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Aug. 24 Work Session Core Area Street Connector Public Comment from Brad WrightBrad Wright 233 Arbour Drive E Kalispell, MT 59901 (owner of the former Kalispell Lumber property) Aug. 21, 2020 Re: Aug. 24 Work Session — Core Area Street Connector Dear Mayor and City Council, This letter is to encourage you to select from one of the alternatives I have made you aware of in prior correspondence that are feasible and abide by the requirements of the TIGER Grant Project. In 1997, when the Westside TIF District was adopted, one of the primary goals was to improve connectivity and provide utility infrastructure by means of a street connector at 8th Ave WN. 7th Ave WN was the eastern boundary of this District. At that time, City staff explained to me their intention was to connect 8th Ave WN to either Center Street or Meridian Road by some means to provide this connectivity and access the utilities, since there are no other feasible ways to do that. In 20111 I met with City staff at City Hall because they were seeking my support to extend the District. I asked if it was still their intention to provide the street and utility connection from 8th Ave WN to Center or Meridian, and they said they were studying acquiring railroad ROW to connect a street across or through the railway corridor to the railroad spur near NW Drywall. I was told a connection through the machinery business property at the south end of 8th Ave WN was likely not feasible because of the extraordinary costs of doing so. Since it was their intention to provide the street and utility connection, I wrote a letter supporting extending the District and my first priority was improving infrastructure. It is logical to conclude the City had discussed agreements with the affected landowners whose properties would have to be acquired for the street connectors, because the 2015 TIGER Grant Application Narrative states - "This project will be 100% ready for construction to start by March 2016", and construction could not have started without some type of discussions with the affected landowners. Since then I have learned that there was no contact by the City to the affected landowners for the railroad spur connection suggested by City staff, even though there was a willingness by those landowners to discuss this with the City. At present, one of the affected landowners has property available on the City's Core and Rail website and it is likely the 8th Ave WN street connector could be completed to Meridian by acquiring that property alone, since the City has an agreement with BNSF for acquiring the railroad ROW to Meridian (See Fig. 1). I also learned there was no and likely would never be an agreement with the landowner affected by both the City's 6th or 8th Ave WN alternatives because the City would not consider purchasing his entire property. Other affected landowners for the 6th Ave WN or 8th Ave WN connectors have told me they were never contacted for acquiring their properties for street connectors. The FONSI states - "the City has had difficulties conducting property appraisals", but this is not possible because of the landowner affected by both the City's 6th or 8th Ave WN alternatives. He has had his property with the leased machinery business for sale for some time and has encouraged potential buyers to get appraisals, which any buyer would do for due diligence. Due diligence is - "a comprehensive appraisal undertaken by a prospective buyer, especially to establish its assets and liabilities and evaluate its commercial potential." The City is the buyer in this instance, and I am not aware that the City ever had any appraisals done for any of the properties that would be required for the street connectors, unless they have done some recently for the owners of the Mall or BNSF. I am also not aware of any research by the City for the costs of all the businesses that would have to be relocated by the City's 6th or 8th Ave WN alternatives. The Aug. 2020 FONSI states that it is consistent with the FRA's Procedures for Considering Environmental Impacts (64 FR 28545), but those regulations state that they must consider "feasible and prudent alternatives". The railroad spur connection suggested by City staff, which I have shown multiple configurations in documents I have submitted to the City Council and staff starting in Dec. 2017, have not been considered, even though they are much more likely to be feasible than the City's alternatives and abide by the requirements of the grant. The 2020 FONSI also states - "The 1 st, 3rd, and 4th Avenue WN complete street options would provide an indirect connection to the south, because of the location of the Mall... A direct connection is not required to meet the Proj ect's purpose." This directly contradicts the 2017 EA, referenced in the 2017 FONSI and the 2020 FONSI, which states - "These above listed connections would not have met the purpose and need of the proposed Project. Each would have provided connectivity to the Kalispell Center Mall (Mall) for southbound traffic on 4th, 3rd, 2nd, and 1 st Avenues and northbound patrons exiting the Mall, but would not have provided a direct connection to the south of Kalispell." Alternatively, the railroad spur connection would provide a direct connection to the south of Kalispell, and would meet the purpose and need of the Project, and abide by the 2017 FONSI and 2017 EA. The 2020 FONSI states the City - "has provided information to FRA demonstrating the 1 st Avenue WN, 3rd Avenue WN, and 4th Avenue WN complete street options would achieve the Project's purpose", but does not state what that information is. If that information is that the Mall has provided an easement for a future potential street connection to Center Street if the Mall is torn down, it is not credible a street connector would ever be constructed through the Mall property, considering the Mall is a modern steel and concrete structure designed to last hundreds of years which has recently added a significant addition to it. Further, the 2020 FONSI ignores the unanimous disapproval by the members of the Rails to Trails of Northwest Montana for the connectors to the Mall in their SEA comments. They are certainly one of the most significant pedestrian trail proponents in the Flathead Valley and for the Kalispell Trail specifically, as the National Rails to Trails organization is across the nation, and their letter provided specific reasons for their opposition to the Mall connectors, including the purpose, need, and public safety issues. With regards to public support, the 2020 FONSI states - "the highest preference was for 1 st Avenue WN". The spreadsheet the FRA relied on shows some twelve people preferred 1 st Ave WN. Of those, it appears four are residents of Kalispell, and it is likely only one could be considered a possible Core Area landowner - Eric Peterson, who is associated with the Mall. By comparison, I have contacted dozens of Core Area landowners and none have expressed a desire for these Mall connections to me. 3 As can be seen in Fig. 2, when the prior public outreach efforts were much more substantial than those done for the SEA, literally hundreds of people supported the 8th Ave WN connector, and it is significant to see the public heavily favored 8th Ave WN for the "Value to Improve Economic Activity in the Core Area", one of the most important goals of the Project. The only entity who benefits economically from the Mall connections are the Mall owners, since they own the majority of the land on both sides of the Trail. The question of improving economic activity because of the Mall connections was seldom brought up and had little support at any of the meetings I attended. The 2020 FONSI states - "Each completed street connection(s) would meet the City's complete streets policy ... and local street standards ..., providing two 14-foot-wide driving lanes, a minimum 9-foot-wide boulevard separating the roadway from a 5-foot-wide sidewalk, tree plantings, and sewer and water extensions, as needed for this Project." It is evident in the 2019 SEA (see Fig. 3), what they are proposing is a driveway access to the fire lane on the north side of the Mall, which does not meet Kalispell's street standards. For these reasons, I encourage you to reconsider the railroad spur connector options to 8th Ave WN as suggested by City staff since 1997. Sincerely, Brad Wright 4 Fig. 1 - Alternatives for the railroad spur connection suggested by City staff MOW a d l .17 —1- lowx IV �Npo�s' J I 10 low �. ik lot' 0011 01 40 a 5 Fig. 2 - Public support for 8th Ave WN highlighting improving economic activity 0 Fig. 3 - Proposed 1st Ave WN Connector in 2019 SEA