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The draft SDD contains recommendations by the MnDOT project team to retain for further consideration in the upcoming Environmental Impact Statement (EIS) a 6-lane freeway project design alternative for Hwy 252 (with or without buses and/or Toll Lanes). In case full funding for a 6-lane freeway is not attained, the draft SDD recommends a temporary phase involving a 4-lane freeway alternative (normal speed) for Hwy 252 with shoulders for buses, as well as four alternatives for I-94 involving combinations of additional northbound and/or southbound lanes with or without Toll lanes. MnDOT only intends to pursue the 4-lane normal speed freeway as an interim phase towards eventual construction of a 6-lane freeway in the event full funding is unavailable in the near-term for a 6-lane freeway.
Hwy 252 is currently an expressway with six local access signalized intersections serving an almost entirely residential area next to the Mississippi River. MnDOT’s Purpose and Need Statement is narrowly focused on transportation criteria, with only a limited and superficial screening for social, economic and environmental impacts. As a result, these narrow criteria have resulted in MnDOT’s recommendation for a 6-lane freeway alternative for Hwy 252, and additional lanes on I-94. This recommendation results in fatally flawed outcomes and causes irreversible harms to the people and environment of Brooklyn Center, Brooklyn Park and North Minneapolis.
RECOMMENDATIONS TO OUR COMMUNITY FOR MnDOT’s Hwy 252/I-94 PUBLIC COMMENT PERIOD
We recommend that the two 6-lane freeway alternatives (w/bus or w/toll lanes) for Hwy 252 should be eliminated, and replaced with two other alternatives, namely; a 4-lane low speed freeway alternative with shoulders for bus lanes and a 6-lane expressway with permanent safety improvements. Also, expansion of I-94 by adding additional lanes should be eliminated from further consideration.
We urge you to insist that MnDOT modify the Purpose and Need statement in order to increase its emphasis on safety, health, environmental protection, and equity for the people of our three cities, while decreasing the emphasis on increasing traffic volume and speed.
We urge you to recommend that MnDOT adopt evaluation criteria that:
(a)place increased emphasis on safety, human health, environmental protection, and equity and
(b) place decreased emphasis on traffic volume, speed and heavy freight truck traffic.
We urge you to insist that project alternatives should be evaluated using expanded criteria that:
- Avoid increases in traffic by not diverting traffic from other nearby freeways and not inducing new traffic
- Avoid increases in diesel-burning heavy freight truck traffic
- Any freeway interchanges at 66th Ave. must meet MnDOT safety design guidelines
- Reduce Vehicle Miles Traveled (VMT) and greenhouse gas (GHG) emissions
- Avoid adverse impacts of traffic increases on local roads
- Reduce impacts of traffic-induced air pollution on human health, hospitalizations and deaths
- Minimize property impacts for all home and business owners, especially BIPOC owners
- Prevent contamination of drinking water sources for Brooklyn Center near Hwy 252 and for Minneapolis at the Fridley water intake on the Mississippi River from road salt and toxic spills arising from crashes of heavy freight trucks
- Prevent pollution of the Mississippi River ecosystem by road salt and toxic spills arising from crashes of heavy freight trucks.
We urge you to insist that MnDOT expand evaluation criteria to elevate the importance of safety, health, environmental and equity, and de-emphasize transportation criteria such as traffic volume and transit time in order to create and promote Hwy 252 / I-94 alternatives that are less harmful to the people of Brooklyn Center, Brooklyn Park and Minneapolis.
Alternatives such as a 6-lane freeway are highly flawed because of higher traffic, faster speeds, poor interchange merging safety, harmful air and water pollution, and inequitable displacement impacts, especially for BIPOC home and business owners. We urge you to insist that MnDOT de-emphasize criteria that increase car and heavy freight truck traffic volume, and instead prioritize criteria that increase safety, health, environment and equity. Some examples of expanded criteria are described below, which, if adopted, would eliminate MnDOT’s flawed recommendation for a 6-lane freeway:
CRITERIA THAT AVOID INCREASED TRAFFIC VOLUME SHOULD BE ADOPTED BY MnDOT
- The MnDOT-recommended 6-lane freeway alternative (with bus lanes) will double existing traffic volumes on Hwy 252 through Brooklyn Center and Brooklyn Park, from 58,000 currently to a projected 114,000 vehicles a day: both cars and diesel-burning heavy freight trucks. This enormous increase also will add significantly to traffic volumes on I-94 through Brooklyn Center and North Minneapolis. We recommend that MnDOT should eliminate the 6-lane freeway alternative to avoid producing large increases in traffic volume, including diesel-fueled heavy freight trucks.
- Much of the increase in traffic volume arises, not from growth in population of the northern suburbs, but from car and heavy freight truck traffic diverted from Hwy 169, Hwy 610, I-694, I-94 and I-35W onto Hwy 252. These other transportation routes have large setbacks from surrounding areas, and are better suited for such traffic than the Hwy 252 residential neighborhoods next to the Mississippi River. We recommend that MnDOT should avoid diverting cars and freight truck traffic from Hwy 169, Hwy 610, I-694, I-94 and I-35W onto Hwy 252. MnDOT also should avoid inducing new traffic starting to use Hwy 252.
- Currently, relatively few trucks use the Hwy 252 expressway because of signalized intersections. The proposed 6-lane freeway will bring a major increase amounting to thousands of additional diesel-burning heavy freight trucks every day. These produce large amounts of air pollution and carry toxic and environmentally hazardous liquid substances such as gasoline, diesel fuel, heating fuels (kerosene), ethanol, sulfuric acid and worse. We recommend that MnDOT needs to conduct a thorough evaluation of this heavy freight truck traffic in the EIS, and include evaluation criteria that minimize diesel-burning heavy freight truck traffic volumeson Hwy 252 project alternatives.
SAFE INTERSECTION AND INTERCHANGE DESIGNS SHOULD BE A VERY HIGH PRIORITY FOR MnDOT
- Area residents and all drivers on Hwy 252 deserve the safest alternative, where crash numbers are average or better than average. MnDOT does not weight safety as high as other transportation criteria that favor maximizing size of roadway, and traffic speeds, volumes and types of vehicles(heavy freight trucks as well as cars).The 6-lane freeway alternative is much less safe than the 4-lane low-speed freeway alternative rejected by MnDOT. This is an affront to local communities, and all drivers who demand safety as the PRIMARY REASON for doing a project on Hwy 252. We recommend that MnDOT elevate safety above other transportation criteria such as traffic volume and speed. Doing so would require eliminating the 6-lane freeway and replacing it with the 4-lane low speed freeway.
- Freeway alternatives on Hwy 252 include the potential construction of freeway interchanges at five possible intersections. The most dangerous of these interchanges involves 66th Ave. north of the I-694 / I-94 / Hwy 100 interchange, which has only 830 ft between the 66th Ave on-ramp and the I-694 on-ramp. This is far less than the absolute minimum of 2,000 feet required by MnDOT’s Road Design Manual (Ch. 6) for traffic to safely merge with cars and large diesel- burning heavy freight trucks traveling to and from the multi-freeway interchange. This failure to allow enough distance for safe merging will increase crashes at the 66th Ave. interchange by 45%. We recommend that MnDOT follow their own safety specifications regarding interchange construction at a possible 66th Ave. interchange.
- MnDOT uses a generic model to estimate crash costs that does not account for specific interchange locations or their designs along Hwy 252 in their assessment of crash costs and safety, so their estimates of crash costs and safety are questionable, especially for the possible interchange at 66th Ave. We recommend that MnDOT should accurately estimate and report the impacts of specific freeway interchange locations and designs on crash numbers, severity and costs.
- MnDOT gives the 6-lane freeway alternative proposed for Hwy 252 a network crash rating of “Poor”. This contradicts MnDOT’s claim that safety will be addressed through this project. We recommend that MnDOT eliminate the 6-lane freeway and replace it with project design alternatives that have a network crash rating of “Good.”
CRITERIA THAT REDUCE VEHICLE MILES TRAVELED (VMT) AND GREENHOUSE GAS (GHG) EMISSIONS SHOULD BE APPLIED
- The doubling of traffic on Hwy 252 through the proposed 6-lane freeway alternative (4.5% reduction in VMT) will not come anywhere close to meeting Hennepin County goals for a 20% reduction in VMT. This also will result in failure to meet Hennepin County goals for reducing GHG emissions. We recommend that MnDOT should not ignore Hennepin County goals for VMT and GHG reductions, as this shows a lack of coordinationwith local, state and federal government planning processesto combat climate change and global warming impacts, which are already evident in our area.
ADVERSE IMPACTS OF TRAFFIC VOLUME INCREASES ON LOCAL ROADS SHOULD BE AVOIDED
- Construction of 6-lane freeway interchanges will increase traffic on local roads (85th Ave., 70th Ave. and 66th Ave.) because local residents who currently access the Hwy 252 expressway from six local access signalized intersections will have to drive farther on local roads to reach one of two or three freeway interchanges. Furthermore, if a freeway interchange is built at 66th Ave., northbound traffic that currently turns left at Hwy 252’s 66th Ave. intersection would exit to the right into a residential neighborhood 100 ft from the Mississippi River, before making a 270 degree turn to head west on 66th Ave. We recommend that MnDOT avoid building interchanges that increase traffic on local roads and infringe on the Mississippi River.
- MnDOT’s potential freeway interchange designs include a plan to reconnect the long-disconnected portion of West River Road between 74th Way and 75th Ave. in Brooklyn Park. This portion was closed in the mid-1990s to eliminate dangerous traffic numbers and speeds on West River Road between Brookdale Drive and 66th Ave. which resulted in numerous crashes and fatalities. Reconnecting this closed portion of West River Road will bring back dangerous traffic conditions on this local road serving an entirely residential area. High traffic volumes on the potential freeway alternatives are another factor that will increase Hwy 252 traffic exiting onto local roads, particularly for the proposed interchanges at 66th Ave. in Brooklyn Center and at 85th Ave. in Brooklyn Park. We recommend that the impacts of these factors on local traffic described here should be avoided by MnDOT.
IMPACTS OF TRAFFIC-INDUCED AIR POLLUTION ON HEALTH SHOULD BE EVALUATED AND REDUCED
- Doubling of traffic and inducing thousands of diesel-burning large heavy freight trucks on Hwy 252 (and significant increases of such numbers on I-94) are a serious health issue for residents of North Minneapolis, Brooklyn Center and Brooklyn Park. The residents of these three cities have large Black, Indigenous and other People of Color (BIPOC) populations who already have very high rates of asthma and chronic obstructive pulmonary disease (COPD).
North Minneapolis and Brooklyn Center have the highest and second highest rates of these diseases in the state. Currently, traffic-induced air pollution kills an estimated 11 people every year in the three zip codes along Hwy 252 / I-94 in these three cities. By comparison, there are currently 1 to 2 deaths every year along this route caused by vehicle crashes.
Doubling traffic and inducing thousands of diesel-burning freight trucks to drive on Hwy 252 (many of which will continue onto I-94) by turning it into a 6-lane freeway will lead to large increases in Air Quality Index (AQI) values and Particulate Matter (PM2.5) air pollution, and large increases (30-50%) in associated deaths and hospitalization of people in North Minneapolis, Brooklyn Center and Brooklyn Park. This is a fatal flaw and a public health disaster.
We recommend that MnDOT in partnership with the MDH comprehensively address and reduce the indirect and cumulative impacts of traffic-induced air pollution on human health.
PROPERTY SEIZURE AND ENCROACHMENT OF HOUSES AND BUSINESSES SHOULD BE MINIMIZED
- Construction of a freeway alternative and associated large, neighborhood-intrusive and damaging interchanges along Hwy 252 would displace many residents, and potentially impact up to 98 residences and 11 businesses in Brooklyn Center and Brooklyn Park through property seizures and encroachments. This will disproportionately impact at least 54 identifiable BIPOC property owners (and their families), many who are first-time homeowners without benefit of generational wealth. Some potential interchange options would encroach upon or seize homes, apartment buildings, businesses, churches, schools or parks along Hwy 252. MnDOT has neglected to evaluate the adverse impacts of these interchanges on our lower income working class and majority BIPOC communities, though these adverse impacts are likely to be extensive, inequitable and unjust. We recommend that MnDOT minimize or eliminate property impacts of freeway construction, with particular attention to avoid harming BIPOC property and business owners.
CRITERIA MUST PREVENT POLLUTION OF THE BROOKLYN CENTER AND MINNEAPOLIS DRINKING WATER SUPPLY
- The west and east sides of Hwy 252 between 66th Ave. and 73rd Ave. fall within Brooklyn Center’s Drinking Water Source Management and Groundwater Emergency Response Areas, where special measures are needed to protect city drinking water wells located along the west side of Hwy 252 near 73rd Ave. These wells are the sole source of drinking waterfor the entire city (population, 33,000),and are among the top three most vulnerable groundwater drinking supplies in the entire state of Minnesota due to very permeable sandy soils.
Any crashes along this stretch (particularly at the dangerous potential freeway interchange on Hwy 252 at 66th Ave.) involving large, slow and heavy freight trucks carrying hazardous liquids have the potential to contaminate Brooklyn Center’s ground water, pollute its city water supply, and shut down city wells, possibly irreversibly. There have been numerous examples of other freeways across the U.S., where such crashes have shut down city drinking water sources. Irreversible damage to Brooklyn Center’s city drinking water supply is a possible adverse outcomeof a dangerous potential freeway interchange at 66th Ave. and Hwy 252. We recommend that MnDOT consider soil or geologic factor impacts on ground water drinking supplies, and avoid building dangerous interchanges in these locations that elevate the risk of crashes involving heavy freight trucks carrying toxic substances that risk polluting drinking water supplies in these vulnerable locations.
- In addition, the east side of Hwy 252 from I-694 north to around 67th Ave falls within the Mississippi National River and Recreation Area. The dangerous potential freeway interchange on Hwy 252 at 66th Ave. on its east side will extend east to within 110 feet from the Mississippi River. Any crashes involving heavy freight trucks carrying hazardous liquids through this area have the potential to spill their loads and contaminate the Mississippi River. The resulting pollution could result in shutting down the Mississippi River drinking water intake located downstream in Fridley, which provides drinking water for the cities of Minneapolis and St. Paul. We recommend that MnDOT avoid building dangerous interchanges and evaluate the likely impacts of crashes for the dangerous potential freeway interchange at 66th Ave. on ground and surface water drinking supplies.
PROTECTION OF MISSISSIPPI RIVER FROM ROAD SALT AND TOXIC SPILLS SHOULD BE A HIGH PRIORITY
- The afore-mentioned diesel-burning heavy freight truck-related crashes and toxic spills also have the potential to upset the unique ecological balance of the Mississippi National River and Recreation Area (MNRRA). Hwy 252 not only falls within the MNRRA from I-694 north to around 67th Ave. but also runs directly next to itfrom 67th Ave north to 73rd Ave. The I-94 freeway itself is located within the MNRRA from I-694 south to 41st Ave. N. Toxic chemical spills along with salinity impacts from salting the roadway pose a real threat to MNRRA wildlife (such as otters, beavers, fox, coyotes and deer), aquatic life (mussels, fish and turtles) and migratory birds (such as trumpeter swans, eagles, herons, egrets and wood ducks)along the Mississippi River, which is a major North American continental flyway. We recommend that MnDOT avoid building a dangerous freeway interchange near the Mississippi River that elevates the risks of toxic chemical spills into the MNRRA. In addition, advanced salt, salinity and stormwater management practices need to be adopted to reduce the risk of salt pollution of ground and surface water that might adversely affect wildlife in the Mississippi River ecosystem.
Please consider these important issues and evaluation criteria as you review MnDOT’s draft Scoping Decision Document (SDD) for the Hwy 252 / I-94 project Environmental Review. We urge you to recommend that MnDOT adopt evaluation criteria that place increased emphasis on safety, health, environmental protection, and equity, while decreasing the emphasis on traffic volume and speed.
Our suggestions are consistent with the principles and criteria for evaluating transportation projects adopted by MnDOT’s own Sustainable Transportation Advisory Council (STAC). Sadly, MnDOT Hwy 252 /I-94 Project team leaders have chosen to largely ignore their own agency’s STAC recommendations.
We ask that you join us in recommending the elimination of the fatally flawed 6-lane freeway alternatives on Hwy 252 and expansion of I-94. We ask that you support adding back to the set of recommended project design alternatives both the 4-lane low speed freeway and the 6-lane expressway, which are less harmful to our cities than the 6-lane freeway alternatives.