CHAPTER 4.0: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

Transcription

1 CHAPTER 4.0: AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES This chapter provides information only on those environmental resources for which existing conditions or project impacts have changed since completion of the Final Environmental Impact Statement (FEIS). No information is provided for the following resource areas for which impacts were fully and completely documented in the FEIS and ROD: Socioeconomic/communities Vegetation Wildlife species and wildlife habitat Threatened or Endangered species Surface water resources Ground water resources Water quality Utilities Geological resources Safety and security Energy Electromagnetic fields The FEIS and ROD are available for review on the project website or arrangements can be made to view the document in RTD offices. 4.1 LAND USE Changed Conditions There have been no substantive changes to existing land use along the Light Rail Transit (LRT) corridor since completion of the FEIS. Changes in future land use will occur as part of a planning effort being undertaken by the General Services Administration (GSA) at the Denver Federal Center (DFC) in Lakewood (see Section 4.1.1). According to the City of Lakewood s Draft Union Corridor Station Area Plan (November 1, 2006), residential and mixed use is anticipated near the proposed LRT station at the DFC; additional office and research space is proposed in the vicinity of the station. Also, in early 2006, GSA completed an Environmental Assessment (EA) proposing the relocation of Saint Anthony s Hospital to the campus (to open in early 2010). These additions are anticipated to increase the 4-1

2 economic diversity of the DFC, as well as to benefit users. The proposed station will help to serve all newly developed areas of the DFC. GSA completed a Draft EIS for the Denver Federal Center in early The comment period for this Draft EIS closed on June 11, RTD staff continues to work with local governments along the corridor in planning and providing for Transit Oriented Development (TOD) opportunities. Examples of planned projects that could spur other TOD at stations along the corridor include: Redevelopment of the former St. Anthony's location near the Perry Station. Candidate joint development sites at Sheridan Station. Lakewood Housing Authority purchase of 6 acres south of Lamar station for redevelopment. Relocation of St. Anthony Central Hospital to the DFC. At both Sheridan and Wadsworth stations, RTD will solicit offers to design and build the required parking garages, with the option of including additional transit-supportive uses on the site. The City of Lakewood has rezoned the Sheridan and Wadsworth station areas to allow denser, mixed-use development to support transit, and the City and County of Denver (CCD) is finalizing a new transit-supportive land-use plan for the Sheridan station area, to be followed by rezoning. RTD s solicitation process will begin in mid-2008, after the District has control of the parcels identified for the parking garages in the EIS. There are three planning studies that have been initiated by the City and County of Denver in the La Alma/Lincoln Park neighborhood: the 10 th and Osage Station Area Plan, the Auraria Station Plan and the La Alma/Lincoln Park Neighborhood Plan. These plans will not be formally adopted until sometime in the spring or summer of In the La Alma/Lincoln Park area, the designation by Blueprint Denver of this area as an area of change remains consistent with its likely future use as industrial. The area of change refers to its designation to change into a more fully utilized industrial area, providing additional jobs Changed Impacts The West Corridor project continues to be consistent with the goals and policies developed in adopted city and regional plans within the study area. The project is included in Denver Regional Council of Government s (DRCOG) MetroVision 2030 Regional Transportation Plan (RTP), which was adopted in January No substantive changes have been made to the project since its inclusion in the 2030 RTP. The Revised Design remains consistent with the Lakewood City Comprehensive Plan and the CCD s Blueprint Denver, an integrated land use and transportation plan. At the Jefferson County Government Center (JCGC) station, the Revised Design would not include construction of a pedestrian bridge originally included in the Preliminary Engineering Study (PE). The bridge would have crossed over US 6 to the south side, linking the JCGC station to land having potential for future development. Removal of this bridge would not 4-2

3 appreciably change the development potential of that property, or increase parking needs or vehicle trips to the JCGC station. RTD has committed to fund a portion of the pedestrian bridge if additional funding can be secured before the end of the FasTracks program. The Revised Design would result in some changed noise and visual effects to existing development (see Sections 3.5 and 3.7, respectively). The vast majority of research on property values from transit projects indicate that, for properties within walking distance of LRT stations, property values would be enhanced. Since the Red Rocks station is now on the south side of US 6, property value enhancements would be expected on the south side of US 6 within walking distance of this station. Also, as discussed in Section 3.5, there would be some changed effects to planned bicycle facilities, and in Section 4.10, new impacts requiring mitigation efforts are anticipated to an existing prairie dog town located adjacent to the west side of Arbutus Drive. West of the DFC, the PE Design alignment traveled along the north side of US 6 until near the Simms Street/Union Boulevard interchange, where it crossed to the south side of US 6. In this area, the alignment traveled along the residential area north of US 6. Under the PE Design, LRT riders from the community college would access the Red Rocks Station, also located on the north, via a pedestrian bridge. The Revised Design would maintain the alignment on the south side of US 6, after leaving the DFC at Union Street, and move the Red Rocks Station to the south on the west side of Arbutus where it would provide better access to the community college. The Revised Design would run north of residential and commercial areas before reaching the DFC, and is consistent with the urban land uses in this area. The US 6 corridor in this area is already developed, and these design changes would not alter the area s future land use. TOD could change traffic patterns near stations. Any TOD traffic effects would be reviewed by the appropriate local government during the development review process, with TOD developers being responsible for providing mitigation, if necessary. 4.2 ENVIRONMENTAL JUSTICE Changed Conditions Current Environmental Justice conditions are consistent with those found in the FEIS. The majority of the heavy concentrations of both minority (Latino) and low-income populations are located within the CCD in the vicinity of Federal Boulevard and the Villa Park and Sun Valley neighborhoods, and the Lincoln Park neighborhood east of the South Platte River (see West Corridor FEIS for complete details on Environmental Justice analysis). A shift in alignment near Ulysses Street and US 6 would bring the LRT closer to Mountainside Estates, a mobile home park in the study area (see Section 2.4.2). Community outreach efforts indicate that the park contains a large number of Hispanic households. The Revised Design would place the LRT tracks atop an existing 15- to 20-foot vegetated earth berm adjacent to the 4-3

4 homes. The berm would be shored up with a retained wall with a maximum height of 20 feet (see Figure 4-6). Other minor changes that would occur in other minority or low-income populations include: Removal of the Harlan Street maintenance facility. Additional LRT traffic using the Central Corridor LRT tracks to access the Elati Maintenance Facility Changed Impacts Design changes with the potential to affect low-income or minority populations include: Changes in LRT Frequency: In the FEIS, RTD planned for LRT trains to run on 5-minute frequencies during peak period operation along the entire alignment, but now proposes a 15-minute headway from the DFC to the JCGC station (see Section 2.4.1). Ridership forecasts for this operating scenario show a minimal effect on overall ridership for the corridor, suggesting that impact to transit users would be minimal. Even with this reduction, the light rail is still providing increased mobility for minority and low-income populations within the study area. Also, reduced frequency of train trips would reduce noise and vibration impacts to any communities near the LRT line, including disadvantaged populations. On the eastern end of the corridor, where the majority of low-income or minority populations are located, the frequency of LRT service remains the same as documented in the FEIS/ROD. JCGC/End-of-the Line Station Changes The visual impact assessment concluded that the Revised Design would change the visual environment for Mountainside Estates residents, but that this change would not be substantial (see Section 4.8.2). RTD will provide aesthetic treatment to the new wall to enhance its visual appearance. As part of the final project design, a noise analysis was conducted to evaluate noise impacts and mitigation options (see Section 4.6). The analysis shows that moderate noise impacts would occur to eleven mobile homes along the frontage road in Mountainside Estates. There would be no severe noise impacts to these residents. Through application of RTD s Moderate Noise Policy, noise abatement is not recommended for Mountainside Estates (see Section 4.6). Change in Maintenance Facility Location The change in the maintenance facility location from Harlan Street to Elati would positively affect the neighborhood around Harlan (with a resulting reduction in noise and traffic impacts). The change would result in increased LRT traffic using the Central Corridor tracks to access the Elati facility. This change would increase LRT trains using the tracks along Osage Street from almost 700 trains today to 744 trains when the West Corridor trains are added. By the year 2030 this would be 892 trains per day without West Corridor and 940 trains with the West Corridor. This five percent increase would not be a substantial increase. 4-4

5 Noise impacts of this change are documented in Appendix D of this Revised EA. Findings of this analysis are that these additional trains are expected to generate an Ldn noise level of 55.8 dba at the closest residence. This is well below the FTA moderate noise criterion of 64.2 dba. As a result, no noise impact (as defined by FTA) would be expected from this change. Construction of the light rail would benefit West Corridor households without automobiles by providing improved transportation access. Also, the LRT system would alter the social interaction of the West Corridor residents by concentrating transit travel opportunities at the stations and increasing the opportunity for community interaction at these locations. In summary and based on the information above, the Revised Design would not result in new disproportionate and high adverse effects to low-income or minority populations Outreach Chapter 5 discusses the public involvement activities that have occurred since completion of the FEIS. In addition to these activities, the project team conducted additional outreach for Mountainside Estates to ensure residents comments and concerns were considered. For example, members of the project team met with the Mountainside Estates park manager to provide general project information and discuss how the design changes may affect the park and its residents. Mailers were sent to Mountainside Estates residents to notify them of the upcoming public information meetings in May and September 2006, and July The mailers, which were provided in English and Spanish languages, also discussed the design changes and their potential effects to their community. Two neighborhood meetings were held with the La Alma/Lincoln Park Neighborhood during the NEPA process (July 29 and July 31, 2007). 4.3 ECONOMIC CONDITIONS Changed Conditions Current economic conditions are the same as those described in the FEIS for all areas of the West Corridor with one exception. The design for the Preferred Alternative has changed near the Auraria West LRT station. The at-grade LRT crossing of Old Colfax proposed during VE would now require the closure of Old Colfax, with cul-de-sacs constructed on the east and west sides of the rail alignment. The cul-de-sac on the west side would result in a continuous roadway from West 13th Avenue north on Umatilla Street to Old Colfax, and then east to the cul-de-sac. There does not appear to be any other public access to this lengthy stretch of roadway. Because of the lack of access in case of fire or other emergency, this will require additional acquisitions and relocations of light industrial businesses in this area. These design changes are described in detail in Section of this document. 4-5

6 4.3.2 Changed Impacts The closure of Old Colfax may have a slight negative impact to the light industrial businesses located on or near this street, however, this negative impact will likely be negligible due to the fact that these types of businesses do not rely on drive-up traffic. To access the businesses remaining in the area, some out-of-direction travel will be required due to the lack of crossing provided where the LRT alignment crosses Old Colfax. In order to get from the east side of the LRT alignment to the west side at Old Colfax, it will be necessary to travel south from Old Colfax on Cottonwood Street, which turns into Shoshone Street at 14th Avenue, and continue south to 13th Avenue. At 13th Avenue the LRT alignment can be crossed and then it would be necessary to travel back north on Umatilla Street to Old Colfax. This is about a five block outof-direction trip compared with the at-grade crossing at Old Colfax that was described in the FEIS. In addition to the out-of-direction travel, some area revenue could be lost from the nine business relocations. RTD believes it can provide suitable replacement property for the displacements. Therefore, the relocations could result in short-term revenue loss, but long-term effects are not anticipated. These relocations are described in more detail in Section 4.4 of this document Mitigation Good communication with the community, business owners, and residents with regard to road delays, access, and special construction activities is recommended during the construction phase. This may be accomplished by radio and public announcements, newspaper notices, onsite signage, and through the City and County of Denver s and RTD s Web sites. In addition, good on-site signing when Old Colfax is closed is recommended to let the public know where crossing the LRT tracks can be achieved. Mitigation for the relocated businesses is described in Section 4.4 of this document. 4.4 RELOCATIONS Changed Impacts The FEIS reported that the LRT project would require displacement of a total of 191 households, consisting of 179 multifamily residences and 12 single family residences. It also would require a total number of 34 business displacements. The Revised Design would result in eight additional business displacements beyond what was presented in the FEIS. Six of these relocations would occur near the proposed Auraria West LRT station due to the closing of Old West Colfax and the creation of a limited access cul-de-sac on the west side of the proposed LRT alignment. In addition, there are two new relocations where the LRT design has changed since the FEIS, and one relocation that was documented in the FEIS that is no longer occupied, so is no longer a relocation. Table 4-1 describes the properties to be acquired and the relocations to take place. 4-6

7 Table 4-1: New Relocations Property Address Owner/Business Description (from windshield survey on August 3 and 10, 2007) 1795 W. Colfax Ave. Atlas Metal & Iron Corp. This property contains Atlas Metal s maintenance building. The entire parcel would need to be acquired and would count as one 1800 W. Colfax Ave. William V. Goodpaster Family Trust/Cardinal Scale Manufacturing relocation. This property is an operating business. The entire parcel will need to be acquired and would count as one relocation W. Colfax Ave. Schwartz Properties, LLLP This property has two buildings that appear to have been vacant for quite some time. No significant storage could be seen on the property. This parcel acquisition would not count as a relocation W. Colfax Ave. Bat A. Ho & Nhi Hy/TC Auto Repair This property is in use as an auto body repair/storage lot. The entire parcel would be acquired and count as one relocation W. Colfax Ave. Atlas Metal & Iron Corp./Altitude Steel This property is in active use and has one access on Old West Colfax. This would count as one relocation W. Colfax Ave. Schwartz Properties, LLLP This parcel contains a large building with trucks, is in good repair, and is operating. The type of business is unknown. This parcel acquisition would count as one relocation W, Myrtle Pl. Graceland Properties, LLC/Electro-Fluid Power Co. The LRT and Siegel Oil Spur will land lock this parcel and therefore would need to be acquired. This will count as one relocation Tejon St. William E. Kugler, Trustee This was identified as parcel 28 in the FEIS Right-of-Way Report as a personal property move of a storage lot. There is no longer property on this lot to move and therefore this will no longer count as a relocation W. 14 th Ave. Gordon S. McKeeta Custom Art Industries There is one business operating on this parcel. It was not estimated as a relocation in the FEIS. The Revised Design will require the acquisition of this parcel and will count as one relocation W. 14 th Ave. Steve M. Fesch There is one concrete building on this parcel signed as Variety Bread. This parcel acquisition will be counted as one relocation Sheridan Blvd Sheridan Blvd Sheridan Blvd Sheridan Blvd. Multi-Family Apartment Complex The Sheridan station and bridge would require four multi-family properties that contain a total of 198 units (the FEIS stated 166 units). Table 4-1 also provides information on residential displacements at Sheridan Boulevard which have increased from 166 units in the FEIS to 198 units now. At Federal Boulevard, additional business relocation will occur as a result of the replacement of the Federal bridge. These are documented in the Federal Bridge Categorical Exclusion. 4-7

8 4.4.2 Mitigation RTD would continue to comply with all commitments in the FEIS regarding relocation of displaced properties and acquisition of real property, which now would include these eight new relocations. RTD believes suitable property can be provided in the area of the relocations to the businesses on the parcels that will be acquired. RTD would also comply with all applicable Colorado and federal relocation assistance requirements, including the Uniform Relocation Assistance and Real Property Acquisition Act of 1970, as amended. 4.5 AIR QUALITY The Revised Design and updating of traffic conditions to 2030 would not result in changed future air quality conditions. As described in Section 3.4, the revisions from the FEIS would not change the Levels of Service at key intersections affected by the project. The study area is now within the boundaries of the Early Action Compact (EAC) which includes strategies for reducing air pollutants from ozone. The West Corridor project changes would have no effect on this EAC. Since the FEIS and ROD were signed, the FHWA has issued Mobile Source Air Toxics guidance. This guidance would not apply to the West Corridor project since it does not increase or affect highway capacity. The West Corridor project is in the fiscally constrained, conforming 2030 Regional Transportation Plan and in the 2007 to 2012 Transportation Improvement Program (TIP) as adopted in June The project that is in the RTP and TIP assumes five minute headways the entire distance. The Revised Design assumes five minute headways from Auraria to the Denver Federal Center and fifteen minute headways from Denver Federal Center to the Jefferson County complex. This change in headway will reduce ridership by 900 riders a day, or 3 percent (from 27,600 to 26,700). This very minor reduction in service would not constitute a substantial change in project scope and would not require an amendment to the 2030 RTP. 4.6 NOISE AND VIBRATION As part of the Final Design for the West Corridor Project, a detailed noise and vibration assessment was performed for the project corridor in accordance with the methodology contained in the Federal Transit Administration s (FTA) Transit Noise and Vibration Impact Assessment (FTA-VA ; revised May 2006). The FTA Guidance Manual presents the basic concepts, methods and procedures for evaluating the extent and severity of noise impacts from transit projects. The 2007 assessment included all of the revised design changes Noise Impacts The assessment was documented in Noise and Vibration Analysis Technical Report, (KM CHNG, 2007). This analysis included additional ambient noise and vibration readings collected two times in 2006 and re-analysis of project impacts to both noise and vibration levels. FTA uses two curves that define how severe a noise impact is (see Figure 4-1). Table 4-2 and Table

9 illustrate noise measurement and noise impact using these curves. The primary noise findings are illustrated in Table 4-2 and Table 4-3. Figure 4-1 Noise Impact Criteria for Transit Project Site No. Table 4-2 Summary of LDN Noise Measurements and FTA Impact Criteria Location Measured-LDN Level (dba) FTA-Moderate Impact Criterion 1 FTA-Severe Impact Criterion 1 East End of Corridor (Knox Court to Oak Street) M Knox Court M Quitman Street M Ames Street East End of Corridor (Knox Court to Oak Street) M Otis Street M th Avenue M Vance Street M Allison Street M Cody Street M Garrison Street M West 13 th Place M Johnson Street

10 Site No. Table 4-2 Summary of LDN Noise Measurements and FTA Impact Criteria Measured-LDN Level FTA-Moderate Impact Location FTA-Severe Impact Criterion 1 (dba) Criterion 1 M th Place M th Place M th Avenue West End of Corridor (along US 6) M Van Gordon Street M West 5 th Avenue M Eldridge Street M-18 Mountainside Estates These criteria represent the allowable project noise limits based on the measured existing noise level. Table 4-3 Summary of FTA Noise Impacts Prior to Mitigation Corridor Section FTA-Severe FTA-Moderate Impacts Impacts Total FTA Impacts Knox Court to Oak Street Union Boulevard to Jefferson County Government Center (along US 6) Total Impacts Noise measurements were obtained at locations that represented existing background levels to all receptors along the corridor. These measurements were used as baseline conditions for use in the noise impact assessment. Noise measurements were not obtained west of the Indiana Street flyover because the major noise source (traffic on highway US 6) was considered to be similar to the noise levels measured at locations M16 (13859 West 5th Avenue) and M17(624 Eldridge Street). Although these noise measurements were obtained prior to the design change to the Indiana Street flyover, noise levels west of Indiana Street were considered to be similar to the noise levels east of Indiana Street. The noise modeling analysis included the revised track alignment and elevated Indiana Street flyover and distance from the LRT corridor to determine potential impacts. Because of the higher noise levels measured along US 6, the FTA moderate and severe impact criteria were significantly higher (see Noise and Vibration Technical Report; Table 4) along this section of the project corridor. As a result, no noise impacts from the LRT operations were identified for receptors along US 6, except at the Mountainside Estates where moderate noise impacts are anticipated. Receptors at this location are currently shielded from US 6 traffic noise resulting in lower measured noise levels and an increased sensitivity for non-us 6-related noise. NOISE IMPACTS FROM WAYSIDE BELLS Because of the use of quad-gates at the grade crossings, the use of the LRT warning horns at grade crossings is not required except in emergency conditions. In addition, RTD does not plan to use wayside bells at quad-gated grade crossings. However, PUC has final approval of this. 4-10

11 Design needs to be basically complete before filing these applications to the Colorado PUC. If the PUC denies RTD s petition, RTD and FTA will re-evaluate the noise analysis to include wayside bells. If this revised analysis results in additional impacts that quality for noise mitigation under RTD s noise mitigation policies, RTD will provide appropriate mitigation. NOISE IMPACTS FROM LRT WARNING DEVICES The LRT vehicles are equipped with several types of warning devices: a gong, a bell, and a horn. RTD s standard operating procedures require the warning bell to be sounded for approximately 5 to 10 seconds (corresponding to a distance traveled of approximately 200 feet) as the LRT vehicles enter the station area. The LRT horns will only be sounded in an emergency condition. The use of gongs and bells at the LRT stations was evaluated separately to determine the change in noise levels at receptors located near the stations. Those LRT stations with nearby residences that were included in this analysis are: Knox Court Station, Perry Street Station, Sheridan Station, Lamar Street Station, Wadsworth Station, and Garrison Street Station. The FTA noise model was used to calculate the L DN noise contribution from the gong at all receptors located within 200 feet of the stations. The results of this noise analysis indicate that the use of the gong will result in no increase in the total L DN noise levels at receptors located near the stations. The calculated L DN noise levels from the gong is significantly below the L DN noise levels from the LRT operations (more than 10-dBA) such that the logarithmic sum of the two noise sources results in essentially no increase in noise above that produced by the LRT vehicles alone. As a result, although the gong will be audible above the background noise levels, it does not contribute to the overall calculated L DN noise level from the LRT operations. The FTA noise model was then used to calculate the L DN noise contribution from the LRT bells at all receptors located within 200 feet of the stations. The measured Lmax sound level from the LRT bells is 95 dba at 10 feet, or 81 dba at a reference distance of 50 feet. The results of this noise analysis indicate that the use of the LRT bells while entering a station increases the overall L DN noise levels of the receptors located within 200 feet of the stations by approximately 2 dba. As a result of this increase in L DN noise level with the LRT bells, four of the previous moderately impacted receptors (without the bells) now become severe impacts, and four previously nonimpacted receptors now become moderately impacted. This change in the total number of noise impacts is relatively small because most of the receptors near the stations are already impacted by the project. Table 4-4 summarizes the results of this analysis. Table 4-4 Summary of Noise Impacts with and without Warning Devices Severe Impacts Moderate Impacts Total Impacts LRT Operations without warning devices LRT Ops with sounding gong at stations LRT Ops with sounding bells at stations

12 NOISE ANALYSIS OF BUS OPERATIONS AT LRT STATIONS In addition to the noise from the LRT vehicles and warning bells at the station areas, RTD buses will also contribute to the overall project noise levels. Because of the West Corridor LRT project, bus operations along several of the bus routes are expected to increase. For example, bus operations along Sheridan Boulevard are expected to increase from 67 to 121 daily operations; bus operations along Wadsworth Boulevard are expected to increase from 125 to 154 daily bus operations; and the existing buses operating on Kipling Street (39 daily bus operations) will be re-routed onto Oak Street (95 daily bus operations) to provide access to LRT service at Oak Street Station. There is currently no bus service on Oak Street. Bus operations on Knox Court, Lamar Street, and Pierce Street will remain unchanged and were therefore not included in this noise assessment. As a result, the noise from bus operations at Sheridan Station, Wadsworth Station, and Oak Street Station are included in this analysis and reflect the additional noise from the incremental increase in bus operations associated with the LRT project, and the noise from the idling buses that stop at the LRT stations. The typical dwell time for the buses at Sheridan Station and Wadsworth Station is 20-seconds, while the dwell time at the Oak Street Station could be up to 3-minutes because there is off-street parking for the buses. If a bus remains at the station for more than 3-minutes, the bus driver is required to shut-off the engine. The typical Lmax noise level for a city bus at a distance of 50 feet traveling at a speed of 35 mph is 80 dba. For idling buses at a distance of 50 feet, the Lmax noise level is 75 dba. The bus noise analysis was performed in accordance with FTA procedures. The bus noise analysis only addresses the noise levels at sensitive receptors in the immediate vicinity of the LRT stations. This analysis is not meant to be a system wide noise assessment of the entire bus route. The incremental increase in bus operations on Sheridan Boulevard and Wadsworth Boulevard are not expected to result in a significant change in noise levels along these bus routes because of the existing traffic noise along these roads. BURNHAM LEAD RELOCATION Noise and vibration impacts for the entire project (including relocation of the Burnham Lead) were analyzed during the FEIS pursuant to FTA guidelines based on location and type of receptors. Neighborhood uses and location of receptors in an area govern those analyses. Noise and vibration analyses for all sensitive receptors lying within the criteria established by FTA guidance were performed, and results were disclosed. Given the location of the relocated Burnham lead, vis a vis other uses within the screening distance for potential impacts prescribed by the 1995 and 2006 FTA Transit Noise and Vibration Impact Assessment Guidance Manual, further analysis was not required during the FEIS and is not required for this EA. Noise impacts of the change in maintenance facility location were analyzed to determine this effect on residences in the La Alma/Lincoln Park Neighborhood. Findings of this analysis are that these additional trains are expected to generate an Ldn noise level of 55.8 dba at the closest residence. This is well below the FTA moderate noise criterion of 64.2 dba. As a result, no noise impact (as defined by FTA) would be expected from this change. 4-12

13 VIBRATION IMPACTS The results of the vibration impact analysis indicate that there are a total of 13 impacted receptors along the project corridor. Twelve of the impacted receptors are located along the project corridor between Knox Court and Oak Street where the residences are relatively close to the rail corridor. There were no vibration impacts predicted along the west end of the project corridor along US 6, where the receptors are located further from the track alignment. For the impacted receptors along the rail corridor, the vibration levels are 1 to 3-VdB above the FTA vibration impact criterion. Appendix E in the Noise and Vibration Technical Report contains a table of the predicted vibration levels at each of the impacted receptors. In addition to the vibration impact assessment at residential receptors, vibration levels were also evaluated at buildings with vibration sensitive equipment. Two such buildings that have been identified are Building #85 at the Denver Federal Center (located approximately 900 feet from the nearest LRT track) and the Gambro Medical Facility at the Lakewood Industrial Park located approximately 75 feet from the nearest LRT track. Applying the FTA s 65-VdB impact criterion for Category 1 receptors (buildings where low ambient vibration is essential for interior equipment operations), the impact distance for LRT vehicles traveling at mph is approximately 95 feet. Therefore, Building #85 at the Denver Federal Center is too far away from the LRT corridor to be impacted, while the Gambro Medical Facility would be impacted. Although the exact location of the vibration sensitive equipment inside the building or the actual sensitivity of the equipment is not known due to security reasons, ballasts mats would be installed to reduce the LRT vibration levels at this location Mitigation RTD NOISE MITIGATION POLICY FTA requires that all severe impacts be mitigated. In response to FTA s recommendation that each transit agency devise a policy to mitigate Moderate impacts that is fair, reasonable, and effective, RTD developed a process for evaluating the need to mitigate for moderate noise impacts for the FasTracks program. RTD is committed to providing noise mitigation to all residential receptors predicted to experience a severe noise impact from the project, unless there are extenuating circumstances that may prevent it. RTD is also committed to evaluating reasonable noise mitigation for residential receptors predicted to experience a moderate noise impact. RTD s Moderate Impacts policy addresses the issue of noise mitigation for residential receptors with moderate noise impact. The results of the analysis, documented in the Noise and Vibration Analysis Technical Report, indicated that there were 50 severe and 168 moderate impacted receptors along the project corridor. For noise mitigation, a six-foot-high noise barrier was recommended to provide the necessary noise reduction at the impacted receptor locations along the project corridor. The location of the remaining 91 moderate impacted receptors along with all of the 50 severe impacted receptors which remain eligible for noise barriers are shown in the figures in 4-13

14 Appendix B of the technical report. Figure 4-2 shows general locations of impacted receptors. Figure 4-2 Location of Impacted Receptors 4-14

15 RTD S PROPOSED NOISE BARRIER LOCATIONS For the remaining 91 moderate impacted receptors still considered eligible for noise barriers, RTD s policy steps 2 and 3 focus on the cost effectiveness of the noise barrier (step 2) and the number of impacted receptors that will benefit from the noise barrier (step 3). Applying RTD s policy steps 2 and 3 result in a total of 26 recommended noise barrier segments along the project corridor between Knox Court and Oak Street. All 50 severe impacted receptors are eligible for noise barriers. However, one of the severe impacted receptors (receptor ID No. 2005) is expected to be acquired by the project for the construction of the proposed parking garage at the Wadsworth Boulevard Station. Table 4-5 describes locations of these 26 noise barriers, while Figure 4-3 shows their general locations. Table 4-5 also shows the number of affected properties, the approximate length of the six-foot-high noise barrier, and the reason why the noise barrier meets the RTD policy requirements. The 26 recommended noise barriers will provide noise mitigation to all 49 remaining severe impacted receptors and to 67 of the 91 moderate impacted receptors within the upper 50 percent of the FTA s moderate impact range. The total length of the 26 recommended noise barriers is approximately 16,522 feet. This represents a reduction of noise barriers from the 30,260 feet proposed in the FEIS. The remaining 25 moderate impacted receptors that are in the upper 50 percent of the FTA s moderate impact range did not qualify for noise barriers under RTD s policy steps 2 and 3. Table 4-5 Proposed Noise Barriers Noise Wall Location Side of Tracks # of Affected Properties Reason Approximate 6' Wall Length (feet) Knox Court to the west north 1 severe 170 Osceola to Perry Street north 2 Sheridan to the west north 5 Pierce to Teller north 9 West of Teller north 2 Teller to almost Wadsworth south 10 Pierce to Saulsbury south 7 residential adjacent to severe 297 Severe (includes adjacent residential) 820 over 800', cost effective Severe (includes residential adjacent to severe) more than 10 properties, 800 ', cost effective more than 800', cost effective East of Zephyr to Allison north 2 severe 363 Allison to Ammons north 2 severe

16 Table 4-5 Proposed Noise Barriers Noise Wall Location Side of Tracks # of Affected Properties Reason Approximate 6' Wall Length (feet) East side of Balsam to Carr north 3 severe 675 Ammons to Carr south 5 more than 800', cost effective 947 East of Ammons to Allison south 1 severe 195 West of Wadsworth to Yarrow south 2 Severe (includes adjacent residential) 319 Spanning Everett Ct. north 2 severe 485 East of Garrison north 1 severe 195 West of Estes to Garrison south 6 over 800', cost effective 1044 Carr to Estes south 9 over 800', cost effective 1295 Garrison to west of Holland north 6 Pikeview to Johnson north 2 Independence to almost Kipling south 7 Garrison to Independence south 11 over 800', cost effective severe over 800', cost effective 1270 over 800', over 10, cost effective 1291 Nelson to west of Lee north 6 over 800', cost effective West of Nelson to Nelson north 1 severe 250 east of Oak north 1 severe 238 Oak to Nelson south properties, cost effective 650 Nelson to East of Moore south 3 severe 406 Total 116 Total

17 Figure 4-3 Proposed Noise Barrier Location 4-17

18 These noise barrier locations have been placed in accordance with RTD s policy described in its Technical Memorandum: Implementation of RTD s Policy for Noise Mitigation Measures for Moderate Impacts (RTD, June 2007), summarized below. The RTD policy contains additional screening requirements for noise barriers. Because the most common noise mitigation is a noise barrier, the RTD policy is specific to selecting locations for the installation of these noise barriers. If the PUC denies RTD s petition, RTD and FTA will re-evaluate the noise analysis to include wayside bells. If this revised analysis results in additional impacts that qualify for noise mitigation under RTD s noise mitigation policies, RTD will provide appropriate mitigation. These noise walls will likely have secondary impacts, such as visual impacts, shading impacts, accessibility impacts, and impacts to community cohesion. To address noise during construction. RTD will obtain the applicable construction noise permits from the City and County of Denver, City of Lakewood, Jefferson County, and City of Golden. PUBLIC INVOLVEMENT RTD conducted specialized public involvement for individuals residing in areas that are estimated to experience noise impacts as a result of the West Corridor project, as summarized below: May 5, 2007, Noise Demonstration. Actual light rail sounds were demonstrated in three locations along the corridor to give community members a feel for the sound of light rail along 13 th Avenue. Over 200 people attended the demonstration. Noise wall heights were also demonstrated. RTD sponsored a series of meetings in June 2007 with affected property owners to guide them through the noise mitigation process. Also, on June 14, 2007, the City of Lakewood held a public meeting where city staff presented computer simulations showing noise walls along 13 th Avenue. VIBRATION MITIGATION For the 13 vibration impacts identified along the project corridor, ballast mats or shredded rubber tires (such as that used on the Denver T-Rex Project) are recommended as the appropriate mitigation measure. RTD commits to the appropriate mitigation for each impacted area. Ballast mats and shredded rubber tires can provide approximately 3 to 10 VdB reduction in vibration levels depending on the frequency of the vibration. For single vibration impacted receptors, the ballast mat should extend for a distance of approximately 100 feet under the tracks directly in front of the impacted receptor. 4-18

19 4.7 CULTURAL RESOURCES Changed Impacts Table 4-6 shows historic properties that are eligible for the National Register of Historic Places (NRHP) affected by the proposed design changes, and the updated effect determinations for each property (see Figure 4-4). Historic Resource International Style House (5JF2873) Kit House (5JF2897) 1918 Farmhouse (5JF2917) Golden Cemetery (5JF401) Table 4-6 Historic Properties having Changed Project Actions 2006 Revised Project 2004 Effect Determination Actions and Impacts No adverse effect. House was in place during operation of railroad on existing right-of-way. Mitigation will minimize impacts of road widening. No effect No effect Not included in original FEIS New right-of-way would be acquired from the northwest corner of the property. Ditch would be moved south onto the new right-of-way. Driveway would be modified to include asphalt up to the property line. 13 th Street would be extended to the edge of the property line. Three-foot swale might be placed on the property to the right of the driveway. Driveway would be modified to include asphalt up to the property line. Clear ditch and remove trees. Shift ditch closer to property line. Modify driveway to be asphalted to the property line. Shifting track alignment at Colfax Avenue (State Highway 40) and 6th Avenue slightly to the north. The space around the electrified catenary wires must be clear of tree branches to avoid the possibility of tree branches rubbing against the wire in the wind or breaking and falling onto the wires and tracks. Therefore, it would be necessary to remove the Cottonwood trees located at the southern edge of the cemetery within the fence Effect Determination No adverse effect. No adverse effect. No adverse effect. No adverse effect. For more information, please refer to the Project Effect Assessment for the FasTracks West Corridor Light Rail Track Project in Denver and Jefferson Counties, Colorado (Carter & Burgess, 2006). In its letter of October 25, 2006, the Colorado State Historic Preservation Officer (SHPO) concurred with these effect determinations for every resource except the Agricultural Ditch. The SHPO concurred with the latest effect determination for the Agricultural Ditch in its letter of November 2, 2006 (see Appendix C). Based on a more-recent VE change, effects to the Agricultural Ditch would be similar to those described in the FEIS and the Memorandum of Agreement (MOA) discussed below. FTA sent a letter to the SHPO on July 10, 2007 describing this change (see Appendix C). Subsequent to this letter the SHPO signed the revised MOA, which is in Appendix F. 4-19

20 Figure 4-4 Location of Historic Properties having Changed Project Actions 4-20

21 The Revised Design would change the effect determinations to several of the properties listed in Table 4-6. It would not result in changes to effects on the other historic properties identified in the FEIS/ROD. For the EIS, consultation with the Colorado State Historic Preservation Officer (SHPO) resulted in a MOA to address the effects of the project on historic properties. The MOA was executed on March 4, 2004, and signed by Lee O. Waddleton (FTA), Georgianna Contiguglia (SHPO), Clarence W. Marsella (RTD), and Thomas E. Norton (Colorado Department of Transportation [CDOT]). To account for the changed effects discussed earlier in this section, the MOA has been amended and is included in Appendix F. REVISED MITIGATION RTD would adhere to all mitigation measures included in the FEIS and ROD except for the commitment to provide ballast mats at the International Style House. This mitigation measure is no longer necessary because of the absence of a vibration impact at this location. 4.8 VISUAL RESOURCES The FEIS presented the visual effects of the previous LRT Alternative. This section of the EA discusses potential visual effects that would result from the revised design, as described in Chapter 2. This discussion focuses on portions of the project that have changed in scale, scope, alignment, and project components that would be located in areas not previously analyzed Changed Conditions The visual environment of the study area has changed little in the last three years. The dominant land uses and visual elements of the study area contain industrial, commercial, residential, roadways, parks, and intermittent open/undeveloped parcels Changed Effects CHANGES IN LRT FREQUENCY Between the JCGC and the DFC the LRT train frequency would be reduced from every 5 minutes to every 15 minutes. This would reduce visual effects caused by trains traveling along the line. JEFFERSON COUNTY GOVERNMENT CENTER The changes at the JCGC include relocating the station and parking lot to the east of the JCGC, and construction of a bus drop-off area. The structures would remain primarily visible to persons working at and using the JCGC. The visual environment experienced by travelers along US 6 would be similar to when the structures were to be located on the west side of the JCGC because the new structures would be obscured by existing landscaping and slopes adjacent to Johnson Road. 4-21

22 Portions of the new parking structure may be visible in the background from isolated locations within Golden Cemetery. As shown in Photo 1, views of the station from the cemetery would be obscured by trees within the cemetery and the slopes adjacent to Johnson Road. Additionally, the parking structure would have a scale, massing, and design, consistent with the JCGC buildings. The structure would not block views of any scenic vista or area and would not substantially alter the existing visual environment. As a result of the Revised Design, the LRT track proposed between the JCGC and the Denver Federal Center was changed from a double-track to a single-track, as described in Section of this EA. This change would reduce visual effects compared to the PE Design due to the following: Reduced track width Reduced catenary wires Reduced walls Narrower construction footprint, resulting in less cut and fill and smaller retaining walls Shorter construction period MEMORIAL GARDENS Photo 1 Photo 2 The West Corridor project would result in a short-term visual impact to the Memorial Gardens area, just west of the JCGC and just north of the platforms at the end-of-line station. The Memorial Gardens is a very sensitive area of planted trees and flower gardens, with memorials to various people. It is maintained by the Jefferson County Court system. A context sensitive location was chosen for the LRT tracks in this area and a two stub track configuration at the station that ends just east of the Memorial Garden site will minimize any impacts to Memorial Gardens. The visual impact that would occur is only during the period of construction, and every effort will be made to minimize noise and visual impacts of the construction activity on users of the Gardens. MOUNTAINSIDE ESTATES East of Ulysses Street, the alignment would shift closer to Mountainside Estates (see Figure 4-5). A single LRT track would be constructed in this area on the top of the existing 15- to 20-foot vegetated earthen berm adjacent to the homes, as shown in Photo 2. Figure 4-6 shows cross section views of the LRT facility. 4-22

23 Figure 4-5 Mountainside Estates 4-23

24 Figure 4-6 New Retained Earth Wall 4-24

25 Construction of this portion of track would no longer require a large retained earth wall along the length of the berm. The Revised Design would result in a shorter retained earth wall on the north side of the berm that would still be clearly visible in the foreground to the southern row of homes. LRT vehicles and catenary lines would still be visible on top of the berm; however, the visual impact would be reduced because of the single LRT track included with the Revised Design. Views of the shortened wall from interior locations of the estates would be obscured by intervening homes and vegetation. Other homes within Mountainside Estates would have partial views of the wall, but primary views would not be blocked. Although the wall would be visible from the southern homes and some interior residences and locations, the wall would not block any midground or background views of any scenic resource or vista because views to the south are already blocked by the earth berm. RTD would treat new walls aesthetically to soften their impact. Therefore, although the visual environment would be changed, the changes would not be substantial. PROPOSED BRIDGE AT US 40/COLFAX Because of the LRT alignment shift northward, the length of the bridge to span Colfax Avenue would be reduced from 1,140 feet to approximately 500 feet. The reduced scale of the bridge would reduce visual effects for all viewers, including travelers on US 6, local roads, business complexes, and residents. The shorter bridge still would be visible for some residents of Mountainside Estates. GOLDEN CEMETERY The LRT alignment would be shifted north near the Golden Cemetery fence line on an elevated 10-foot footing with vertical walls. The alignment shift would require the removal of seven mature cottonwood trees approximately 50-to-55 feet tall. Removal of the trees would alter the views and remove the vegetation screen between the cemetery south toward US 6, businesses on the opposite side of US 6, and the opposing hillside. Views from US 6 into the cemetery would be more clear. The foreground views from the cemetery would change upon removal of the trees and upon construction of the new retaining wall. Photo 2 shows a current view from Golden Cemetery looking south. Persons within the southern area of the cemetery nearest the proposed LRT line would be particularly aware of changes in the visual environment. Views from US 6 to the northeast also would change. Photo 3 shows a view from eastbound US 6 to the east. Removal of the trees would Photo 3 change the visual environment by restoring views of the eastern skyline and downtown Denver. The new track structures would be a new visual 4-25

26 element, but they would not block views of any scenic vista or area. Therefore, effects to the visual environment would change but are not considered substantial. INCREASED UNDERPASS DEPTH AND FILL WALL A deeper tunnel underneath I-70 is proposed as part of the revised alignment. The underpass would remain in the same location but would be lengthened. Because more of the track would be located underground, less would be directly visible. Therefore, the lengthened underpass would reduce the foreground visibility of the alignment over this section of track and slightly improve the visual environment. The lengthened underpass would allow for the replacement of the previously proposed 40- to 50-foot high retaining walls with a 15-foot fill wall. This would reduce the overall height of the retaining structure by 25 to 35 feet and substantially reduce the visual effects. ALIGNMENT SHIFT TO SOUTH OF US 6 The LRT alignment in the vicinity of the US 6/Indiana Street interchange was changed under the Revised Design. From the north side of US 6 immediately west of Indiana Street, a proposed bridge approximately 1500 feet in length would carry the LRT line across Indiana Street and US 6. Once on the south side, the bridge would turn sharply roughly 400 feet west of Gladiola Street, and then continue until its touch down point near Gladiola Street, where the LRT line would be at-grade. The LRT line would continue at-grade past the Sixth Avenue West subdivision, running between the frontage road and US 6 (see Section 2.4.5). The LRT realignment west of the US 6/Indiana Street interchange would relocate the LRT alignment farther from the neighborhood immediately west of the interchange along the north side of US 6. However, the LRT track would be more visible to that neighborhood because it would be elevated on a bridge beginning approximately between Juniper and Joyce Streets. Visual impacts would be slightly reduced for properties east of the interchange along the north side of US 6 because the LRT alignment would be shifted to the south side of US 6. Along the south side of US 6 immediately east of the interchange are commercial and office land uses, which are not considered visually sensitive receptors. As the bridge transitions to ground level east of the interchange, the LRT track would be supported with piers rather than a retaining wall, which would reduce the visual impact. Visual impacts would be reduced for the neighborhood to the north of US 6 since the LRT would run along the highway s south side. Residents exiting the US 6 South neighborhood from Gladiola Street onto the frontage road south of West 6 th Avenue would have a clear view of the bridge. Residents exiting from Flora Way and Deframe Court would have a clear view of the at- Photo

27 grade, single track LRT alignment between US 6 and the frontage road. Photo 4 shows a view to the north from the intersection of Deframe Court and West 5 th Avenue. The new bridge would be most noticeable to drivers along US 6. The bridge would be constructed along a transportation corridor with developed urban centers, including two bridges located approximately 1.25 miles to the west and east, and would be consistent with other structures in the vicinity. Based on the existing visual characteristics of the surrounding areas, the new bridge would be consistent with the existing urban environment. Although it would change the visual environment in the immediate vicinity, the bridge would not block any scenic views or impact significant viewing opportunities. Incorporation of the bridge would enable relocation of a LRT wall from the northern side of US 6, adjacent to about 50 homes, to the south side of US 6. Along the southern alignment, land uses consist of vacant land at the entrance to Red Rocks Community College, two office buildings, and a portion of an apartment complex. These uses are typically less sensitive to changes in the visual environment. The wall would maintain a decorative design with interlocking concrete panels. Overall, the wall would be less visually obtrusive, would affect fewer viewers, and would reduce visual effects. DRAINAGE PROJECTS AT DRY GULCH AND LAKEWOOD GULCH Improvements to a detention basin in Dry Gulch and realignment and widening of Lakewood Gulch between Decatur Street and the South Platte River would be undertaken by City of Lakewood and CCD, respectively. Photo 5 shows a view of the existing concrete lined channel and vegetation on the southern bank of the channel. Visual conditions would be enhanced by improving the drainages, restoring riparian vegetation within the stream and floodplain, and re-channelizing some areas. Photo 5 ELIMINATION OF THE MAINTENANCE FACILITY AT HARLAN STREET The maintenance facility between Sheridan Boulevard and Harlan Street and between West 11 th Avenue and the LRT alignment would be removed, and trains would be serviced at the existing Elati Maintenance Facility. This would eliminate the visual effects of the maintenance facility. WALLS AND BARRIERS The Revised Design would lower the track in various sections of the alignment. This would result in lowering or eliminating some retaining walls. The remaining walls would maintain an attractive design theme as originally proposed, resulting in a reduction of the overall visual 4-27

28 effects of the project. Compared to the PE Design, walls would be reduced in several visuallysensitive, parkland areas along Lakewood Dry Gulch. The Revised Design would include more walls at the DFC and along US 6 than assumed under the PE Design. NOISE BARRIERS As discussed in Section 4.6 of this EA, noise barriers (referred to as soundwalls in the FEIS) are proposed in certain areas along the LRT corridor (see Figure 4-3). However, property owners that determine they do not want noise barriers can opt-out of the noise mitigation. Further, property owners eligible for a noise barrier can opt for other features such as wooden privacy fences. As discussed in Section 4.5, the exact locations, lengths, and heights of the noise barriers or new privacy fences will be determined in consultation with the municipalities and neighborhood groups. Therefore, it is difficult to definitively assess visual impacts associated with noise barriers. The number of noise barriers was reduced as a result of the Revised Design. Implementation of RTD s policy for noise mitigation measures for moderate impacts further reduced the number of noise barriers proposed for the project. For areas where noise barriers are no longer proposed, the visual impact would change from a view of a noise barrier to intermittent views of a LRT train. Also, where neighborhood groups elect not to have a noise barrier constructed, the visual impact would also change from a view of a noise barrier to a view of a LRT train Mitigation Measures to mitigate for new visual effects discussed above include treating new walls and noise barriers aesthetically to soften their visual impact. This may include aesthetic treatments on the surfaces of the walls themselves or planting of landscaping. RTD will provide funds for additional landscaping and will work out agreements with local agencies and other parties for maintenance. 4.9 WETLANDS Changed Conditions The West Corridor project would require a permit under Section 404 of the Clean Water Act for impacts to waters of the U.S., including wetlands. In preparation for this permit application, a complete delineation of study area wetlands was conducted in 2006 in accordance with the 1987 U.S. Army Corps of Engineers (COE) Wetlands Delineation Manuel. The wetland delineation included mapping of wetland areas with a Trimble GeoXH Global Positioning System. Additionally, wetland functions were rated using the Carter & Burgess Basic Wetland Functional Assessment form, which is based on the Montana Wetland Functional Assessment form. On June 19, 2006, the U.S. Supreme Court issued the Rapanos decision (United States v. Rapanos, US No , 62 ERC 1481 (2006) that calls into question which wetlands will fall under COE jurisdiction. Following the Rapanos decision, the COE and Environmental Protection Agency provided new guidelines (June 5, 2007) to determine COE jurisdiction for Clean Water Act Section 404 Permits. The COE had provided a preliminary jurisdictional 4-28

29 determination for the West Corridor in its letter of December 18, 2006, (see Appendix C). The COE provided a letter dated October 2, 2007 confirming that the Lena Gulch and jurisdictional wetlands 4, 5, 6, and 7 are Waters of the U.S., and prior determinations are still valid. In comparing the 2006 delineation with the FEIS, Wetlands 1, 2, 8, and 9 identified in the original FEIS are no longer in the study area., and Wetlands 3 and 4 did not meet wetland parameters during the 2006 surveys. Wetland 5 is now termed the Lakewood Gulch and Dry Gulch system, and Wetlands 6 and 7 are now termed the Denver Federal Center wetlands. Also, the 2006 delineation includes wetlands that have been placed into the following categories: the Drainage and Agricultural Ditches (Wetland 3), Miscellaneous Isolated areas (Wetland 5), and Lena Gulch (Wetland 6). Impacts to the South Platter River wetlands (Wetland 1) were excluded because they are part of a separate river improvement project built by Urban Drainage and Flood Control District. Study area wetlands are associated with stream systems, swales, and ditches. Dominant wetland plant communities, based on the Cowardin classification system, include palustrine emergent and palustrine scrub-shrub classes (Cowardin et al., 1979). Wetlands of the palustrine system include marshes, swamps, and small ponds vegetated with herbaceous species, shrubs, and/or trees. Within the palustrine system, wetlands of the emergent class are typically vegetated with grasses, sedges, rushes, and forbs. Scrub-shrub class wetlands are vegetated with sapling trees and/or shrubs such as willows. Well-developed riparian areas are present in many areas adjacent to streambank wetlands and serve as an effective wetland buffer. For detailed information on study area wetlands and associated riparian areas, refer to the West Corridor Wetland Delineation Report (RTD, 2006). The following list groups the study area wetlands by general location, from east to west, and provides general descriptions. See Figure 4-7 and Figure 4-8 for general locations of wetlands. Lakewood Gulch and Dry Gulch Tributary: The Lakewood Gulch and Dry Gulch system extends from the confluence with the South Platte River to just east of Harlan Street. The alignment also crosses upper Dry Gulch in Ritchey Park and upper Lakewood Gulch just east of Simms Street. Wetlands are emergent and scrub-shrub streambank bands and are intermittent in areas of scour, downcutting, and fill. Emergent wetlands are dominated by reed canary grass with cattail, bulrush, rushes, and redtop. Scrub-shrub wetlands are dominated by sandbar willow with areas of peach-leaved willow. Both Lakewood Gulch and its tributary, Dry Gulch, are perennial streams. Drainage and Agricultural Ditches: Drainage ditches are present north of the proposed LRT alignment at the east end of the study area, north of West 12 th Avenue, in the northwest quadrant of the Colfax and US 6 intersections and an irrigation ditch is present north of West 8 th Avenue. Vegetation is typically reed canary grass, redtop, and/or spikerush. 4-29

30 Figure 4-7 General Wetland Locations 4-30

31 Environmental Assessment Figure 4-8 General Wetlands Locations 4-31

32 Denver Federal Center: Two wetlands are present in the portion of the study area, which includes the Denver Federal Center. A shallow swale dominated by a sandbar willow scrubshrub wetland exists just south of US 6. An emergent wetland is present in a shallow basin south of North Avenue. Dominant vegetation includes cattail with minor three-square bulrush, curly dock, sandbar willow, poison hemlock. Areas of open water were present at the time of the survey. Miscellaneous, Isolated Wetlands: Isolated wetlands are present near Lakewood Gulch, on the RTD property just east of Simms Avenue, and at the toe of the US 6 slope. These wetlands vary in vegetative diversity from cattail monoculture to a variety of rushes, sedges, and grasses. Lena Gulch: Narrow scrub-shrub wetland bands are present along the constructed channel of Lena Gulch just north of US 6. Dominant vegetation includes sandbar willow and smartweed with minor spikerush and curly dock. To support the Section 404 permit application, the project team conducted functional assessments on study area wetlands. The Carter & Burgess Basic Wetland Functional Assessment form, based on the Montana Department of Transportation s Montana Wetland Assessment Method, was used to give a basic evaluation of wetland functions for each of the six wetland groups. The Lakewood and Dry Gulch wetlands were the highest functioning wetlands of the study area and rated moderate or high in most categories (see RTD s Wetland Delineation Report for details) Changed Impacts Since preliminary design was still in progress when the FEIS was completed in August 2003, wetlands were identified, but wetland impacts were not calculated for the document. A request for final jurisdictional determination was submitted to COE in July Based on the design completed as of July 2007, permanent impacts to assumed jurisdictional and non-jurisdictional wetlands are anticipated to total 0.77 acre and 0.28 acre, respectively. Most impacts occur in the Lakewood and Dry Gulch stream system (see Table 4-7). Consistent with Executive Order 11990, the project design includes measures to avoid and minimize wetland impacts to the greatest extent practicable. Wetland Group Table 4-7 Wetland Impacts and COE Jurisdiction COE Jurisdiction Existing Area Permanent Fill Impacts Temporary Construction Impacts 1 Lakewood Gulch, Dry Gulch Yes 2.53 acres Drainage, Irrigation Ditches No 0.93 acre Denver Federal Center No Wetlands 1.43 acres Isolated, miscellaneous No 0.30 acre Lena Gulch Yes 2.00 acre Total 7.19 acres

33 On July 18, September 12, and October 6, 2007, the project team held pre-application meetings with the COE, EPA, U.S. Fish and Wildlife Service, and the Colorado Division of Wildlife. The purpose of the meetings was to review results of the delineations, discuss avoidance and minimization measures, and obtain agency input on information needed for the permit application Mitigation All impacts to jurisdictional and non-jurisdictional wetlands will be mitigated at a 1:1 ratio, including those wetlands in CDOT right-of-way. Mitigation concepts currently are being developed and discussed with regulatory agencies include restoration and creation of wetlands and upland riparian buffer adjacent to the low flow channel in Lakewood Gulch and Dry Gulch. RTD will adhere to mitigation commitments contained in the FEIS and this EA for unavoidable impacts to wetlands and to minimize erosion and sedimentation. Also, it will implement the following measures: All wetland areas and water bodies not directly impacted by the project will be protected by temporary fencing from unnecessary encroachment, or other boundary markers. Upland areas disturbed by construction will be seeded in phases throughout construction. Sediment control, such as silt fence or erosion logs, will also be used where needed to protect wetlands from sediment. Situation control devices (e.g., fences) will be placed on the down-gradient side of construction areas to prevent soil from entering wetland areas. No staging of construction equipment, equipment refueling, or storage of construction supplies will be allowed within 50 feet of a wetland or any water-related area. Standard erosion/sediment control measures will be observed and an erosion control plan will be developed prior to and for inclusion in the construction bid plans. All bare fill or cut slopes adjacent to streams or intermittent drainages will be stabilized as soon as practicable. No fertilizers, hydrofertilizers, or hydromulching will be allowed within 50 feet of a wetland or any water-related area. Work areas will be limited as much as possible to minimize construction impacts to wetlands PROTECTED SPECIES Initial research and coordination with the United States Fish and Wildlife Service (FWS) was conducted by RTD in 2002 regarding the potential presence of Ute Ladies Tresses Orchid and Colorado Butterfly Plant. No existing populations or individuals were identified during these initial surveys during the FEIS. In support of this EA, RTD conducted additional field surveys 4-33

34 for the Ute Ladies Tresses' Orchid and Colorado Butterfly plant in the study area in No populations, individual species, or areas of critical habitat were found. On July 6, 2007, RTD sent the draft report to FWS documenting results of these habitat surveys and literature reviews conducted for these species, and requesting concurrence on the findings. On July 25, 2007 RTD received a letter of concurrence from FWS agreeing with the provided habitat surveys determination that the species will not be adversely affected and provided a clearance for the project area that is valid for the next three years (see Appendix C). Black-tailed prairie dogs are a Colorado state species of special concern and any impacts to prairie dog towns would require mitigation. The LRT station proposed at the Red Rocks Community College on the south side of US 6 would impact approximately 0.6 acre of an existing prairie dog town located west of Arbutus Drive. These impacts will require a relocation permit from CDOW and implementation of mitigation measures described in Table 4-8. Water depletion in the Platte River has become a concern due to its potential adverse effects on downstream protected species, particularly species in Nebraska such as the whooping crane, least tern, Eskimo curlew, piping plover, pallid sturgeon, or western prairie fringed orchid. This project would not result in water depletions for the following reasons: Water quality ponds would be dry facilities and would release detained water within 40 hours; therefore, they would not result in discernable water loss via evaporation. Water used for dust abatement would be obtained from municipal sources that have previously undergone depletions consultations. Wetland mitigation would be at a 1:1 ratio; therefore, there would not be water loss via transpiration Mitigation Impacts to the existing prairie dog town from construction of the Red Rocks LRT station are unavoidable and will require a CDOW permit and adherence to an established mitigation plan. Impacts to black-tailed prairie dogs will be mitigated as explained in Table FLOODING AND WATER QUALITY Changed Conditions As part of the final design, more detailed hydraulic studies have been conducted than what was prepared during the PE Design. Section presents the changes in drainage design proposed as part of the Revised Design Changed Impacts The channel excavation proposed in Dry Gulch as part of the Revised Design would result in impacts to floodplains and floodways not accounted for in the FEIS. RTD evaluated the drainage design modifications, and determined that the Revised Design would: 4-34

35 Protect the LRT track in all locations from flooding. Result in floodwater running over the track in the event of a 100-year flood. This may affect operations for 45 minutes to an hour. Once the water subsides, there will be no damage to the trackway. Improve the current drainage in all areas. Would not increase flood elevations in any locations over current conditions and, in most locations, would lower flood elevations. Would improve flooding conditions at Knox Street. The existing structure at Knox Court is overtopped by almost 4 feet during the 100 year storm. The Revised Design would reduce the roadway overtopping depth to approximately 1 foot consistent with CCD drainage criteria. By raising the road profile and track elevation, the track would not be inundated in the 100-year event. As a result of the proposed construction of the Sheridan bridge, Sheridan would be elevated above the 100-year floodplain to allow for better conveyance of floodwaters through the culvert. The existing culvert can accommodate existing floodwater without overtopping, therefore this culvert would remain in place. Similarly, the floodplains would be improved to allow for the 100-year flood and for better conveyance of floodwaters under the Federal Boulevard bridge as part of LRT alignment construction. RTD will continue working with the technical staff of each of the affected agencies as the storm drainage system is designed for the West Corridor. At a minimum, RTD would follow current criteria of local jurisdictions and the Urban Drainage and Flood Control District (UDFCD) Mitigation Since the Revised Design will improve flooding and drainage conditions, no additional mitigation is required. With regard to water quality, RTD would adhere to all mitigation measures included in the FEIS. This mitigation will include adherence to existing Municipal Separate Storm Sewer Systems (MS4) requirements consistent with provisions of the Colorado Water Quality Control Act, ( et seq., CRS, 1973 as amended) and the Federal Water Pollution Control Act, as amended (33 U.S.C et seq.). RTD has an existing MS4 permit that proposes a series of actions to meet plan requirements, then documents implementation of those actions. RTD sends a report annually to the Colorado Department of Public Health and Environment (CDPHE) which describes all of its facilities, including any that have been added in the last year. As new facilities or corridors are built, RTD updates the MS4 permit to include those facilities that need to be included in the permit. Therefore, upon completion of the West Corridor project, RTD will include the new track and station platforms in their next annual report. To meet MS4 requirements, the Revised Design includes the construction of water quality extended detention basins and use of other permanent Best Management Practices (BMPs), including riprap at cross culvert outlets, channel improvements to reduce potential for stream 4-35

36 bank erosion, use of drop structures, flatter channel gradients to reduce velocities, silt fences, inlet protection, stabilized construction entrance/access, slope stabilization, ditch checks, concrete washouts, erosion logs, inlet filters, sediment basins, vehicle tracking pads, etc. All detention basins will be sized to provide 100 percent water quality capture volume based on the Urban Drainage and Flood Control District (UDFCD) design guidelines. Negotiations between the RTD, CCD, the City of Lakewood, UDFCD, and CDOT will determine maintenance responsibilities. Portions of the LRT alignment will be constructed within existing CDOT right-of-way. To meet water quality requirements along US 6 between Union Boulevard/Simms Street and Colfax Avenue, CDOT applied BMPs, consisting of nine permanent porous landscape swales located along the south side of US 6 between Simms and Indiana Streets. Since the LRT track could interfere with these swales, RTD has studied these potential effects and provided several options to CDOT to address the issue. CDOT is reviewing these options and will approve final stormwater plans for the project areas in the CDOT right-of-way. Any changes proposed to the existing BMP features constructed by CDOT will be subject to approval by CDOT HAZARDOUS MATERIALS Changed Conditions Because of the close proximity of the rerouted alignment to the previous alignment, the original Phase I Environmental Site Assessment (ESA) contained a sufficient search buffer to identify potential concerns associated with the Revised Design. Phase IIs were also done in certain locations. Changed conditions in the industrial area of La Alma/Lincoln Park are that the Colorado Department of Public Health and Environment issued a finding in March 2003 and August 2003 that no further action is required to assure that the properties in this area are protective of existing and proposed uses and do not pose an unacceptable risk to human health or the environment. This is based on their continued use as heavy industrial Changed Impacts Based on the results of the Phase II ESA work and assumptions made regarding the Phase I ESA work, the potential for the Revised Design causing a change in conditions with respect to hazardous material issues along the West Corridor appears low. The Phase I ESA investigations indicated the presence of a plume of chlorinated solvents from an industrial park close to Indiana Street. However, preliminary studies for the proposed bridge over 6th Avenue indicated that groundwater levels in this area are well below the existing ground surface and the probable bridge foundation depths. Therefore, the potential of encountering contaminated groundwater during construction appears low. 4-36

37 Two sites (the Bradley station on Sheridan and an old auto finishing business on Wadsworth) will need to have Phase II ESA work done after acquisition occurs. RTD will comply with any mitigation that is recommended as a result of this Phase II ESA Mitigation RTD will adhere to all mitigation measures contained in the FEIS PARKS AND RECREATIONAL RESOURCES Changed Conditions Since the FEIS, a disk golf course was constructed in Lakewood Dry Gulch and Sanchez parks. The course roughly parallels and is located on both sides of Lakewood Dry Gulch Changed Impacts The Revised Design would require more land from Lakewood Dry Gulch and Sanchez parks than anticipated during PE. These impacts are described in Section As part of the project design, RTD worked to alter the course layout to minimize effects to the disk golf course. However, the Revised Design will impact some existing features of the course. Also, the LRT alignment will be fenced through the park, and so will not allow players to freely cross the tracks as some currently do. Crossings will occur at designated pedestrian crossings or streets. RTD met with a representative from CCD s Parks Department to discuss project effects to the course Mitigation After construction, RTD will work with CCD Parks to restore the course, or modify it where appropriate CONSTRUCTION IMPACTS Changed Impacts The FEIS discussed the different types of impacts that would occur during construction of the LRT alternative and measures to mitigate these impacts. The Revised Design will not change the type or nature of these construction impacts, although changes in horizontal and vertical alignment would result in different areas experiencing these impacts. For example, the alignment shift to the south side of US 6 west of Indiana Street will increase construction impacts to the 6 th Avenue West subdivision and decrease impacts to the residential areas north of US 6. Also, the alignment shift near Colfax Avenue will increase construction impacts to the Mountainside Estates MHP Revised Mitigation Mitigation options outlined in the FEIS/ROD have not changed. 4-37

38 4.15 SECTION 4(f) EVALUATION The FEIS includes a Section 4(f) Evaluation consistent with Title 49 U.S.C. Section 303. The Revised Design will result in changed project actions to several of the Section 4(f) resources included in that evaluation. As discussed in Section 4.6, the Revised Design will include relocation of a drainage ditch on three historic properties along 13th Avenue: the International Style House, the Kit House, and the 1918 Farmhouse. Since the drainage ditch relocations on these properties will not permanently incorporate that property into a transportation facility, consistent with FHWA/FTA Regulations at 23 C.F.R (p), these drainage impacts will not constitute a Section 4(f) use. The Revised Design will result in minor (not adverse) impacts to three Section 4(f) resources the International Style House, Lakewood Dry Gulch, and Paco Sanchez Park. These impacts, and the FTA s intent to make de minimis findings for these impacts, are discussed in the following sections. The Revised Design will not change the proposed use or impacts to other Section 4(f) properties described in the FEIS De Minimis Provisions Since issuance of the ROD in 2004, Congress amended Title 49 USC 303, also know as Section 4(f) when it enacted the Safe, Accountable, Flexible, and Efficient Transportation Equity Act: A Legacy for Users (Public Law , enacted August 10, 2005) (SAFETEA-LU). Section 6009 of SAFETEA-LU added a new subsection to Section 4(f), which authorizes the Secretary of Transportation (FTA) to approve a project that uses Section 4(f) lands that are part of a historic property, or park, recreation area, or wildlife or waterflow refuge without analysis of feasible and prudent avoidance alternatives, if it makes a finding that such uses would have de minimis impacts upon the Section 4(f) resource, with the concurrence of the relevant SHPO for historic properties or official with jurisdiction (OWJ) over the park, recreation or wildlife or waterflow refuge. In order to clarify the language in SAFETEA-LU, the FTA has required compliance with the following procedures in order for the impacts to parks, recreational resources, and wildlife or waterfowl refuges to be considered de minimis: 1. The transportation use of the Section 4(f) resource, together with any impact avoidance, minimization, and mitigation or enhancement measures incorporated into the project, does not adversely affect the activities, features, and attributes that qualify the resource for protection under Section 4(f); 2. The official(s) with jurisdiction over the property are informed of FTA s intent to make the de minimis impact finding based on their written concurrence that the project will not adversely affect the activities, features, and attributes that qualify the property for protection under Section 4(f); and 4-38

39 3. The public has been afforded an opportunity to review and comment on the effects of the project on the protected activities, features, and attributes of the Section 4(f) resource International Style House (5JF2873) SITE DESCRIPTION The International Style House (5JF2873) is a property eligible for the National Register of Historic Places (NRHP) (Section 4.6.1). It is located at 1290 Pierce Street, at the southeastern corner of the intersection between 13 th Avenue and Pierce Street It is a one-story International Style (Art Deco Moderne) house built in 1940 as part of the original Lakewood Subdivision. The International Style House (5JF2873) is eligible for the NRHP under Criterion C (embodies the characteristics of a type, period, or method of construction, or represents the work of a master, or that possess high artistic values, or represents a significant and distinguishable entity whose components may lack individual distinction). The area of significance that makes this historic property eligible for the NRHP is architecture. IMPACTS The Section 4(f) evaluation in the FEIS indicated that approximately 15-feet of right-of-way on 13 th Avenue might be required from the International Style House for widening of 13 th Avenue. The Revised Design indicates that additional right-of-way (0.004 acre) is needed along Pierce Street from the northwest corner of the property. This right-of-way is required to: Provide adequate turning radius for emergency vehicles at the intersection of 13 th Avenue and Pierce Street. Provide adequate room for construction of the LRT Alternative, which includes the installation of quad gates at the at-grade crossing at Pierce Street. Pierce Street would be a through street and, therefore, require gates for crossing safety. To accommodate the quad gates, the Revised Design for 13 th Avenue will bow to the south at Pierce Street, necessitating the additional right-of-way. It will require conversion of 196 square feet (0.004 acres) from the northwest corner of the property to transportation use (see Figure 4-9). In its most recent effect determination for the International Style House, FTA determined that decreasing the lot size by a small percentage on the very outskirts of the lot will not diminish the building s National Register qualities. FTA determined that, since the proposed project actions would not affect the architectural significance of the building (the characteristic that makes the historic property eligible), a finding of no adverse effect would be appropriate for this resource for purposes of Section 106 of the NHPA. The Colorado SHPO concurred with this determination in its letter of October 25, 2006 (see Appendix C). The SHPO was notified that FTA intends to classify this impact as de minimis. 4-39

40 Figure 4-9 International Style House (5JF2873) 4-40

41 Based on the no adverse effect finding, as described in the paragraph above, and taking into consideration the minimization measures that have been incorporated into the Revised Design (see Section ), FTA believes the proposed action would have de minimis impacts on the International House and that an analysis of feasible and prudent avoidance alternatives under Section 4(f) is not required Paco Sanchez Park SITE DESCRIPTION Paco Sanchez Park is a City of Denver park located directly west of Rude Park. Paco Sanchez Park is bounded by West 12th Avenue on the south West Avondale Drive on the north, Federal Boulevard to the east and Knox Court to the west. In 1973, Denver City Ordinance designated the 30.5-acre property as a park. The most notable features of the park include Lakewood Gulch flowing west to east through the park, the existing rail tracks parallel to the gulch, and the view of the downtown Denver skyline from the southern edge of the park. The park is characterized by fairly steep slopes to the gulch at the eastern edge of the park, with less steep slopes toward the west. Approximately 10 acres of Paco Sanchez Park are in the Lakewood Gulch floodplain. The north side of the park has two parking areas, a playground, a softball field, and a picnic area. The south side of the park has two basketball courts. The D-10 bicycle path continues to follow Lakewood Gulch through Paco Sanchez Park. A paved path crosses the gulch and the existing railroad right-of-way about 200 yards west of Federal Boulevard and connects to the D-10 bike path. IMPACTS The Section 4(f) evaluation in the FEIS stated that the LRT alignment will require a 0.2-acre property acquisition (less than 1 percent of park) from Paco Sanchez Park in addition to the 2.46 acres of right-of-way already owned by RTD. It also indicates up to an additional 4 acres of parkland might be required during construction. In addition, a barrier will separate the LRT from the park and eliminate the free north-south pedestrian access across the park that currently exists. The Revised Design will require an approximate 0.16 acre of additional right-of-way from Paco Sanchez Park for a total of 0.36 acre, which is the 0.2 acre from the original design plus the 0.16 acre of additional right-of-way needed from the Revised Design. There is a need to veer slightly south from the former alignment through Paco Sanchez Park, particularly east and west of Tennyson. This is largely due to efforts to avoid and minimize wetland and stream impacts just north of the former alignment. See Figure 4-10 for a map showing the park impacts. FTA has determined that the impacts to Paco Sanchez Park do not adversely affect the activities, features, and attributes that qualify the resources for protection under Section 4(f). At a public meeting held on July 18, 2007, the public was afforded an opportunity to review and comment on the effects of the project. There were seven comments received relating to the impacts to Paco Sanchez Park and Lakewood Dry Gulch. Five of the comments did not have an issue with 4-41

42 Figure 4-10 Paco Sanchez Park 4-42

43 the proposed impacts and thought that the minimization efforts are sufficient. One comment was concerned about access to both sides of the park that are separated by the tracks, and one comment felt that any project through a park would have adverse impacts. At a meeting on July 25, 2007, RTD met with a representative from the CCD Parks Department to discuss the increased impacts. The CCD representative indicated he did not believe the increased impacts were adverse. FTA notified the Parks and Recreation Manager (the official with jurisdiction) of its intent to make a de minimis determination in a letter dated July 24, 2007 (see Appendix C). Based on these actions and correspondence, and taking into consideration the harm minimization measures that have been incorporated into the proposed action as documented in this Section 4(f) Evaluation, FTA believes the proposed action would have de minimis impacts on the park and that an analysis of feasible and prudent avoidance alternatives under Section 4(f) is not required. Therefore, FTA has made a finding of de minimis and the CCD Parks Department has concurred, as included in Appendix E Lakewood Dry Gulch SITE DESCRIPTION Lakewood Dry Gulch Park is located immediately west of Paco Sanchez Park and is approximately 47 acres. The CCD plans to dedicate this area as a park upon completion of the LRT project. It was considered a Section 4(f) resource in the FEIS. The property is bordered on the east by Knox Court on the west by Sheridan Boulevard, on the south by West 10 th Avenue from Knox Court to Perry Street, and by West 11th Avenue from Perry Street to Sheridan Boulevard. The northern border varies from West 13th Avenue at Knox Court, to West 12th Avenue at Perry Street, and to Wells Place at Sheridan Boulevard. Lakewood Dry Gulch Park is characterized by sloping terrain down to the gulch through most of the park. Approximately 20 acres of the park lie in either the Lakewood Gulch or Dry Gulch floodplain. The relatively steep terrain of the park makes it unsuitable for most recreational purposes; thus, it provides passive use and urban green space. There are three developed playgrounds in the park at Osceola Street and Vrain Street on the south side of the park, and at Utica Street on the north side of the park. The paved D-10 bike path (the Lakewood Dry Gulch Trail) continues through this park. A second paved path follows along the northern side of the park, but is not continuous. This northern path crosses the existing railroad right-of- way approximately 100 yards west of Perry Street. Informal trails cross the park (and the rails) near Stuart and Tennyson Streets. IMPACTS The Section 4(f) evaluation in the FEIS stated that the LRT alignment and three stations at Knox Court, Perry Street and Sheridan Boulevard would partially be located within the park boundaries and require a 0.3-acre property acquisition (less than 1 percent of park) in addition to the 7.81 acres of right-of-way already owned by RTD. It also indicated up to an additional 13 acres of parkland may be required during construction. The existing pedestrian/bike paths will be realigned to avoid LRT crossings, but will be continuous on either side of the LRT track and 4-43

44 designed to connect to LRT stations and safe crossings of the LRT and the gulch. A new pedestrian/bike connection under the alignment at Meade Street and new pedestrian/bike bridges over the LRT at Tennyson and Wolff Streets will be constructed. The existing pedestrian/bike crossing of the right-of-way at Newton Street may be removed. RTD will revisit this potential closure during final design. For more detailed information about the bike path design (see Section 3.6). In addition to the impacts mentioned above, a barrier will separate the LRT from the park and eliminate the free north-south access across the park that currently exists. The park improvements planned by the CCD incorporated the LRT project and the three stations located in this park. These improvements are documented in the technical report Lakewood Dry Gulch Park Concept Plan, 2003 prepared by Shapins Associates. As discussed in Section , the Revised Design will impact several holes of an existing disk golf course in the park. The course layout will be modified and restored after construction and, therefore, will not be adversely affected. The Revised Design will require an additional 2.4 acres of the park for a total of 2.7 acres due to the need to veer slightly south from the former alignment through Lakewood Gulch, particularly east and west of Tennyson. This is largely due to efforts to avoid and minimize wetland and stream impacts just north of the former alignment. In addition, the Revised Design includes the replacement of walls and steeper fill slopes with gentler slopes. These gentler slopes reduce project costs considerably, and will improve the park over PE Design since the slopes can be revegetated more easily and better lend themselves to recreational activities. Also, the removal of the walls will reduce visual impacts that would have disturbed the park setting and feel. A finding of de minimis has been made by FTA and the CCD Parks Department has concurred, as documented in Appendix E. Based on these actions and correspondence, and taking into consideration the harm minimization measures that have been incorporated into the proposed action as documented in this Section 4(f) Evaluation, FTA believes the proposed action would have de minimis impacts on the park and that an analysis of feasible and prudent avoidance alternatives under Section 4(f) is not required. See Figure 4-11 for a map showing the park impacts Measures to Minimize Harm In general, RTD has attempted to minimize impacts to the historic resource and parks in its project design. The Revised Design minimizes impacts to the International Style House by reducing the proposed width for 13th Avenue to 20-feet wide, which is below the 24-feet minimum roadway width standard for a two way street. RTD negotiated this width with the City of Lakewood and the West Metro Fire Department, which was established as a minimum for 13th Avenue to accommodate fire safety requirements. 4-44

45 Figure 4-11 Lakewood Dry Gulch 4-45