--The Turquoise Trail-- Citizens Advisory Committee Letter
For the Record
to New Mexico's Transportation Department
"No net loss of scenic values' as a criterion for design success" ?
For the purposes of the public record, the statement below is a reflection and summation of the feelings of members of the CAC on outstanding issues through January 23--the last formal public hearing/meeting required within the framework of the Environmental Assessment (EA) process. Since the hearing, the Department has committed to continuing to work with citizens in attempting to address many of the issues expressed in this CAC statement of record. We appreciate this commitment and are genuinely hopeful that the final design, still in process, will result in success. We would encourage citizens to express their opinions to the Department, as well as to members of the CAC, and to attend expected follow-up meetings with the Department and Design Team.
--RL, Jan. 31, 02
Letter from CAC
February 1st, 2002
[From] NM 14 Citizens Advisory Committee
P.O. Box 245
Cerrillos, NM 87010
[To] Parsons Brinckerhoff
5801 Osuna Road NE
Albuquerque, NM 87109
Re: NM 14 Project--Comments from NM 14 Citizens Advisory Committee for the Record
NM Project No. TPM-BR-0014(9)29, CN 1285 & TPM-BR-0014(10)32, CN 2516
Although the current plans are clearly an improvement over the original proposals for this project, especially as regard following the existing alignment and minimizing at least some lane widths, the undersigned CAC representatives feel that the current reconstruction design has shortcomings in safety and scenic features and is not worthy of an internationally recognized National Scenic Byway, a byway that has been likewise memorialized by the NM State Legislature mandating that the NM transportation department (NMSHTD) "exercise care and sensitive planning in carrying out the reconstruction...." This letter of record comments on significant issues, some old and familiar, some new and recent.
Below we comment upon the following issues: the safety of the lane width though mountainous terrain, new regulations, construction supervision, guardrail (treatment, placement and implications of design exceptions), rip-rap, tapers, clear zones and guidelines, recycled glass in base course, industrial use of the National Scenic Byway, and the method or process of developing a design.
In our judgment the current design would be a liability to the communities as well as the State. The current design we believe will not result in a significantly safer road and it does not meet the design goal of "'no net loss of scenic values' as a criterion for design success" as proposed at a "partnering" meeting of March 2001.
There were statements at the hearing (Jan. 23, 2002) and also statements in the Department's previous writing (Jan. 16) that the Department will continue to explore options on various issues. These statements are appreciated by the CAC and commendable. These are not, however, minor issues "because a few people have concerns," as Ted Garcia was quoted in the New Mexican. If consideration merely results in rejection of community concerns, as has happened too often without explanation, the design as currently presented will fall far short of being an example of context- and community-sensitive design. If continued exploration results in resolution of these issues, the design may become acceptable.
LANE WIDTH SAFETY ISSUE: As demonstrated previously (and partly touched upon in the above paragraph), we have documented studies that throw into question the safety of expanding to 12' lanes. The off-tracking rationale was first used during a time when a gravel mining operation was trucking illegally on the Scenic Byway. Again, the CAC believes the Department's current plan of 12' lane widening through mountainous terrain would build in an induced-speed for both cars and trucks. The CAC has offered compromises that might help reduce this affect.
The concept of striping a center "visual median" so that a 12' driving space appears as 11' lanes we believe may be part of a solution to keep visual and environmental effects of widening to a minimum.
It is our view that the Department's Jan. 16th response on this issue has again no substance and is without professional back-up. The department has shown no standards that require these dimensions for this type of road with these traffic volumes through this terrain. Further explorations towards meaningful resolution of this issue, such as those suggested by the Department's & citizen's consultant, should be entertained. Lane widening is only one of several widening elements of the present design, which cumulatively would eliminate the intimate scenic, as well as traffic-calming qualities of a truly contextual design. Lane width must be considered together with shoulder and taper widening, and with clear zone requirements, to keep the total width of construction and clearing to the absolute minimum possible.
NEW REGULATIONS: Nationally, rules are changing for more flexibility in highway design. There are new publications being released (or soon will be) by progressive engineers. These may be to the benefit of the Turquoise Trail. Advance copies should be obtained (as the NMSHTD pledged at the hearing to attempt), and the final design coordinated with the more flexible standards:
Item: The Federal Highway Administration is about to issue a Scenic Byways Design Guide. It is currently in printing.
Item: AASHTO is preparing a "Context Sensitive Design" manual.
Item: The 2001 edition of the AASHTO "Green Book" was issued late in 2001. There are substantial changes from the previous edition.
Item: The UMTCD (Uniform Manual of Traffic Control Devices) also has a brand new 2001 edition, with substantial changes including signage and warrants for traffic calming.
The CAC thanks the Department for pledging to attempt to acquire an advance copy of the Scenic Byways Design Guide.
CONSTRUCTION SUPERVISION: The Department's refusal to set financial penalties or incentives for site and vegetation protection is of serious concern, and flies in the face of industry-standard best practices in construction management. The CAC strongly suggests that "liquidated damages" or similar provisions are needed to ensure against contractor corner-cutting where protection of existing features is concerned. The CAC also suggests that Sites SW be given a role in the construction supervision, to insure that the landscape plantings are actually installed as specified in the plans and that roadside vegetation is not unnecessarily removed. This is particularly important because of the scenic value of the road and the Department's unacceptable refusal to impose penalties for "out of bounds" disturbance. The Department's environmental oversight contractor presumably is not qualified to perform these functions. Perhaps Sites SW could be a subcontractor to the environmental oversight contractor. We understand that the Department has ways of writing the bid documents so that specialists pre-approved by the Department must be used.
GUARDRAIL: Concerning the proposed guardrail treatment and placement, it is a good step that the Department will continue to explore the feasibility of "stable surface alternatives" for use behind the guardrail, and investigate options in lieu of using a bituminous curb.
Although maintenance and longevity of a road are an important consideration, inventive means to accomplish this must be sought for this road, otherwise the design would revert into outdated over-building paradigms.
We understand the placement of the rail at the edge of the shoulder is under review for a design exception. The implications of a refusal of this exception might suggest a design that adds considerable width to the roadway wherever there are guardrails. In the event that the exception is NOT granted, the CAC recommends that if the guardrails are to be set back, that there shall be no asphalt used beyond the 4 foot shoulders, and that other crash-tested guardrail designs be explored that eliminate any extra (2 foot) dimensions behind the rails. Again the CAC wishes to emphasize that asphalt, colored or not, would diminish the scenic qualities by "framing" the rails predominantly into the picture.
If the road was viewed location by location, if the drainages, slopes of the road were really studied, there might be large areas where curbing would not be needed; instead, the runoff could help in the establishment of vegetative solutions to erosion problems. Places of convergence of run-off could be identified and dealt with.
The CAC wishes to thank the Department in its acceptance of using cor-ten steel type of railings.
RIP-RAP: An excessive amount of highly visible rip-rap remains in the design, despite many discussions of alternatives, and the removal of rundowns. The department's response, that rip-rap channels will be covered with soil and seeded, is not stated in any contract drawings or documents made available to the CAC, and we are concerned that the contractor will "overlook" this requirement as a way of cutting costs. The huge rip-rap gabions at Rogersville road and elsewhere need to be redesigned to incorporate terraces and planting. Plantings will serve to stabilize the gabions (a principle well known and documented in the practice of 'bio-engineering,' today's most advanced method of erosion control), and also will reduce the visual impact of walls which appear to be unbroken expanses 400 feet long and a dozen or more feet high.
TAPERS: The CAC rejects the maintenance-driven design of a taper that includes visible paving and suggests instead that duffing be reinstated per the department's earlier verbal commitment to this process. The concern that duffing will trap water which gets through traps in the driving surface is drastically exaggerated; the objection to the cost of duffing does not consider that seeding the tapers will be equally costly.
The Department's current proposed asphalt taper is no compromise to an alternative (3) that was strongly advocated by a community that desired a shoulder that was part grass. CAC considers the recent deletion of duffing to be a promise broken, serving only a false "value-engineering."
Contrary to what the Design Team had agreed to at CAC meetings, the typical in the PS&E Submittal does not show that the taper VARIES.
CLEAR ZONE AND GUIDELINES: The clear zone should be kept to a minimum for two reasons: traffic-calming and safety-improving effects of visual narrowing by roadside vegetation, which is well documented; and the more general environmental and scenic benefit of preserving as much existing vegetation as possible. Guidelines exist that could be used to the advantage of this scenic road:
The AASHTO Roadside Design Guide is largely based on geometry, mathematic formulae, EXCEPT Chapter 10: "Roadside Safety in Urban and/or Restricted Environments". See page 32 of the Turquoise Trail Alternative Design Plan, by Donal Simpson, for more detail and possible application to NM 14.
Also pp. 35-37 of the Alternative Design Plan are apropos. For low-speed rural collectors (40 mph or less design speed), AASHTO recommends a minimum clear zone of 10 ft. This should be reflected in the design plans of NM 14 rather than using the requirements for higher speed rural collectors.
CONSIDERATION OF RECYCLED GLASS IN THE BASE COURSE: As we had requested consideration of recycled glass in base course, and as the Department response (dated Jan. 16, 2002) only dealt with recycled materials in asphalt, we again reiterate that serious consideration should be given to the use of recycled glass in at least the base course of the new road. The community has been directly and negatively affected by gravel mining for many years, and is deeply concerned that work on NM 14 not lead to further mining if alternatives can be found. Glass, recycled concrete, and other alternatives do exist and have national track records as stable materials for base course and asphalt aggregate use.
The State Materials Bureau Chief, John Tenison, has responded favorably to the possibility of using recycled glass in base course:
"As for the use of glass in base course materials I see no problem with their use. However, specifications will need to be developed and we will need to address the issue of cost since these materials more than likely cost more to manufacture and place than conventional "non-glass modified" base course materials in that where will these additional funds be found due to the Departments many other funding needs throughout the State." --John Tenison, 26 Oct. 2001
Specifications for the use of the material would have to be developed, but that is a one-time cost that could be spread over many highway projects in the future. The material will likely cost more compared to the mined alternative, if only the direct cost to the Department is considered. We would appreciate an analysis of the total costs, including the avoided costs of placing glass in landfills and the costs to surrounding communities from mining. If the time frame for the first part of the project does not allow for completion of these items, they certainly can be accomplished before the second increment of the project.
INDUSTRIAL USE VERSUS THE NATIONAL SCENIC BYWAY: At the hearing it was suggested by a Department representative, that the widening of the lanes between Madrid and Cerrillos was in part warranted in the event of the Byway being turned into an industrial use road for gravel mining haul trucks. The CAC strongly protests designing the road under such an industrial forecast. The CAC requests that the Department instead recognize their own truck traffic projections and the low expected truck traffic percentage of 5.3%. The likelihood of many gravel haul trucks using the NM 14 project area grows more unlikely as the area evolves a more sustainable economic tourist paradigm and becomes more residential.
The idea put forth by the Department that NM 14 is a "regional" highway and must be designed as a truck route because it connects 2 county seats, we believe is a fallacy. The only county seat on NM-14 is Santa Fe; Tijeras, Madrid, Cedar Crest, and Cerrillos are not county seats; the appropriate connection between Albuquerque and Santa Fe is I-25, and between Moriarty and Santa Fe, US 287. Suggested long-range planning would consider CR22 as a feeder route to I-25. The idea that a trucker would favor turning from I-40 onto NM 14 in an attempt to get to I-25 North in a timely manner, is specious, especially given the new Big I interchange. There is the appearance of a political agenda on the part of a department's favoritism--in this case, industrial.
METHOD OR PROCESS OF DESIGNING AND COMMUNITY/DEPARTMENT INTERACTION: The process of designing (context sensitive) roads through communities and working with communities in NM is badly in need of revision. This project has lately been pressured by unrealistic deadlines that we believe would result in a far less safe and scenic road if allowed to manifest without substantial changes.
As the department well knows from past meetings, there has been considerable expressed frustration with the long time periods it has taken the department to respond to citizen input that can not be dismissed as mere bureaucracy. This is disrespectful and breeds disrespect.
A result of this disassociation is that citizens of communities become subjected to disinterested often fleeting, political and economic forces that have nothing to do with the communities impacted. Many good PEs are likewise constrained to design without the necessary sensitivities. Thus communities are subjected to a likelihood of being dropped out of the process and volunteers from communities must in essence, work overtime "for" the Department, researching, etc. and in a real and direct way are forced beyond reasonable civic duty, into paying a "second tax" in personal time.
There is clearly a need to develop context sensitive and traffic calming standards for rural and scenic roads throughout NM and to make these standard rather than exceptional practice. Assuming that the continuing investigation of the community's concerns, as expressed above for the record, lead to actual changes, the lessons of NM 14 may serve as a valuable example in developing new processes, methods, and standards to bring NMSHTD into a context- and community-sensitive 21st century.
CC: Rochelle Byars, Parsons Brinckerhoff
Contact the CAC, E-mail: firstname.lastname@example.org To: Turquoise Trail Home Page To Group's Actions To Resources for Saving America's Rural Roads and Communities--a listing.