Figure 2.1 Existing Roadway Conditions------4 Figure 2.2 Existing Belleview Avenue Study Area Traffic Demands ------5 Figure 2.3 I-25/Belleview Interchange Traffic Patterns ------7 Figure 2.4 Existing Intersection Geometry and Levels of Service ------8 Figure 2.5 Signalized Intersection Crash Summary (2009-2011) ------10 Figure 3.1 RTD Transit Serving the Belleview Corridor ------13 Figure 3.2 RTD Transit Stop Daily Activity ------14 Figure 3.3 Existing Sidewalks and Connecting Trails ------16 Figure 3.4 Existing and Planned Bike and Multi-use Facilities ------17 Figure 4.1 Existing Land Use ------21 Figure 4.2 Existing Transportation Analysis Zones (TAZs) ------22 Figure 5.1 Environmental Resources Evaluation ------24 Figure 5.2 Noise Issues ------35

LIST OF TABLES Page Table 4.1 DRCOG Land Use ------19 Table 5.1 Summary of Potential Environmental Issues ------23 Table 5.2 Special Status Species ------27 Table 5.3 National Ambient Air Quality Standards ------29 Table 5.4 Hazardous Material Sites ------32 Table 5.5 CDOT Noise Abatement Criteria ------34 Table 5.6 Developed Properties within the Study Area ------38

Page ii Existing Transportation Conditions Draft Report

LIST OF ABBREVIATIONS AND ACRONYMS µg/m3 micrograms per cubic meter AST above ground storage tank BCZ Block Clearance Zone CAP Corrective Action Plan CDOT Department of Transportation CFR Code of Federal Regulations CPW Colorado Parks and Wildlife CDPHE Colorado Department of Public Health and Environment CHS Colorado Historical Society Office of Archaeology and Historic Preservation CO Carbon Monoxide CRS Colorado Revised Statutes dBA A-scale decibels DOT Act U.S. Department of Transportation Act DRCOG Regional Council of Governments DSEDP Denver South Economic Development Partnership DSTMA Denver South Transportation Management Association DTC Denver Technological Center FHU Felsburg Holt & Ullevig FHWA Federal Highway Administration IPaC Information, Planning, and Conservation System I-25 Interstate 25 ITS Initial Site Assessment IRA Intelligent Transportation System Leq equivalent sound level LPG liquefied petroleum gas LOS Level of Service LUST leaking underground storage tank LWCF Land and Water Conservation Funds MPH miles per hour MSAT Mobile Source Air Toxics NAAQS National Ambient Air Quality Standards NAC Noise Abatement Criteria

Page iii Existing Transportation Conditions Draft Report

NDIS Natural Diversity Information Source NEPA National Environmental Policy Act NRHP National Register of Historic Places NWI National Wetland Inventory

O3 ozone OPS Colorado Department of Labor and Employment Division of Oil and Public Safety PEL Planning and Environmental Linkage

PM10 particulate matter less than 10 microns

PM2.5 particulate matter less than 2.5 microns ppb parts per billion ppm parts per million RTD Regional Transportation District RTP 2035 Regional Transportation Plan (Metro Vision) SPIMD Southeast Public Improvement Metropolitan District TAZ transportation analysis zone TMA Transportation Management Agency TMDL total maximum daily load USACE U.S. Army Corps of Engineers USEPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Service USGS US Geological Survey UST underground storage tank

Page iv Existing Transportation Conditions Draft Report

1.0 INTRODUCTION Belleview Avenue is a key east-west arterial road in the southern . Besides serving as a connection between the Denver Tech Center (DTC) area and Littleton, Belleview Avenue provides critical access to Interstate 25 (I-25) for the Denver Tech Center area. Poor traffic operations have spurred the need to assess this corridor around the interchange area, particularly given the plans for additional development in the immediate area. Arapahoe County has taken the lead by sponsoring this effort, developing a partnership with the City of Greenwood Village, the City and County of Denver, the Denver South Economic Development Partnership (DSEDP) in association with the Denver South Transportation Management Association (DSTMA), Southeast Public Improvement Metropolitan District (SPIMD), and Greenwood North Metropolitan Improvement District. In addition, other entities are providing support including the Regional Transportation District (RTD), the Colorado Department of Transportation (CDOT), Cherry Hills Village, and the Denver Regional Council of Governments (DRCOG). The primary goal of the study is to determine the appropriate improvements, their lay out, and phasing in developing a solid foundation for subsequent National Environmental Policy Act (NEPA) efforts and funding pursuits in support of improving mobility along the corridor. The effort focuses along Belleview Avenue from Monaco Street to DTC Boulevard including the I-25 interchange. This is approximately one mile in length with the I-25 interchange being located at the mid-point. Figure 1.1 shows the corridor along with the municipal jurisdictions involved and the full extent of the study area, which measures one-mile east-west along Belleview Avenue and approximately one-mile north-south from Union Avenue on the north to Berry Street on the south. While not technically a Planning and Environmental Linkage (PEL) document, this report and the full corridor study contain information typically presented in a PEL report. This document can be used in a similar matter. This report summarizes the existing conditions of the corridor and the study area. Information presented includes corridor geometric, roadway network, land use, traffic operations, accident data, transit data, alternative mode accommodations, and available environmental data. The information will serve as a baseline with respect to understanding future needs along the corridor.

Page 1 Tufts Ave.

Union Ave.

CHERRY DENVER

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o COUNTY Niagara St. Niagara Ulster St. M Belleview Ave. 88

Progress Pl. DTC Pkwy. DTC Blvd. DTC Monaco St. Monaco ve. GREENWOOD VILLAGE Prentice A

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Figure 1.1

FELSBURG Belleview Corridor Study Area HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

2.0 ROADWAY NETWORK Figure 2.1 shows current roadway conditions within the study area with respect to laneage, speed limits, and intersection traffic control. Belleview Avenue provides four through lanes of through traffic at the eastern and western ends of the study area, and much of its length within the study area is six lanes wide. As it passes through the I-25 interchange, only four through lanes are provided as the curb lanes become dedicated right turn lanes at the ramp intersections. The speed limit along Belleview Avenue is posted at 40 miles per hour (MPH) west of I-25 (which is also a dedicated State Highway, SH 88) and 35 MPH on the east side (which is not a state highway). The major cross streets shown in the figure range in size from two lanes (Quebec Street north of Belleview Avenue) to six lanes (Monaco Street), with speed limits ranging from 30 to 40 MPH. Union Avenue is the only parallel route to Belleview Avenue, located approximately one-half mile to its north. This facility is four lanes in width and crosses over I-25. Improvements were recently completed to this roadway that enhances its connectivity to the Belleview Light Rail station located just south of Union; the improvements entail the accommodation of bus pull-off parking and an improved means for pedestrians to connect from Union Avenue to the light rail station that sits below. The Belleview Avenue interchange with I-25 is currently a tight diamond configuration; only 375 feet separate the two ramp intersections. The ramps connecting Belleview Avenue to/from the north split such that one set connects directly to/from I-25 and the other set connects to/from I-225. The distance to the first intersection on either side of I-25 is also short, being roughly 450 feet on the east side (to DTC Boulevard/Syracuse Street) and approximately 475 feet to the west side (Quebec Street). Ideally, signalized intersections should be spaced at least 600 to 700 feet apart, and the close spacing of these four intersections combined with relatively heavy use of each intersection are major reasons why the area operates at a poor Level of Service (LOS) typically in the LOS E and LOS F range with major movements suffering delays that exceed 55 seconds per vehicle (some movements more than 80 seconds per vehicle on average at peak times). The existing right-of-way along Belleview Avenue varies, but it ranges from its widest of approximately 220 feet near the I-25 interchange to typical of approximately 120 feet. Much of the corridor straddles the Denver/Greenwood Village city boundary. 2.1 Vehicular Traffic Operations Demands Daily and peak hour traffic counts were obtained and collected along the study area roadways and intersections. These data are shown on Figure 2.2. Belleview Avenue traffic is greatest immediately adjacent to the I-25 interchange, approaching 50,000 vehicles per day. The traffic volumes gradually reduce as one moves away from the interchange, to 21,000 vehicles per day east of DTC Boulevard, and 40,000 vehicles per day east of Monaco Street.

Page 3 LEGEND

X = Number of Travel Lanes Tufts Ave.

= Posted Speed Limits xx 4

STOP = Stop Sign 4 = Traffic Signal 4 on 6 Union4 Ave. 4 4 35 35 4

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4 STOP Belleview Ave. 4 88 4 6 6 6 40 STOP 40 4 35 35 4 4

co 30 2 30 na DTC Pkwy. o STOP Progress Pl. DTC Blvd. DTC Monaco St. Monaco ve. 25 4 Prentice A 4 40 25 4 4 4 .

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30 V r

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Figure 2.1

FELSBURG Existing Roadway Conditions HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 558(428) 51(234) 123(51) 309(404) 14(50) LEGEND 9(101) 26(5) 34(96) 79(146) 38(162) 27(15) 89(38) = AM(PM) Peak Hour Traffic Volumes 356(217) XXX(XXX) 8(3) 126(356) 153(104) Tufts Ave. 147(338) 103(255) XXXX = Daily Traffic Volumes (vehicles per day) 1 2 3 51(169) 1(35) 146(13) 366(332) 54(59) Counts Collected in May 2012 54(11) 287(541) 250(115) 18(135) 237(73) 145(201) 6(35) 263(162) 118(104) 3(55) 118(53) 105(380) 50(85) 3 257(563) 8000 397(409) Union Ave. 7000 127(97) 44(60) 63(90) 2 10,000 9(74)

1 33(81) 189(138) . 338(428) 1141(2115) 1165(1698)

t 18,850 S

. 1065(1803) 72(30) 545(530) t e

S s

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r 439(281) 5(2) 46(39) a y Ulster St.

n 0(26) 0(3) 1(12) S 272(512) 41(33) 572(731) 6700 o 1637(1128) 2061(1537) 1477(1239) Niagara St. Niagara 13,400 14,400 M

11,000 10(1) 449(409) 39,750 42,850 29,700 Belleview Ave. 4 5 10 11 42,500 6 7 8 9 24,950 21,050 48,050 713(334) 941(969) 157(581) 71(77) 47(59) 24,000 9950 0(0) 11,450 Progress Pl. Pkwy. DTC

DTC Blvd. DTC 66(75) Monaco St. Monaco 12

19,800 998(1357) ve. 406(774) 1039(1335) Prentice A 338(764) 947(1698) 44(26) 7 8 9 1687(1572) 763(756) 478(213) .

y 364(357) 5(21) 888(431) Quebec St. DTC Pkwy. 464(426) 132(529) 86(91) 16(62)

. 1611(1237) 1561(1301) W

25 e a v

i 488(207)

t A

n Crestline Cir. e e l c

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r V r

19,450

e T Berry Ave. k 779(602) 913(904) 212(323) 183(218) 155(159) 118(258) 13 14 r 116(213) 15 Pa 88(189) 128(155) 120(198) 874(747) 787(521) 57(188) 74(49) 197(179) 3(2) 10 11 12 648(710) 335(239) 104(314) 214(67) 5(21) 171(285) 442(1146) 89(185) 4(19) 884(1144) 34(56) 796(992) 162(299) 102(253) 54(148) 501(776) 235(137) 139(214) 69(285) 34(28) 16(127) 38(5)

13 14 16(21) 15 16(7) 57(252) 33(24)

851(732) 77(39) 275(187) 160(57) 96(276) 25(44) Figure 2.2

FELSBURG Existing Belleview Avenue Study Area Traffic Demands HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

The peak hour turning movements show heavy use of the interchange and the first intersection on either side of it. The predominant patterns through the interchange (exclusive of the Quebec Street and DTC Parkway/Syracuse Way intersections) include the exchange of trips between the north and west (many of which are also oriented to/from Quebec South) which makes up more than 25 percent of the total interchange demand. Another major exchange pattern through the interchange includes trips crossing I-25, which also comprises slightly more than 25 percent. Commuter patterns can be observed in the data that reflect heavy employment in the area as the off-ramp traffic (from both I-25 directions) is heavier during the morning peak hour and the on-ramp traffic (again in both I-25 directions) is heavier during the PM peak hour. This is particularly true with respect to traffic to/from the east side of I-25. The major patterns through the intersection are shown on Figure 2.3. The busier cross-streets include Quebec Street south of Belleview Avenue, DTC Boulevard, and Monaco Street. DTC Boulevard and Quebec Street (south of Belleview) are the busiest cross- streets within the corridor study area serving nearly 20,000 vehicles per day. Most of the traffic traveling DTC Boulevard (approximately 70 percent during peak hours) is simply crossing Belleview Avenue traveling north-south. On the other hand, traffic patterns to/from Quebec Street are heavily oriented to/from Belleview Avenue; Quebec Street terminates a couple blocks north of Belleview Avenue so much of its traffic to/from the south is oriented to/from Belleview Avenue. Approximately 55 percent of the peak hour traffic on Quebec Street is oriented to/from the east (and much of this oriented to/from I-25 north), whereas 40 percent is oriented to/from the west. Syracuse Street/DTC Parkway, located just east of I-25, serves less traffic, but the patterns at the Belleview Avenue intersection are heavily oriented to/from the west; between 70 and 80 percent of the traffic along this cross-street either turns towards or comes from the I-25 interchange. Operations Intersection LOSs were calculated for the study area intersections given the existing conditions at each intersection. The analysis is based on procedures documented in the Highway Capacity Manual 2010 (Transportation Research Board, Fifth Edition, 2010). This analysis procedure provides an LOS, which is a qualitative measure based on the average delay per vehicle at a controlled intersection. Levels of service are described by a letter ranging from “A” to “F”. LOS A represents minimal delay, while LOS F represents excessive congestion and delay. The signalized intersection analysis reports an LOS rating for the entire intersection, although LOS measures for each movement are calculated. A LOS D or better at peak traffic times in an urban environment typically constitutes acceptable conditions. The Synchro traffic analysis software was used to develop the LOS calculations. Synchro applies capacity analysis procedures specified in the Highway Capacity Manual 2010 published by the Transportation Research Board. Further, this software package includes a simulation module (referred to as Sim Traffic) that allows the user visualize the results. This package is often used in preparing PEL reports. Figure 2.4 shows the LOS results for the AM and PM peak hours. Intersections in which the LOS D threshold is not being met include the interchange ramps and the DTC Parkway/Syracuse Street intersection just to its east. This is primarily due to the relatively close spacing of these intersections in combination with heavy concentration of traffic demand. Also, while the overall LOS at the Belleview Avenue/Quebec Street intersection shows an overall LOS D, some movements are operating much worse.

Page 6 26% 25 17%

Belleview Ave. 25% Belleview Ave.

19% 13% DTC Pkwy.DTC St. Syracuse Quebec St.

Figure 2.3

FELSBURG I-25/Belleview Interchange Traffic Patterns HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 LEGEND A/B B/B B/B = Lane Assignment x/x = Stop-Controlled Movement Level of Service Tufts Ave. 1 2 3 X/X = Signalized Intersection Level of Service = Stop Sign = Traffic Signal 3

Union Ave. A/A E/F

2 c/f

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o c 4 5 6

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o Niagara St. Niagara M Belleview Ave. b/f 4 5 88 6 7 8 9 10 11

NOTE: E/D D/E A/E Intersection 5 was unsignalized at the time of this study, but a Progress Pl. Pkwy. DTC DTC Blvd. DTC Monaco St. Monaco signal was being planned. 12 ve. Prentice A 25 7 8 9

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c/f 10 11 12 b/b A/A a/a

NOTE: 13 b/c a/a 14 Intersections 5 and 12 are unsignalized; 15 a/a LOS's shown are for the specific movement. Figure 2.4

FELSBURG Existing Intersection Geometry and Levels of Service HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

Namely, the northbound approach left and right turn movements suffer significant delay during the PM peak hour as queues can often build to one-quarter to one-half mile in length. Improvements were recently completed at this intersection to add an additional northbound lane, thereby simplifying the signal phasing and improving the overall operations. However, the interchange area has remained an issue relative to functionality. Outside the interchange area, all the other study area intersections are currently operating at acceptable levels. There is one minor exception to this, namely the unsignalized access onto Belleview Avenue from the south, opposite Niagara Street. Traffic along this approach experiences significant delay in turning onto Belleview Avenue during the PM peak hour, but the approach traffic demand is light at that time (approximately 40 vehicles per hour or one vehicle approaching every 90 seconds, on average). While not ideal, a very low volume of traffic experiencing a LOS F is generally not considered a significant issue; it only represents one percent of the entire peak hour traffic passing through the intersection. Further, this condition will improve with signalization (which was planned and installed near the end of this study). Accidents The safety of any transportation system is among the priority considerations when considering long-term improvements, and PEL reports typically require a safety assessment. Understanding recent accident experience helps assess the safety of the current system. Crash data along the Belleview Avenue corridor have been compiled for the three-year period of 2009 to 2011. The data were obtained from CDOT (for the section west of and including I-25), City and County of Denver, and Greenwood Village. Because there are three sources, all data were carefully reviewed for duplication reports. The vast majority of the crashes occurred at the signalized intersections, and Figure 2.5 shows the results. The figure gives a snapshot by showing how many accidents occurred at each intersection during the three-year time period, the kind of accident that has occurred, and a relative sense as to whether the crash experience exceeds expectations given the signalized intersection’s traffic demands. The relative sense of expectation is based on crash experience at similar intersections as compiled by CDOT. Three signalized intersections stand out with respect to the magnitude of collisions; these include the Belleview Avenue intersections with Quebec Street and with both I-25 ramp intersections; the current interchange complex may not be among the best solutions with respect to safety. Besides being the locations with the most accidents in the corridor, these three locations are also shown to have experienced an above average number of accidents given their traffic. The predominant pattern at the ramp intersections included “Front to Side” collisions, many of which included approach left turning vehicles colliding with opposing through movement vehicles. At the two ramp intersections, the “Front to Side” accident type comprised over one-half of the total accidents. It is thought that some of these are due to the capacity constraints of the left turn movements (which are allowed only on a green arrow) and drivers pushing the limits of the yellow and all-red phases so as to avoid another signal cycle of delay. The Quebec Street intersection accident pattern was different in that “Front to Rear” type of accidents made up the majority of collisions types. Many of these took place along the northbound approach.

Page 9 LEGEND 1 1 1 2 1 1 1 1 7 5 Type of Crash 4 23 8 21 Tufts Ave. 14 = Front to Rear 12 4 10 20 = Front to Side 5 6 = Front to Front 9 = Side to Side - Syracuse Street Ulster Street same direction 49 59 = Sign/Structure Southbound I-25 Ramps Northbound I-25 Ramps = Pedestrian Union Ave. = Bicycle

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= Other t

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s = Relative Number . u

of Crashes t c

S a

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= Number of Crashes S XX a

n

o Niagara St. Niagara Ulster St.

= Better than 23 M Expected Number 72 34 34 34 Belleview Ave. of Crashes 88 = Moderately Above Number of Crashes 95 102 Expected = Significantly Above Number of Crashes Progress Pl.

Expected Blvd. DTC DTC Pkwy. DTC Monaco St. Monaco ve. = Within One Standard Prentice A Deviation Above 1 1 1 2 3 Expected Number of 1 Crashes . y

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1 a a r Quebec St. V Number of Crashes 2 40 r e 2 15 Berry Ave. T 9 rk DTC Boulevard 1 Pa

Quebec Street 8

Monaco Street Figure 2.5

FELSBURG SOURCES: CDOT, City & County of Denver, Greenwood Village Signalized Intersection Crash Summary (2009-2011) HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

A review of the time-of-day crash patterns at I-25/Belleview interchange (since this area experienced the highest number of crashes in the study area) indicates that patterns can vary throughout the day. Noteworthy observations include:  Approximately one-half of all crashes that occurred at the Belleview/Syracuse/DTC Parkway intersection occurred between 3:00 and 6:00 PM. Two-thirds of the 3:00 to 6:00 PM crashes were front-to-rear (rear-end) crashes. Congestion appears to be a significant contributor to accidents at this location.  While not as pronounced, a similar pattern can be seen at the Belleview/Quebec intersection (crash data reflect a period prior to the recent improvements) in which 25 to 30 percent of the all crashes occurred between the hours of 4:00 and 7:00 PM of which nearly two-thirds were rear end crashes. Again, congestion appears to be a contributor toward some of the crash experience.  The I-25/Belleview Interchange also experiences a greater number of accidents during the PM timeframe (mid- afternoon as well as the PM peak commuter period), but the accident type pattern resembles that of the entire accident population (as depicted in the pie chart of Figure 2.5). However, the interchange also experiences a peak during the 9:00 PM to 12:00 AM timeframe. Approximately 15 percent of the interchange’s accidents have occurred during these three hours (which only represent five percent of the daily traffic). There is not a clear pattern that can be seen from the crashes during this time period, and the data do not indicate whether alcohol might have been involved.

Page 11 Existing Transportation Conditions Draft Report

3.0 ALTERNATIVE TRANSPORTATION MODES 3.1 Transit Light rail rapid transit and numerous RTD bus routes serve the Belleview Avenue corridor study area, and these are shown on Figure 3.1. Seven bus routes including the 27, 46, 65, 73, 105, 121, and the T route all serve the area. These all converge at a major bus transfer center located at Ulster Street and Tufts Avenue, northeast of the I-25/Belleview Avenue interchange. Two of these routes travel along the Belleview Avenue corridor. Route 73 makes use of the western section from Monaco Street to Quebec Street. The T route uses the short section from Syracuse Street to Quebec Street as part of its run. The light rail line is located along the west side of I-25 with stations located roughly every mile within the Tech Center area. The serves most of the study area, and it is located on Quebec Street approximately one-quarter mile north of Belleview Avenue. Quebec Street terminates at the light rail station. A 59-space park-n-Ride is also provided at this station, and on-street parking available in the area allows another 50 to 60 vehicles for light rail riders driving to the station. Fixed route bus service does not serve the station directly, but with recent improvements along the Union Avenue bridge near the station, routes 46 and 73 are now connected to the station via elevators and stairs. Also, RTD operates a Call-n-Ride service which tends to coordinate with the heavier train arrivals and departures. Scheduled stops are made at the station during peak periods (with less frequent service corroding during mid-day hours), and the service area for the Call-n-Ride is east of I-25 bounded by I-225, Yosemite Street, Orchard Road, and I-25. This Call-n-Ride’s service area is limited west of I-25 to only areas adjacent to Quebec Street (north of Belleview). Other areas west of I-25 such as the Landmark are served by the Call-n-Ride service associated with the Orchard Station. A train station is also located near Orchard Road serving the southern sections of the study area. A pedestrian bridge connecting the east and west side of I-25 is located in close proximity to the Orchard Station so as to provide service to both sides of the interstate. Call-n-Ride service is also provided from this station. Figure 3.2 shows the relative use of transit stops in the study area based on data provided by RTD. The light rail stations see the heaviest use; the Belleview Station experiences an average of 1400 persons a day (boarding and alighting combined) and the Orchard Station serves a similar level of activity. The Ulster Street and Tufts Avenue bus transfer stop experiences less activity, but this transfer center stills stands out as one of the busier transit facilities in the area. Early 2012 Call-n-Ride data shows that the Belleview service served between 30 and 40 riders per day; the Orchard service saw approximately 100 riders per day in early 2012. All of the routing bus stop information shown on Figure 3.2 was summarized and allocated to the nearest intersection for summarization reasons. Specifically along Belleview Avenue, the transit stops are not heavily used with each serving fewer (and in many cases far fewer) than 50 persons per day.

Page 12 Tufts Ave.

LEGEND = Orchard Light Rail Station Union Ave. = Belleview Light Rail Station

= Ulster/Tufts Transfer Station

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t = Belleview Call-n-Ride Service S

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a RTD Transit Lines y Ulster St.

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= 27 M = 46 Belleview Ave. 88 = 65 = 73 = 105 = 121 Progress Pl. DTC Pkwy.

= T Blvd. DTC Monaco St. Monaco = E Line ve. Prentice A = F Line

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Figure 3.1 RTD Transit

FELSBURG Serving the Belleview Corridor HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 08/18/15 LEGEND Tufts Ave. = Orchard Light Rail Station = Belleview Light Rail Station = Ulster/Tufts Transfer Station = Belleview Call-n-ride Service = Orchard Call-n-Ride Service

Union Ave. Daily Total Boardings and Alightings

(Spring 2012)

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t S

= >1,000 . t e

S s

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o c

c a r

a y Ulster St.

n

= 500 - 1,000 S

o Niagara St. Niagara M Belleview Ave. = 100 - 500 88

= 50 - 100 = 0 - 50

Progress Pl. DTC Pkwy. DTC Blvd. DTC Call-n-Rides Average Daily Boardings St. Monaco ve. Prentice A = Belleview Avenue call-n-Ride - 30 to 40

= Orchard Road call-n-Ride - 100 . y

Quebec St. DTC

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Figure 3.2 RTD Transit Stop

FELSBURG Daily Activity HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

3.2 Pedestrian and Bicycle Facilities Many of the streets in the study area provide sidewalks for pedestrian use. Some walks are attached while others are detached, creating a more comfortable pedestrian environment. Widths generally vary from five to ten (narrow widths are along sections of Union). Figure 3.3 shows the roadway sidewalk locations along the study area roadways. Most of the sidewalks in the area are detached or at least meandering along the side of the road (depicted with alternating attached and detached denotation). Along Belleview Avenue, there are several obvious gaps in the sidewalks. They include:  Through the I-25 Interchange. A detached sidewalk (eight to ten feet in width) is provided along the north side of Belleview Avenue through the I-25 interchange, but there is not any kind of pedestrian facility along the south side. Pedestrians are prohibited along the south side and must cross to the north side at Quebec Street and at DTC Parkway/Syracuse Street intersection to safely walk through the interchange complex.  West of Quebec Street. While a sidewalk does not exist along the north side of Belleview Avenue east of Niagara Street, it is anticipated that the Belleview Station development will complete this gap upon development. Figure 3.4 shows the trails and dedicated bicycle lanes in the area. On-street facilities are provided along Union Avenue, Ulster Street (north of Belleview Avenue), and Progress Place/ Berry Street through the Landmark area. Off-street trails are provided west of DTC Boulevard (along Goldsmith Gulch) and south of Belleview Avenue between Quebec Street and Monaco Street. 3.3 Transportation Demand Management The study area is part of a larger Transportation Management Agency (TMA), referred to as the Southeast Connections. This agency encourages users of the area to travel via non-automobile modes and provides resources in support of this cause. Their service area is generally located along the I-25 corridor in the southeast metro area, and agency partners include Arapahoe County, Douglas County, City of Greenwood Village, City and County of Denver, City of Centennial, City of Lone Tree, Centennial Airport, SPIMD, and DSEDP. The agency’s objectives include enhancing 1) mobility, 2) economic growth, and 3) image. They are especially concerned with limiting the amount of traffic at peak times through:  Carpooling  Transit  Bicycle  Flex hours  Working from home

Page 15 Tufts Ave.

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Figure 3.3 Existing Sidewalks and

FELSBURG Connecting Trails HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 LEGEND Existing Tufts Ave. = Wide Right Lane with Sharrow = Bike Lanes = Multi-use Trail (Paved) = Multi-use Trail (Unpaved) = Denver Designated Bike Route Planned (Denver Moves) Union Ave. = Proposed Bike Lanes

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FELSBURG Bike and Multi-use Facilities HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

Toward this end, certain measures could contribute such as:  Wider and more sidewalks and trails  Direct pedestrian connections between major activity areas  Frequent, convenient and efficient transit service (possibly with intelligent transportation systems, Intelligent Transportation System [ITS], technologies)  Bicycle lanes, where appropriate  Wayfinding information via variable message signs and smart phone applications.  Other provisions of traveler information regarding local conditions 3.4 Intelligent Transportation Systems The notable ITS that currently exists along within the Belleview Avenue corridor includes the interconnection of four-signal system between Quebec Street and DTC Parkway/Syracuse Street. These four are part of CDOT’s communication system that connects to the fiber optic backbone that was installed along I-25 as part of the TREX project. Recently, CDOT obtained funding to add three additional signals to the system including Niagara Street (which was not yet signalized at the onset of this project), Monaco Street, and Holly Street (all west of I-25 along state highway designation of Belleview Avenue). Provision for the extra communication capability should provide for improved signal coordination. The recent funding will replace a 12-strand fiber optic cable with a 96-strand cable, allowing greater bandwidth for other ITS devices. In addition, this improvement could eventually allow better monitor traffic conditions, uploading of signal timing information, installation of pan-tilt- zoom cameras for surveillance, dynamic message signs to convey information, among other devices to help manage travel along the corridor.

Page 18 Existing Transportation Conditions Draft Report

4.0 SURROUNDING LAND USE The surrounding area was assessed relative to land use as is typically done as part of a PEL study. The area contains a various mix of uses, but the predominant use tends to be office and commercial/service oriented. Figure 4.1 shows the current mix of uses within the study area. Immediately surrounding the interchange is primarily office/commercial development with vacant ground on the northwest. This vacant ground is programmed for development, referred to as the Belleview Station development, planned to include approximately 5.3 million square feet of mixed-use development. This development will access directly onto Belleview Avenue as well as Union Avenue once it is built out. Another redevelopment recently completed is the Kuni Lexus dealership. Office and other commercial uses are the predominant uses along the entire corridor, but residential and open space exists at locations away from the interchange (although none of the residential uses front onto Belleview Avenue within the study area. DRCOG land use data were also obtained to assess the baseline quantifications from which future conditions will build upon. Figure 4.2 shows their current transportation analysis zone (TAZ) structure in the area, and Table 4.1 illustrates the household and employment levels that exist in each. Trip-making for future conditions is based on these two key land use variables. Table 4.1 DRCOG Land Use Production Retail Service TAZ Households Employment Employment Employment 1684 1,412 31 83 161 1685 521 8 9 58 1686 892 479 213 816 1687 0 399 427 3,123 1688 0 807 401 3,366 1689 369 5 3 30 1690 244 295 240 143 1691 547 44 192 704 1692 1 1,682 412 2,941 1693 280 3 47 193 2176 193 1 0 327 2207 220 23 21 153 2208 124 271 54 1,087 2209 55 237 306 1,375 2210 34 67 243 2,575 2211 0 257 145 779 2247 0 440 187 1,883 2248 27 146 368 1,510 2249 605 268 167 2,199 2250 199 127 252 574 2251 332 66 4 88 2252 378 89 79 2,308 2253 14 7 76 48

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Table 4.1 DRCOG Land Use Production Retail Service TAZ Households Employment Employment Employment 2254 282 183 134 815 2255 11 374 24 1,099 2256 0 237 184 3,843 2271 248 27 38 323 2274 355 18 296 1,161 TOTAL 7,343 6,591 4,605 33,682

Employment dominates the land use quantities with the largest employment being southeast of the I-25/I-225 interchange (TAZs 1687 and 1688) as well as the areas just northeast of the I-25/Belleview Avenue interchange (TAZ 1692) and northeast of the I-25/Orchard Road interchange (TAZ 2256).

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Figure 4.1 FELSBURG Existing Land Use HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 2/5/13 25 Quincy Ave. 1684 1685 225

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FELSBURG Existing Transportation Analysis Zones (TAZs) HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

5.0 ENVIRONMENTAL CONSIDERATIONS Similar to a PEL study, this effort included a preliminary environmental analysis to identify environmental issues that may affect the planning decision and to identify environmental issues that require additional evaluation in any future NEPA documentation. The analysis was conducted by reviewing available existing documents, conducting archival research, and performing site visits. Table 5.1 and Figure 5.1 summarize the environmental resources evaluated and identify those that would potentially be affected by the alternatives. The majority of the study area was included in Southeast Corridor Environmental Impact Statement (CDOT 1999) and Southeast Corridor Record of Decision (CDOT 2000). Table 5.1 Summary of Potential Environmental Issues

Environmental Concerns Needing Avoidance/ Further Analysis Needed on Resource Minimization/Mitigation Preferred Alternative Yes—Wetland Delineation Wetlands None expected Report Yes—Biological Survey/ Noxious Weeds None expected Assessment Wildlife Habitat None expected None expected Special Status Yes—Biological Survey/ None expected Species Assessment Water Resources None expected None at this time Yes—Air Quality Impact Air Quality None expected Assessment Petroleum contaminated soil and groundwater may be present in the Yes—Initial Site Assessment Hazardous vicinity of the Belleview Avenue/ (ISA) or Phase I Environmental Materials Quebec Street and Belleview Site Assessment Avenue/Ulster Street intersections Sensitive receptors are present and Yes—Noise Impact and Noise may be impacted Abatement Analysis All are disqualified from eligibility in Cultural Resources the National Register of Historic None expected Places (NRHP) Parks and None expected None expected Recreational Trails

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Figure 5.1 FELSBURG Environmental Resources Evaluation HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 9/1/15 Existing Transportation Conditions Draft Report

5.1 Biological Resources The biological resources in the study area consider wetlands and Waters of the U.S., wildlife and habitat such as riparian areas, and vegetation. Impacts associated with roadway improvements have the potential to cause habitat loss, spread noxious weeds, and impact wildlife. An assessment of the biological resources will be necessary in the Biological Report. Wetlands Wetland resources are protected under Section 404 of the Clean Water Act and Executive Order 11990 Protection of Wetlands. The Clean Water Act requires coordination with the US Army Corps of Engineers (USACE) and resources agencies, such as the U.S. Environmental Protection Agency (USEPA) and the US Fish and Wildlife Service (USFWS), for impacts to waters of the U.S. A jurisdictional determination by the USACE is required to determine if a water body or wetland is a water of the U.S. The U.S. Department of Transportation Order 5660.1A, Preservation of the Nation’s Wetlands, provides guidance on wetland mitigation assessment. CDOT has incorporated this and other Federal Highway Administration (FHWA) environmental guidance into its Environmental Stewardship Guide (CDOT 2005). Although certain wetlands may not fall under USACE jurisdiction and therefore are not afforded protection under the Clean Water Act and Executive Order 11990, CDOT policy requires that impacts to all wetlands be avoided and minimized to the greatest possible extent. A wetland delineation report was not prepared nor submitted to the USACE as part of this analysis; however, a thorough desktop and onsite assessment of the study area for the presence of jurisdictional and non-jurisdictional wetlands, as defined under Section 404 of the Clean Water Act, was conducted in July 2012 and was based on the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Great Plans Region (Version 2.0) (USACE 2010) for the presence of wetland vegetation and hydrology indicators. No soil pits were dug to identify if hydric soils were present. Previous wetland mapping was also reviewed for existing wetlands in the study area. Staff reviewed the National Wetland Inventory (NWI), which is a dataset managed by the USFWS as well as incorporating wetlands which are mapped by Arapahoe County. Figure 5.1 depicts potential wetlands in the study area. Potential wetlands identified are located along Goldsmith Gulch south of Syracuse Street, in Monaco Park, in the Open Space east of Monaco Park, in the northern section of Running Fox Park, and at Monaco/ Wetland pond in Crestline Park. Running Fox Park. A jurisdictional determination has not been made for the wetlands along Goldsmith Gulch although the wetlands along Goldsmith Gulch are assumed to be jurisdictional. Goldsmith Gulch is considered a Water of the U.S. and is identified on a US Geological Survey (USGS) 7.5” topographical map as being a perennial stream. The USGS topographical map also identifies an un-named intermittent stream at Monaco/Crestline Park.

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A Wetland Delineation Report will need to be prepared to assess jurisdictional and non- jurisdictional wetlands and open water. In accordance with USACE requirements, wetlands will be delineated based on three parameters: hydrology, soil, and vegetation. Riparian and wetland vegetation, as well as upland vegetation, will be identified. The ordinary high water mark will be established along the banks of Goldsmith Gulch and the un-named intermittent stream in the study area to determine jurisdictional open water (Waters of the U.S.). As part of the Wetland Delineation Report, the functional value of each wetland will be determined. The Wetland Delineation Report will be prepared and submitted to the USACE for concurrence. A Wetland Findings Report will be prepared based on the preferred alternative. FHWA and CDOT policy requires compensatory mitigation for permanent impacts to both jurisdictional and non-jurisdictional wetlands. Wetland mitigation is typically done on a 1:1 basis; however, a Clean Water Act Section 404 permit, which will be issued by the USACE, may require higher ratios if unique or high quality wetlands are impacted. Goldsmith Gulch is a perennial stream that provides habitat for a variety of coldwater aquatic organisms, including macroinvertebrates and fish. An assessment of these aquatic resources will be necessary. Noxious Weeds The Colorado Noxious Weed Act (Colorado Revised Statutes [CRS] 35-5.5) requires the control of designated noxious weeds. The study area is located in the plains grassland ecosystem or mid-height grasslands. The increase of impervious surfaces and other human caused activities have already altered the ecological value (CDOT 1999). No site assessment was conducted at this time; however, the locations and species of noxious weeds will need to be documented based on a survey in conformance with CDOT guidelines during final design. An assessment of noxious weeds will be included in the Biological Resources Report. Wildlife Habitat A site assessment of wildlife habitat was conducted in July 2012. With the exception of the parks and open space within the study area, the majority of the study area has little ecological value for wildlife habitat due to urbanization. The highest ecological value habitat exists at Goldsmith Gulch south of Syracuse Street, at Monaco Park, the Open Space to the East of Monaco Park, Running Fox Park, and Monaco/Crestline Park. However, all of these parks are isolated and provide minimal use for large numbers of wildlife species due to the lack of habitat connectivity between parks. Any wildlife movement that occurs in the study area is north-south along Goldsmith Gulch and east-west along the un-named intermittent stream located at Monaco/Crestline Park. There is no connection between Goldsmith Gulch and Monaco/Crestline Park (see Figure 5.1). A Senate Bill 40 permit will need to be acquired from the Colorado Parks and Wildlife (CPW) for Wetland pond in actions that disrupt the Goldsmith Gulch stream bank, stream channels, and riparian areas as Running Fox Park. well as areas around the un-named intermittent stream at Monaco/Crestline Park. Riparian vegetation will be assessed during the Wetland Delineation Report and Biological Resources Report to support preparation of a Senate Bill 40 evaluation. An assessment of aquatic resources will be included in the Biological Resources Report.

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Special Status Species Special status species refer to species that have been listed by the USFWS as being either endangered (FE), threatened (FT), or a candidate for listing (FC) (under the Endangered Species Act), or by the CPW as endangered (SE), threatened (ST), or special concern (SC) at the state level (under the authority of the CRS and Colorado Wildlife Commission regulations). Table 5.2 identifies special status species potentially located in the study area. This list was researched by using the CPW’s Natural Diversity Information Source (NDIS) website and the USFWS Information, Planning, and Conservation System (IPaC) website. Table 5.2 Special Status Species

Species Status Description Habitat Present? American Peregrine SC Native to the Front Range and inhabits Not Present Falcon (Falco peregrinus rock and cliff habitats. anatum) Bald Eagle (Haliaeetus ST Found throughout Colorado and Not Present leucocephalus) inhabits reservoirs and river/riparian environments. Black-Tailed Prairie Dog SC Inhabits short and mid-grass prairie Not Present (Cynomys ludovianus) and semi-desert shrublands. Ferruginous Hawk SC Occurs along the Colorado Front Not Present (Buteo regalis) Range, inhabits grasslands and semi- desert shrublands. Least Tern FE/SE Nest on bare sandy shorelines of Not Present (Sternula antillarum) islands and reservoirs. Migrants occur at reservoirs, lakes, and rivers with bare sandy shorelines. Mexican Spotted Owl FT/ST Residents of old-growth or mature Not Present (Strix occidentalis lucida) forests that possess complex structural components (uneven aged stands, high canopy closure, multi- storied levels, high tree density). Midget-Faded SC Tend to prefer rocky outcrops in areas Not Present Rattlesnake (Crotalus where sage is the abundant viridis concolor) vegetation. (venomousreptiles.org 2010) Northern Leopard Frog SC Inhabits wet meadows, and the banks Present (Rana pipiens) and shallows of marshes, ponds, beaver ponds, lakes, reservoirs, streams, and irrigation ditches. Northern Pocket Gopher SC Inhabits agricultural and pasture lands, Not Present (Thomoys talpoides semi-desert shrublands, and macrotis) grasslands.

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Table 5.2 Special Status Species

Species Status Description Habitat Present? Pallid Sturgeon FE Adapted to living close to the bottom of Not Present (Scaphirhynchus albus) large, silty rivers. Preferred habitat has a diversity of depths and velocities formed by braided channels, sand bars, sand flats and gravel bars. Preble’s Meadow FT/ST Inhabits stream, riparian, and other Not Present, also Jumping Mouse (Zapus mesic environments. within the hudsonius preblei) Preble’s Meadow Jumping Mouse Block Clearance Zone (BCZ) Piping Plover FT/ST Inhabits mudflats and shorelines of Not Present (Charadrius melodus) reservoirs and lakes. Breeding birds are found on sandy open shorelines with pebbles. Plains Short-Tailed SE Inhabits Gambel oak and other Not Present Grouse (Tympanuchus shrublands lacking conifers. phasianellus jamesii) Swift Fox SC Inhabits grasslands, from shortgrass to Not Present (Vulpes velox) midgrass prairies over most of the Great Plains. Townsend’s Big-Eared SC Inhabits semi-desert shrublands, Not Present Bat (Corynorhinus pinyon-juniper woodlands, and open townsendii pallescens) montane forest. Ute Ladies’-Tresses FT Inhabits sub-irrigated alluvial soils Not Present Orchid (Spiranthes along streams and in open meadows diluvialis) in floodplains. Western Burrowing Owl ST Inhabits grasslands and semi-desert Not Present (Athene cunicularia) shrublands, usually in or near prairie dog towns. Western Prairie-Fringed FT Occurs most often in mesic to wet Not Present Orchid (Platanthera unplowed tallgrass prairies and praeclara) meadows but have been found in old fields and roadside ditches. Whooping Crane (Grus FE/SE Has been recorded in mudflats around Not Present Americana) reservoirs and in agricultural areas.

Notes: FE Federally listed endangered species SE State listed endangered species FT Federally listed threatened species ST State listed threatened species FC Federally listed candidate for listing SC State listed special concern

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No defined special status species habitat exists within the project study area. A Biological Resources Report of threatened and endangered species, including aquatic species, will be required. Coordination with the USFWS and CPW would be necessary to mitigate potential impacts to special status species habitat. 5.2 Water Resources The study area lies within the Little Dry Creek to un-named watershed, part of the Goldsmith Gulch stream segment (COSPCH04) in the 6th level Hydrologic Unit Code (101900030304 and 101900020906). The Goldsmith Gulch stream segment (COSPCH04) currently is on the Colorado Department of Public Health and Environment’s (CDPHE) 303(d) list and is listed as having a Section 303(d) stream impairment for Selenium, but is considered Low Priority. If a stream segment is on the 303(d) list, it requires the development of a total maximum daily load (TMDL). TMDL is a term that represents the total amount of a pollutant that a waterbody can assimilate and still meet standards. This segment of the Goldsmith Gulch has no TMDLs at this time. 5.3 Air Quality The Clean Air Act of 1970 and its amendments led to the establishment by USEPA of National Ambient Air Quality Standards (NAAQS) for several criteria air pollutants: carbon monoxide (CO), sulfur dioxide, ozone (O3), suspended particulate matter (PM10), nitrogen dioxide, and lead (Table 5.3). In 1997, USEPA changed the O3 standard from 1-hour to 8-hour averages (note: the 1-hour standard has been revoked by USEPA) and added a new standard for very fine particulate matter (PM2.5). Table 5.3 National Ambient Air Quality Standards

Primary Pollutant Averaging Time Standard 8 hours 9 ppm Carbon Monoxide 1 hour 35 ppm Annual 0.03 ppm Sulfur Dioxide 24 hours 0.14 ppm 1 hour 75 ppb Ozone 8 hour 0.075 ppm 3 Particulate Matter <10 µm (PM10) 24 hours 150 µg/m Annual 15 µg/m3 Particulate Matter <2.5 µm (PM ) 2.5 24 hours 35 µg/m3 Annual 53 ppb Nitrogen Dioxide 1 hour 100 ppb Lead Quarterly 0.15 µg/m3 Source: EPA, 2012. Notes: ppb = parts per billion ppm = parts per million µg/m3 = micrograms per cubic meter µm = micrometers

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The Denver metropolitan area has been in attainment of the sulfur dioxide, nitrogen dioxide, lead, and PM2.5 NAAQSs since monitoring began for each of them. The Denver metropolitan region had been a nonattainment area for CO, O3 (1-hour), and PM10 but reached attainment/ maintenance status for each of them by 2002, so those three pollutants have historically been concerns in Denver. The Denver region was designated a nonattainment area for the 8-hour O3 NAAQS in 2007. These classifications are long term and do not change often. In general terms, federal regulations include requirements for transportation systems and individual projects within NAAQS nonattainment and maintenance areas to conform to the relevant air quality improvement plans and to not worsen local air quality conditions. Therefore, transportation improvement projects must be evaluated for effects on air quality in the Denver area. Vehicles are a major source of air pollutants in the study area, particularly those pollutants that have been regulatory problems within the larger Denver metropolitan area (CO, O3, and PM10). Vehicles are getting cleaner with time due to advances in technology and stricter regulatory requirements. Nevertheless, changes in roads that can increase traffic volumes or increase congestion may diminish air quality in the study area, and such changes must be viewed for regional impacts as well. The Denver metropolitan area, which includes the study area, has experienced a trend of generally improving air quality conditions for several decades. None of the current air quality monitoring stations is within the study area, so data from the nearest permanent stations were reviewed to summarize existing conditions. Note that 2011 is the most recent year with a full data set. The air pollutants of greatest concern for the study area are described below. Carbon Monoxide Measured concentrations of CO in the Denver area have not violated the NAAQS since 1995. For the CO station nearest to the study area (678 S. Jason Street), the 2011 measured values for NAAQS comparison for CO for 1 hour and 8 hours are 2.3 ppm and 1.5 ppm. These values are below their respective NAAQS (Table 5.3). Particulate Matter

Measured concentrations of PM10 in the Denver region have not violated the NAAQS since 1993, while PM2.5 concentrations have never violated the NAAQS during its monitoring period.

For the PM10 station nearest the study area (678 S. Jason St), the 2011 measured PM10 value 3 for NAAQS comparison is 61 µg/m . For the PM2.5 station nearest the study area (6190 S. Santa Fe Drive), the 2011 measured values for NAAQS comparison for 24 hours and annual are 14 µg/m3 and 6.3 µg/m3, respectively. These values are below their respective NAAQS. Ozone Ozone is not emitted directly from vehicles, but instead is formed in the atmosphere through chemical reactions between certain pollutants. Measured concentrations of 8-hour O3 in the Denver region violated the NAAQS in 2011, but the O3 violations are most pronounced in the western metropolitan area. For the O3 station nearest the study area (8100 S. University Boulevard), the 2011 measured O3 value for NAAQS comparison for 8 hours is 0.074 ppm. This

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value is below the NAAQS; however, other stations in the Denver monitoring network recorded violations of the O3 NAAQS in 2011. Mobile Source Air Toxic Pollutants Most toxic air pollutants originate from human-made sources, including on-road mobile sources (e.g., automobiles), non-road mobile sources (e.g., airplanes), area sources (e.g., dry cleaners), and stationary sources (e.g., factories). Mobile Source Air Toxics (MSATs) are a subset of the 188 air toxics defined in the Clean Air Act. MSATs are compounds emitted from highway vehicles and mobile non-road equipment. Some MSATs are present in fuel and are emitted to the air when the fuel evaporates or passes through an engine unburned. Some MSATs are emitted from the incomplete combustion of fuels or as secondary combustion products. Federal regulations are reducing these pollutant emissions from vehicles. Between 2000 and 2020, FHWA estimates that the regulatory programs will reduce on-highway emissions of benzene, formaldehyde, 1,3-butadiene, and acetaldehyde by 57 to 65 percent and will reduce on-highway diesel particulate emissions by 87 percent, even with a 64 percent increase in miles traveled. Mitigation and Best Management Practices Air quality can be affected by mobile sources at both the regional and local levels. Individual projects generally do not have a significant effect at the regional level because of their small relative size, but collectively the individual road segments constitute the larger regional network for all the mobile sources. For this reason, regional air quality is more affected by higher-level controls on mobile sources, such as national vehicle emission standards. These types of controls can affect regional air quality over time, but are clearly beyond the scope of individual projects such as improvements to the Belleview Avenue corridor. Individual projects can have a much greater effect on local air quality, such as pollutant hotspots around a congested intersection. There are many local changes that could be used individually or collectively to reduce local pollutant emissions, such as coordinated signal timing. For the range of vehicle speeds likely on the project roads, changes that will reduce vehicle idling time or increase vehicle speeds in congested traffic will also reduce local pollutant emissions from mobile sources. The typical next step would be to complete an air quality analysis, if necessary, for the Belleview Avenue improvements to evaluate both regional and local air quality effects. The DRCOG 2035 Regional Transportation Plan Metro Vision (RTP) envisions Belleview Avenue as a 4-lane street through the study area. Other possible road configurations have not been evaluated, so a regional conformity analysis would be needed through a future RTP amendment for any plan with more than four traffic lanes on Belleview Avenue or any other recommended road/transit improvements. The regional analysis would actually be done by DRCOG through their conformity analysis for the RTP and Transportation Improvement Program. A local-level analysis for corridor alternatives may be needed during future NEPA actions that looks at hot-spot modeling for CO concentrations at intersections or other locations where

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vehicle idling may result in higher CO concentrations. A qualitative analysis for PM10 hot-spots may be needed and possibly calculation of daily emission levels of the mobile source pollutants. Often a concurrence letter from the Air Pollution Control Division on conformity is required. Although MSATs can be difficult to quantify, some level of qualitative MSAT analysis may be necessary, depending on details of the proposed action. 5.4 Environmental Contamination Issues Brown and Caldwell performed a Modified Phase I Environmental Site Assessment and Phase II Environmental Site Assessment for the Southeast Corridor Project, which included a portion of the study area (Brown and Caldwell 1998; Brown and Caldwell 2000). Felsburg Holt & Ullevig (FHU) reviewed these reports, verified sites with potential hazardous material conditions in publicly accessible databases with the CDPHE and the Colorado Department of Labor and Employment Division of Oil and Public Safety (OPS), and conducted a “windshield survey” limited site reconnaissance of the study area. This section is not intended to replace the need for an ISA or Phase I Environmental Site Assessment or to satisfy the due diligence requirements for the study area. Table 5.4 summarizes the sites located within or adjacent to the study area. Petroleum contaminated soil and groundwater may be present in the vicinity of the Belleview Avenue/ Quebec Street and Belleview Avenue/Ulster Street intersections due to sites with leaking underground storage tanks (LUST) in the vicinity of these intersections. Table 5.4 Hazardous Material Sites

Site Name Address Potential Impact Description Conoco 7295 E. Three 10,000-gallon underground storage tanks (UST) for Phillips Belleview unleaded gasoline and diesel currently in use at the site. One Avenue liquefied petroleum gas (LPG) above ground storage tank (AST), one 500-gallon UST for used oil, one 4,000-gallon UST for gasoline, one 6,000-gallon UST for gasoline, and one 10,000- gallon UST for gasoline were permanently closed at the site. A leaking underground storage tank (LUST) was reported in 1990. A no further action letter was sent on March 17, 1992. Residual petroleum contaminated soil and groundwater may be present in the area of Belleview Avenue/Quebec Street. Diamond 7296 E. One 10,000-gallon UST for unleaded gasoline, one 12,000-gallon Shamrock Belleview UST for unleaded gasoline, one 8,000-gallon UST for unleaded Avenue gasoline, and one 8,000-gallon UST for diesel currently in use at the site. Two 6,000-gallon USTs for gasoline, one 8,000-gallon UST for gasoline, one 10,000-gallon UST for gasoline, and one 6,000-gallon UST for diesel were permanently closed at the site. A LUST was reported in 1990. A Corrective Action Plan (CAP) is being implemented. Known petroleum contaminated soil and groundwater are present in the area of Belleview Avenue/Quebec Street.

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Table 5.4 Hazardous Material Sites

Site Name Address Potential Impact Description Amoco 7300 E. Three 12,000-gallon USTs for gasoline, one 8,000-gallon UST for Belleview gasoline, one 10,000-gallon UST for gasoline, and one 550-gallon Avenue UST for used oil were permanently closed at the site. A LUST was reported in 1987. A no further action letter was sent on December 6, 2006. Residual petroleum contaminated soil and groundwater may be present in the area of Belleview Avenue/ Quebec Street. Tech Center 7699 E. Two 10,000-gallon USTs for unleaded gasoline, one 8,000-gallon Sinclair Belleview UST for unleaded gasoline, two 560-gallon USTs for used oil, one Avenue 1,000-gallon AST for racing fuel, one 1,000 LPG AST, and one 500-gallon LPG AST were permanently closed at the site. A LUST was reported in 1990. A no further action letter was sent on March 11, 2010. Residual petroleum contaminated soil and groundwater may be present in the area of Belleview Avenue/ Ulster Street. Tech Center 7701 E. One 10,000-gallon UST for gasoline, two 6,000-gallon USTs for Phillips 66 Belleview gasoline, one 500-gallon UST for an unknown substance, one Avenue 900-gallon AST for diesel, and two 1,000-gallon LPG ASTs were permanently closed at the site. A LUST was reported in 1995. A no further action letter was sent on August 5, 2011. Residual petroleum contaminated soil and groundwater may be present in the area of Belleview Avenue/ Ulster Street. Life Partners 7887 E. One 500-gallon UST for diesel is currently in use at the site. Group Belleview A LUST was reported in 1995. A no further action letter was sent Avenue on August 5, 1997. Residual petroleum contaminated soil and groundwater may be present in the area of Belleview Avenue/ Ulster Street.

5.5 Noise A traffic noise analysis is often required for CDOT and CDOT-administered road improvement projects to comply with the Council on Environmental Quality regulations (40 Code of Federal Regulations [CFR] 1500) and to comply with FHWA NEPA regulations under 23 CFR 772. Additionally, the analyses support compliance with CDOT’s Environmental Stewardship Guide and ensure the statewide transportation system is constructed and maintained in an environmentally responsible, sustainable, and compliant manner. A preliminary evaluation for traffic noise was performed to assess the potential for future traffic noise concerns for the project corridor. The noise evaluation consisted of a review of land uses adjacent to Belleview Avenue in the study corridor. Current and future traffic noise levels will be considered in detail in subsequent NEPA processes.

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Noise impacts from traffic are assessed by comparing the traffic noise levels to CDOT's Noise Abatement Criteria (NAC) (Table 5.5). The CDOT NAC for residences (Category B) and other sensitive receptors (Category C) is an exterior equivalent sound level (Leq) of 66 A-scale decibels (dBA). For sensitive commercial areas (Category E) the NAC is an Leq of 71 dBA. Under CDOT guidelines (CDOT 2011), equaling or exceeding the NAC or having traffic noise levels increase by 10 dBA or more are noise impacts and either would trigger an investigation of noise mitigation measures. Table 5.5 CDOT Noise Abatement Criteria

Land Use CDOT NAC Description of Land Use Category Category (Leq) Tracts of land in which serenity and quiet are of extraordinary 56 dBA significance and serve an important public need and where A (Exterior) the preservation of those qualities is to continue to serve its intended purpose. 66 dBA B Residential (Exterior) Active sport areas, amphitheaters, auditoriums, campgrounds, cemeteries, day care centers, hospitals, 66 dBA libraries, medical facilities, places of worship, public meeting C (Exterior) rooms, public or non-profit institutional structures, radio studios, recording studios, schools, Section 4(f) sites, trails, trail crossings, open space, and television studios Auditoriums, day care centers, hospitals, libraries, medical facilities, places of worship, public meeting rooms, public or D 51 (Interior) non-profit institutional structures, radio studios, recording studios, schools and television studios Hotels, motels, offices, restaurants, bars, and other 71 dBA E developed lands, properties or activities not included in (Exterior) A-D or F Agriculture, airports, bus yards, emergency services, industrial, logging, maintenance facilities, manufacturing, F NA mining, rail yards, retail facilities, ship yards, utilities (water resources, water treatment, electrical), and warehousing G NA Undeveloped lands that are not permitted for development Source: CDOT, 2011 The current land uses in the study area corridor are illustrated on Figure 5.2. Most of the study area is Land Use Category E (sensitive commercial), F, or G. Categories F and G are not concerns for traffic noise and relatively few of the Category E properties have exterior areas of frequent human use that would be a concern from traffic noise. Consequently, most of the study area would not be subject to traffic noise impacts. The few exceptions in the commercial areas would be exterior patios for dining associated with restaurants east of I-25.

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Figure 5.2 FELSBURG Noise Issues HOLT & ULLEVIG NORTH Belleview Avenue Corridor Study, 12-069, 8/31/15 Existing Transportation Conditions Draft Report

There are relatively few Category B (residences) or C (parks) properties, which typically are the greatest concerns for traffic noise impacts, in the study area (Figure 5.2). These properties are mostly in the southwest quadrant of the study area; however, there are a few residential and park areas east of I-25 as well. From a traffic noise perspective, the project alternatives should avoid or minimize any addition of traffic noise to these areas to prevent impacts from traffic noise. If noise impacts are identified from the project at any property, appropriate mitigation measures will need to be evaluated according to CDOT guidelines (CDOT 2011). A strategy to avoid traffic noise impacts is to separate busy roads from sensitive receivers. However, the separation distance usually cannot be changed in developed areas such as the study area, so other solutions must be considered. Some other noise reduction considerations that may avoid or minimize noise impacts include:  Vertical alignment (e.g., road cuts or fills)  Speed restrictions  Lane closures  Limited truck routes  Buffer zones  Pavement type  Barriers Often, there are limited opportunities within a project to use any of these measures. Some measures may conflict with the basic purposes of the road improvements and not be viable. Other measures may require more space than is available in the study area. Of these measures, noise barriers typically have the widest applicability in traffic noise abatement. The typical next step would be to complete a noise analysis that includes the evaluation of existing and future noise levels. The primary goal of the analysis would be to determine if there will be traffic noise impacts within the study area from the proposed improvements. If there will be impacted areas, CDOT policy requires that noise mitigation for the impacted areas be evaluated. The mitigation actions could include traffic management, horizontal/vertical alignment changes, buffer zones, building insulation, or noise barriers. The potential noise mitigation actions would be evaluated for feasibility and reasonableness according to CDOT guidelines (CDOT 2011). To be feasible, the action must be permanent, "buildable," and reduce noise by at least 5 dBA. To be reasonable, the action must meet several performance criteria specified in the CDOT guidance. Noise mitigation actions that are found to be both feasible and reasonable would be identified and recommended for implementation as part of the project. 5.6 Cultural Resources Historical resources are buildings, structures, districts (groups of buildings or structures), sites, and objects meeting the minimum age criterion of 45 years. Typically 50 years is used as an age threshold; however, a 45-year-threshold is often used in transportation projects to account for their protracted schedules including environmental clearance, design, and obtaining funding. Archaeological resources are the physical traces of past human activity and may be either

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associated with prehistoric Native American or later Euro-American use. Non-renewable historical and archaeological resources warrant protection if they are listed on or determined to be eligible for inclusion on NRHP. In July 2012, FHU conducted a records search and reconnaissance (“windshield”) survey of the study area. A review of the Colorado Historical Society (CHS)/Office of Archaeology and Historic Preservation COMPASS database reveals that one previously recorded cultural resource does occur within the study area; however, it does not qualify for eligibility in NRHP.  5AH.1565.1 – Belleview Avenue Overpass Bridge - Officially Not Eligible, 4/20/1999 Furthermore, property records from both the Arapahoe County and Denver County Assessor’s Offices reveal that all but one property along Belleview Avenue within the study area are less than 45 years old and therefore are not eligible for inclusion in NRHP. The one exception includes the Diamond Shamrock service station located at 7296 East Belleview Avenue, which was constructed in 1968. However, a field determination concludes that the historic integrity of the building has been compromised with a recent renovation and therefore disqualifies it from eligibility in NRHP. No archaeological sites have been identified to date within the study area. All properties adjacent to the study area are presented in Table 5.6.

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Table 5.6 Developed Properties within the Study Area Assessor's Site Type/ Address Construction NRHP Eligibility Name Date(s) 6501 E. Belleview Ave. Office 1996 Field Not Eligible 6900 E. Belleview Ave. Office 1979 Field Not Eligible 7000 E. Belleview Ave. Office 1980 Field Not Eligible 7100 E. Belleview Ave. Office 1981 Field Not Eligible 7295 E. Belleview Ave. Service Station 1991 Field Not Eligible 7296 E. Belleview Ave. Service Station 1968 Field Not Eligible 7300 E. Belleview Ave. Automotive Shop 1994 Field Not Eligible 5090 S. Quebec Street Restaurant 1989 Field Not Eligible 5105 DTC Parkway Office 1983 Field Not Eligible 5075 S. Syracuse Street Office 2005 & 2009 Field Not Eligible 7700 E. Belleview Ave. Bank 1975 Field Not Eligible 7730 E. Belleview Ave. Office 1976 Field Not Eligible 7795 E. Belleview Ave. Commercial/Retail 1999 Field Not Eligible 7887 E. Belleview Ave. Office 2006 Field Not Eligible 7901 E. Belleview Ave. Office 1980 Field Not Eligible 8000 E. Belleview Ave. Retail/Restaurant 1999 & 2000 Field Not Eligible 8095 E. Belleview Ave. Bank 1982 Field Not Eligible 8101 E. Belleview Ave. Commercial/Retail 1978 Field Not Eligible 8200 E. Belleview Ave. Commercial/Retail 1981 Field Not Eligible 8300 E. Belleview Ave. Hotel 1997 Field Not Eligible 8310 E. Belleview Ave. Restaurant 1996 Field Not Eligible 8351 E. Belleview Ave. Gym 1998 Field Not Eligible 8401 E. Belleview Ave. Office 1983 Field Not Eligible 8480 E. Belleview Ave. Restaurant 2000 Field Not Eligible 8490 E. Belleview Ave. Office 1998 Field Not Eligible 5117 S. Yosemite Street Commercial/Retail 1997 Field Not Eligible Residential 8500-8760 E. Bellewood Pl. 1970-1971 Field Not Eligible (Individual Homes) 8790 E. Bellewood Pl. Residential 2001 Field Not Eligible 5062 S. Xenia St. Residential 1970 Field Not Eligible

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5.7 Parks and Recreational Trails The presence and accessibility of community parks, recreational trails, and open space is an important consideration within the study area. These open space areas and interconnected trails protect natural values and provide user diversity opportunities. There are three parks identified near the Belleview Avenue/I-25/DTC Boulevard corridor: Wallace Park (CDOT 1999) and two un-named park areas. Near the Monaco Street/Belleview/ I-25 corridor are three parks, two open spaces areas, and several trails. The locations of these facilities are shown on Figure 5.1. George Wallace Park – (13.35 hectares [33 acres]) Within the Belleview Avenue/I-25/ DTC Boulevard corridor is the George Wallace Park, owned and operated by the City and County of Denver and is bordered on the:  West side by DTC Boulevard  South side by Belleview This park is named after George M. Wallace, who was instrumental in establishing the Arapahoe Avenue County Airport later renamed Centennial Airport.  East side by South Wabash Street  North side by the frontage road frontage road for I-225 The facilities at Wallace Park include a playground, picnic tables, and a series of bike paths that run through the park, including the Goldsmith Gulch Trail, which stretches along Goldsmith Gulch that runs the length of the park. Goldsmith Metropolitan District operates and maintains two un-named park areas located on both the east and west corners of Belleview Avenue and DTC Boulevard adjacent to Wallace Park. Each park has a water feature, several walking paths, benches, and life-sized bronze sculptures from Located at Belleview Ave. and DTC Blvd. Frisbee in artist Don Budy. Goldsmith Gulch the Park is from artist Don Budy, a retired teacher. runs along the park on the southeast corner of the intersection. The park on the southwest corner of the intersection includes a small amphitheater. Owned and operated by Greenwood Village (Greenwood Village Parks and Open Space 2012), the following parks, open space, and trails identified near the Monaco Street/Belleview Avenue/ I-25 corridor are:

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Monaco Park – 6500 East Belleview Avenue – (4.17 acres) This park is a natural park area with a detention pond for Prentice Gulch. The park is also a link in the Village’s trail system and offers a hike/bike trail which winds through natural vegetation. The picnic table and sitting area at Monaco Park entices park and trail users to stop and enjoy the natural area just south of Belleview Avenue. Monaco/Crestline Park – Monaco Street and East Crestline Avenue – (0.7 acre) Monaco/Crestline Park is a small greenbelt area directly west of Monaco Street and overlooks a scenic garden and wetlands area. It provides a nice resting area with a bench for trail users making their way from Cattail Park, east of Holly Street, or trail users headed south on Monaco Street from Monaco Park Running Fox Park – 5290 South Quebec Street (7.7 acres) Running Fox Park provides recreational opportunities for both park and trail users. This park is just one scenic leg of the Village’s Trail System, lined with a variety of trees and shrubs. Running Fox Park is also home to an abstract steel structure, The Cusp of Life, which has been added to the Village Public Art Program. There also is a wetland pond and several benches. Public Service Company Property – South of Belleview Avenue and east of Monaco Park (9.2 acres) This Public Service Company Property was purchased by Greenwood Village in 2003 and is now an open space area, preventing potential development in the area. It is a wetland and open space area home to diverse wildlife. The open space also provides a buffer between the Greenwood Hills neighborhood and adjacent commercial properties. Bowman Property – (4.7 acres) The Bowman Property was purchased by Greenwood Village in 1997 for open space purposes. The open space lies south of the Public Service Company open space property and Monaco Park. The parcel is not publicly accessible. Trails Arapahoe County Bikeways – on Belleview Avenue from Quebec Street to past Monaco Street, and on side streets south along Monaco Street, Quebec Street, and Berry Avenue. Greenwood Village Trails – along Belleview Avenue from Quebec Street to past Monaco Greenwood Village has 40 miles Street, and south into neighborhood (horse, within its community trail system. bike, walking trails). Monaco/Crestline Trail – accessible at Crestline Avenue on the east side of Monaco Street in the Greenwood Hills neighborhood. The trail travels easterly and then bends to the north providing access to Running Fox Park and is part of the Greenwood Village Trail system. The City of Greenwood Village requires that any potential change in the use of open space land be subject to a city-wide ballot measure. City voters decide whether dedicated open space land can be used alternatively. This includes any changes that would convert open space to public right-of-way. As such, transportation improvements that would require land from open space areas would be subject to a popular vote.

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Future projects could require an additional evaluation for parks and recreational resources, including a Section 4(f) evaluation and Section 6(f) evaluation, which are described below. Additionally, the park boundaries and amenities for the resources identified on Figure 5.1 should be verified during any future project-level analysis. Section 4(f) Evaluation Section 4(f) resources are protected under the U.S. Department of Transportation Act (DOT Act), as defined in 23 CFR 774 and include publicly-owned parks, recreational areas, wildlife and waterfowl refuges, or public and private historical sites. If any future project with federal funding involves the use of a Section 4(f) property, then a Section 4(f) evaluation would be required for that particular resource. Section 6(f) Evaluation Section 6(f) resources include land or facilities that have been purchased or improved with Land and Water Conservation Funds (LWCF). Section 6(f) would apply to all transportation projects involving possible conversions of any Section 6(f) land or facility and would need to be considered for any projects with CDOT involvement (including oversight).

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6.0 REFERENCES Arapahoe County Assessor’s online real property database, searchable by address or parcel number. Website: http://gis.co.arapahoe.co.us/arapamaplite/ Accessed July 2012.

Brown and Caldwell. 1998. Modified Environmental Site Assessment.

Brown and Caldwell. 2000. Phase II Environmental Site Assessment.

COMPASS: Colorado’s On-Line Cultural Resource Database. Website: http://oahp.historycolorado.org/compass/ Accessed July 2012.

Colorado Department of Transportation (CDOT). December 1999. Southeast Corridor Final Environmental Impact Statement.

CDOT. March 2000. Southeast Corridor Record of Decision.

Colorado Department of Public Health and Environment (CDPHE). March 2012. Water Quality Control Commission, Colorado's Section 303(D) List of Impaired Waters and Monitoring and Evaluation List.

Denver County Assessor’s online real property database, searchable by address or parcel number. Website: http://www.denvergov.org/realproperty.asp Accessed July 2012.

Greenwood Village Parks and Open Space. 2012. Greenwood Village Neighborhood Parks/Playgrounds. Monaco/Crestline Park. Website: http://greenwoodvillage.com/index.aspx?NID=329 Accessed July 2012.

Greenwood Village Parks and Open Space. 2012. Greenwood Village Neighborhood Parks/Playgrounds. Monaco Park. Website: http://greenwoodvillage.com/index.aspx?NID=330 Accessed July 2012.

Greenwood Village Parks and Open Space. 2012. Greenwood Village Neighborhood Parks/Playgrounds. Running Fox Park. Website: http://greenwoodvillage.com/index.aspx?NID=332 Accessed July 2012.

Greenwood Village Parks and Open Space. 2012. Greenwood Village Open Space. Bowman Property. Website: http://greenwoodvillage.com/index.aspx?NID=356 Accessed July 2012.

Greenwood Village Parks and Open Space. 2012. Greenwood Village Open Space. Public Service Property. Website: http://greenwoodvillage.com/index.aspx?NID=359 Accessed July 2012.

Greenwood Village Parks and Open Space. 2012. Greenwood Village Open Space. Monaco/Crestline Equestrian Trail. Website: http://greenwoodvillage.com/index.aspx?NID=346 Accessed July 2012.

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Greenwood Village Parks and Open Space. 2012. Greenwood Village Park and Trail Map. Website:http://co-greenwoodvillage.civicplus.com/DocumentCenter/Home/View/69 Accessed July 2012.

Natural Diversity Information Source (NDIS). 2012. Website: http://ndis.nrel.colostate.edu/conservationcnty.asp?cnty=031 Accessed July 2012.

U.S. Army Corps of Engineers (USACE). 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Great Plans Region (Version 2.0) ed. J.S. Wakeley, R.W. Lichvar, and C.V. Noble. ERDC/EL TR-10-1. Vicksburg, MS: U.S. Army Engineer Research and Development Center.

United States Fish & Wildlife Service (USFWS). 2012. Information, Planning, and Conservation System (IPaC) internet mapping tool website: http://ecos.fws.gov/ipac/wizard/trustResourceList!prepare.action Accessed July 2012.

Venomous Reptiles Organization. 2010. The Midget Faded Rattlesnake. Website: http://www.venomousreptiles.org/articles/213 Accessed July 2012.

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Appendix A. Traffic Count Data

Appendix A Existing Transportation Conditions Draft Report

Appendix B. Level of Service Calculations

Appendix B Existing Transportation Conditions Draft Report

Appendix C. Crash Data

Appendix C