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.
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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
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Fig. 1 - Alternatives for the railroad spur connection suggested by City staff
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Fig. 2 - Public support for 8th Ave WN highlighting improving economic activity
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Fig. 3 - Proposed 1st Ave WN Connector in 2019 SEA