Chapter 24: Response to Comments on the DEIS1 24-1 INTRODUCTION This chapter summarizes and responds to comments on the Draft Environmental Impact Statement (DEIS) for the Tappan Zee Hudson River Crossing Project. The Federal Highway Administration, acting as federal lead agency, and the New York State Department of Transportation (NYSDOT) and New York State Thruway Authority (NYSTA), acting as joint lead agencies signed the cover sheet of the DEIS on January 18, 2012, and the document was made publicly available. A notice of its availability was published in the Federal Register on January 27, 2012, which established the public comment period on the document. The public comment period was initially scheduled to conclude on March 15, 2012, but in response to public comments, FHWA, NYSDOT, and NYSTA extended the public comment period to March 30, 2012. Two public hearings were held during the public comment period. The first was on February 28, 2012 at the Palisades Mall in West Nyack, New York, and the second was on March 1, 2012 at the Westchester Marriott in Tarrytown, New York. A court reporter was on hand to accept oral comments on the DEIS at the hearings. Written comments (email and letters) were accepted throughout the public comment period. Written comments received after March 30, 2012 were also accepted. All substantive comments on the DEIS have been responded to in this Final Environmental Impact Statement (FEIS). Section 2 contains a summary of these relevant comments and a response to each. These summaries convey the substance of the comments made, but do not necessarily quote the comments verbatim. Comments are organized by subject matter and generally parallel the chapter structure of the DEIS. Where more than one commenter expressed similar views, those comments have been grouped and addressed together. Some commenters did not make specific comments related to the proposed approach or methodology for the impact assessments. Others suggested editorial changes. Where relevant and appropriate these edits, as well as other substantive changes to the DEIS, have been incorporated into this FEIS. Section 3 lists the public agencies, elected officials, organizations, and individuals that provided relevant comments on the DEIS. Volume III of this FEIS contains the written comments received on the DEIS, including transcripts of the public hearings. 1 This chapter is new to the FEIS. 24-1 Tappan Zee Hudson River Crossing Project Environmental Impact Statement 24-2 RESPONSES TO COMMENTS ON THE DEIS 24-2-1 CHAPTER 1: PURPOSE AND NEED C 1-1: Several commenters stated that the project should consider mobility, congestion, and safety improvements along the 30-mile corridor of Interstate 87/287. The original project considered regional transportation needs within the I- 287 corridor to alleviate traffic congestion and improve safety between Port Chester and Suffern. If the original purpose of the project was to improve regional infrastructure, then it would follow that a plan that does not include mass transit, or alternatives to low-occupancy vehicles, would fall short of recognizing the future needs of the region. On October 12, 2011, both the Federal Highway Administration (FHWA) and the Federal Transit Administration (FTA) rescinded the Notice of Intent for the Tappan Zee Bridge/I-287 Corridor Project and issued instead a Notice of Intent for the Tappan Zee Hudson River Crossing Project. If the proposed action is now limited to maintaining the “link in the regional and national transportation network,” then it fails to consider the project’s original purposes–improved infrastructure, reduced congestion, and safety. While maintaining the Tappan Zee Bridge link across the Hudson River is surely of critical importance for regional transportation, the project must contemplate the need for smart growth and the environmental review must thoroughly analyze the project’s impacts on the entire I-287 Corridor and the region. R 1-1: Many planning studies have identified the replacement of the Tappan Zee Bridge as a critical need for the Lower Hudson Valley. The Tappan Zee Hudson River Crossing Project addresses this need based on the structural, operational and safety, security, and mobility deficiencies of the existing Tappan Zee Bridge. The replacement of the Tappan Zee Bridge is considered a high-priority project by the federal and state government and is being advanced at this time. The proposed replacement of the Tappan Zee Bridge would not preclude other initiatives to enhance mobility along the Interstate 87/287 corridor should these projects be advanced independently at some point in the future. C 1-2: Several commenters expressed concern as to whether a new bridge is actually needed. R 1-2: As identified in the DEIS, the existing bridge does not meet current standards for its design or traffic operations. The Tappan Zee Hudson River Crossing Project would address the structural, operational, mobility, safety, and security limitations and deficiencies of the existing Tappan Zee Bridge. C 1-3: The health and beauty of the Hudson River are more important to me than cars. Leave it the way it is. We must enter a new era where growth is replaced with sustainability. 24-2 Chapter 24: Response to Comments on the DEIS R 1-3: The Tappan Zee Hudson River crossing is an important route for both passenger vehicles and freight. It is the only interstate highway crossing of the Hudson River for the 48-mile stretch between the George Washington Bridge (Interstate 95) and the Newburgh-Beacon Bridge (Interstate 84). It is a vital link between the population and employment centers of Rockland and Westchester Counties, is a major route for freight movement, and is an emergency evacuation route. The absence of a highway crossing at this location would extensive impacts on local, regional, and national mobility, economy, and security. C 1-4: The DEIS does not actually say how or why increased lane size will decrease accident rates. R 1-4: The American Association of State Highway Transportation Officials (AASHTO) identifies 12 feet as its standard lane width for urban, interstate highways. At 12 feet or greater, drivers can best achieve interstate highway speed with safe buffer for passing vehicles and a comfortable distance for minor fluctuations in vehicle control. Standard lane widths are one of many considerations to improve safety of the Tappan Zee Hudson River crossing. C 1-5: The document should also reference recent and projected growth in Orange County. R 1-5: Future traffic volumes on the bridge are projected using the New York Metropolitan Transportation Council (NYMTC) regional forecasts, which include the entire commuter shed of the Tappan Zee Bridge, including Orange County. The growth rates cited in Chapter 1, “Purpose and Need,” are illustrative of trends in the immediate vicinity of the Tappan Zee Bridge and are not intended to discount growth in other parts of the New York Metropolitan region. C 1-6: In section 1-5, one of the clearly defined "Deficiencies" of the existing bridge is "Mobility Deficiency." However, not one of the Goals or Objectives addresses mobility deficiencies. R 1-6: The mobility deficiencies of the existing bridge relate to its non-standard features with respect to traffic operations, and its difficulties in terms of safety and timely emergency response. The goals and objectives for the project address these deficiencies. Furthermore, the Replacement Bridge Alternative would include a shared-use path, which would improve trans- Hudson mobility for bicyclists and pedestrians. C 1-7: Population data used in the DEIS should be corrected to reflect that Rockland County has grown from 89,000 in 1950 to 311,000 in 2010 (not 299,000) and that the 2010 Westchester County population was 949,113 (not 962,000). It should also be noted that the 2010-2047 population and employment projections for Rockland County obtained from NYMTC are not consistent with projections commissioned by the County. Further, NYMTC has provided updated population and employment projections for 2040 based on the 2010 census. The EIS should reflect these updates. 24-3 Tappan Zee Hudson River Crossing Project Environmental Impact Statement R 1-7: Project development for federally-sponsored transportation planning projects requires consistency with population and employment using forecasts by the local Metropolitan Planning Organization, NYMTC in this case. Therefore, NYMTC data are cited in the DEIS. The DEIS cites projections used for the modeling of traffic, which were based on socioeconomic data published prior to September 2011. The revised socioeconomic data released by NYMTC in September 2011 included projected 2040 population and employment figures that for Rockland and Westchester were roughly 1 to 5 percent higher than prior NYMTC estimates. From a transportation perspective, the full impact of these types of changes on travel patterns and volumes in the future analysis years would likely be very small given the size of these changes and the various factors that drive trip making. There are myriad factors that affect trip making beyond the number of residents or jobs. However, when considered cumulatively, a small change in these projections would have a limited effect on the 2017 and 2047 travel volumes and patterns predicted in the DEIS. C 1-8: Several commenters stated that the study area should be expanded, citing the following reasons: The bridge would be able to accommodate transit and therefore must consider the more widespread effects from future transit; Haverstraw Bay and the Piermont Marsh are identified as a “Significant Coastal Fish and Wildlife Habitat,” which is in proximity to the study area. Impacts on local and migrating species must be assessed; There are roadway improvements that are needed in proximity to the study area to better address traffic conditions and safety. R 1-8: The Tappan Zee Hudson River Crossing Project is examining alternatives to address the deficiencies of the existing Tappan Zee Bridge and is not a corridor study.