Before turning to the substantive reasons for KRCs position that this proposal is without merit, let me begin by expressing my dismay with the precipitous manner with which KIPDA has approached this issue.
I am informed that the KIPDA Regional Transportation Technical Committee voted on November 8, one day prior to the close of the comment period that had been announced by KIPDA, to remove these advanced transit projects from the plan project list. That action has tainted this entire public involvement process and casts grave doubt on the sincerity of the agencys solicitation of public involvement, since it gives every appearance that KIPDA has already committed to a position, and has begun implementation of that position in violation of fundamental procedural due process obligations, making public comment a hollow exercise and reflecting a basic disregard for input from the community whose taxes pay for these transportation projects and whose electoral decisions populate KIPDAs Board. The only appropriate remedy for the action of the Technical Committee is for KIPDA to reject and set aside that determination, and to place the review and recommendation authority in the hands of a different Committee whose membership does not include persons who were involved in that prejudicial commitment of the agency to a substantive policy position in advance of the close of the public comment period, and who could make a recommendation after appropriate consideration of (and provision of response to comments received from) the public.
Regarding the substantive action proposed by KIPDA, KRC believes that the decision to remove the advanced transit projects from the long-range Horizon 2030 Plan is ill-advised, and is not required by the FHWA and FTA finding, which acknowledged that the transit projects in the current long-range plan were found to have adequate, reasonable sources of revenue at the time of the plan approval and that the next plan update would need to be adjusted to include only transit projects that can reasonably be anticipated to advance during the cycle of the plan. KIPDA has failed to provide adequate basis for concluding that the advanced transit projects are unlikely to advance during the next cycle of the long-range plans. Three independent yet related trends suggest that removal of these projects is ill-timed and ill-advised.
The first is that both the newly-elected Congressman from this District, and the Kentucky General Assembly committees with budgetary oversight over the Ohio River Bridges project have raised publicly what has long been known by those familiar with the project(s) that absent an unlikely new infusion of significant federal revenues to support the project, or dedicated of the lions share of state transportation monies to the project for the foreseeable future, a two-bridge scenario may be unrealistic as a budgetary matter, and that some or all of the need for intrastructure improvement will likely have to be met through more cost-effective, environmentally sustainable, and equitable transportation approaches such as light rail, BR or express buses or other advanced cross-river transit. Given the relative cost and dependence of the bridges project(s) on as-yet uncommitted federal funding and the lack of a financial plan for the bridge project(s), the reasonable anticipation that these transit projects can be funded and developed in the next 24 years is comparatively much higher and raises a question of whether the same standards of reasonable anticipation of funding are being evenly applied to transit and highway / bridge projects.
The second trend is the increased cost of motor fuel, which (despite the current abatement of the price increases) has significantly burdened both the commercial and residential sector, and has priced vehicle travel out of the reach of many local residents, as well as encouraging increased ridership. The deletion of the advanced transit projects in the face of rising demand is irrational and irresponsible.
The third trend is the redevelopment of the downtown and urban areas for residential and mixed use. Enhanced transit opportunities will facilitate mobility and encourage redevelopment of the urban core for an aging population. The lack of transit opportunities serving the redeveloping southern, southeast and downtown corridors will hinder these development efforts.
KRCs final concerns are the adverse effects of removal of these projects on both environmental quality and on economic justice. The jettisoning of these projects will result in failure to mitigate the increasing traffic congestion along many of these corridors that are economic drivers for this communitys retail businesses, and will caused increases in vehicle miles traveled by single occupancy vehicles that will complicate the ability of this community to reach attainment with the new fine particulate standards and the anticipated reductions in the current 8-hour ozone air quality standards.
Additionally, a number of Planning Commission zoning and development plan approval decisions, along the Highway 22 Corridor and elsewhere, rest in part on the assumption that transit projects in the Horizon 2030 Plan would be built. The elimination of these projects may require revisiting the development plans and air quality analyses for a number of development projects that have been approved by the Commission. Prior to taking any action towards elimination of any of these projects, a comprehensive assessment of the traffic and air quality impacts of removal of each and all of these projects should be undertaken. With respect to economic justice issues, KIPDAs devaluation of advanced transit in favor of retention in the long-range plan of highway improvement projects of low priority and low impact, reflects a lack of appreciation of the necessity of investment in public transit as a more sustainable, equitable, affordable transportation option for many residents of this community.
For each of these reasons, KRC requests that the Technical Committee vote be rejected, that the proposed changes be reevaluated after receipt of and consideration of the full range of comments, and that absent a compelling case that these projects cannot be funded within the next 24 year-cycle, that the proposal to eliminate these advanced projects from the long-range plan be withdrawn.