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Partial DRAFT Response to

Questions Submitted by C!TRAN Board

May 14, 2013 Special Meeting

May 13, 2014

Note: Responses to some questions are still under

development and will be provided when completed.

City of Washougal ! Connie Jo Freeman

1. Is "light rail" required to obtain federal funding, or will "bus rapid!transit" suffice?

Local project sponsors unanimously selected light rail as the preferred option in 2008 because the

benefits were greater than other options studied, including bus rapid transit. Changing the LPA to

include bus rapid transit would require agreement from the project’s partners in Washington and

Oregon. If that agreement was reached, CRC would need to describe the design changes and the

associated environmental impacts in a re!evaluation document. The Federal Transit Administration

(FTA) and Federal Highway Administration (FHWA) would review the document and decide a course

of action. If the re!evaluation finds no new significant impacts, FTA and FHWA would amend the

Record of Decision and the project proceeds. If a change to the preferred alternative results in new

and significant impacts, a supplemental EIS is required. A supplemental EIS would likely require 12 to

24 months to complete.  

If an agreement was reached to change the LPA to include bus rapid transit, the New Starts Full

Funding Grant Agreement (FFGA) would be delayed because it cannot be awarded without a current

Record of Decision. A new grant application would be submitted, which FTA would re!evaluate. With

a 12 to 24 month schedule delay, FTA has stated that federal funds may not be available for the CRC

Project.  See question 11 for more information.


2. Do the stops meet the criteria for ½ mile employment requirement? [CTRAN]

Yes. FTA Administrator Peter Rogoff wrote a letter dated July 24, 2012, related to this issue, stating

that “local project sponsors have provided sufficient documentation to FTA that demonstrates that

the light rail transit stations proposed as part of the CRC project are reasonably located within a

one!half mile radius of the employment areas…”


City of Vancouver ! Larry Smith

3. Question on timing ! is it necessary for the operations and maintenance funding plan to be in

place by October 2013?  

A New Starts agreement requires all capital funds and operations and maintenance funds to be

identified and committed, including state equity funds and tolling authorization. The Finance Plan

assumes application for the grant by October 2013, with FTA grant funds committed in the second

quarter of 2014. FTA has said there is less certainty for New Starts funding after 2013, and CRC is

one of a few projects at the top of the list.



DRAFT – 5/13/13                   Page 1 of 29  

Clark County ! Tom Mielke

4. Will TriMet receive the farebox revenues in addition to the $2 million they would be paid to

operate light rail?  

It is assumed that C!TRAN will receive farebox revenue from the light rail transit trips that begin

in Vancouver and TriMet will receive farebox revenue for the trips that begin in Portland.  

Please refer to question 27 for more information about cost sharing between C!TRAN and TriMet for

operations and maintenance of light rail.


C!TRAN/ATU ! Roy Jennings

5. What is the projected cost to C!TRAN for wages and fuel due to traffic congestion if the

replacement bridge is not built?  

Based upon Alternative 4 of the C!TRAN 20 Year Plan that assumes no replacement bridge but an

aggressive financially constrained budget for bus service, the operations and maintenance costs for

express service is expected to reach approximately $15,220,000 per year in 2030 dollars (inclusive of

inflation). However, traffic congestion is expected to continue to raise costs more than what projected

funding can accommodate and the projected express service levels will likely be reduced as travel times

continue to increase.  

Cities of La Center/Ridgefield ! Jim Irish

6. Show a representative year when tolls were levied on the existing bridges and compare to CRC

estimates for proposed tolls.  

It is difficult to draw direct comparisons between the cost of tolls levied on the I!5 bridge between 1917

and 1929 and 1958 and 1966 with today’s dollars. However, the following comparisons were made using

the U.S. Bureau of Labor Statistics online Consumer Price Index Inflation calculator:

  Tolls were collected on the first bridge from 1917!1929. The toll was $0.10 for a vehicle and

driver. According to the BLS, the ten!cent toll levied in 1917 would have the equivalent buying

power of $1.82 in 2013. A $0.10 toll in 1929 is the equivalent of $1.36 in 2013 dollars.

  Tolls were collected on the second bridge from 1958!1966. Tolls were $0.20 for cars and $0.40

to $0.60 for trucks. Using the same calculator, the $0.20 toll in 1958 would be $1.61 in 2013

dollars, and $1.44 when comparing the 1966 value. For larger vehicles, the original $0.40 to

$0.60 toll in 1958 would have the equivalent buying power in 2013 of $3.22 to $4.83. In 1966,

this range would have the equivalent buying power of $2.87 to $4.31 in 2013 dollars.

  For the Final EIS, the range of one!way toll rates studied for the financial analysis was $1 to $3

(2006 dollars, see Exhibit 4.3!3 from the FEIS).  Assuming a 2.5 percent annual inflation rate, this

range in 2013 dollars would be $1.19 to $3.57.


Please note that the CPI Inflation calculator was used to calculate current dollar year figures for toll rates

specific to the 1917 and 1958 I!5 bridges. The calculator was used for all years up to 2013.


Toll analysis for the project has been based on toll rate schedules in 2006 dollars which, when escalation

was necessary, were escalated at 2.5% per year. The assumed  toll  rate provided in 2013 dollars  is not

calculated using the CPI Inflation calculator.


The  CPI  Inflation  calculator  escalation  between  2006  and  2013  does  not  exactly  match  this  2.5%

assumed  escalation  rate  used  in  project  tolling  analysis.  Because  the  2.5%  escalation  rate  has  been

assumed in analysis and is the basis for toll rates analyzed, it is continued here.  

DRAFT – 5/13/13                  


7. Provide the number of people crossing southbound on both the I!5 and I!205 bridges daily and

during peak hours.*(updated )

The latest data we’ve prepared for southbound peak period traffic is that reported in the FEIS Traffic

Technical Report. That provides southbound data  for a 2!hour AM peak on  I!205 and  for a 4!hour

AM peak on I!5. These figures are as follows:

  I!5 vehicle demands (4!hour AM peak) = 26,300

  I!205 vehicle demands (2!hour AM peak) = 17,745

For 2012, we have average weekday traffic (AWD) volumes on I!5 and on I!205.  

 2012 AWD on I!5 is 128,400 vehicles (rounded to the nearest hundred).  

 2012 AWD on I!205 is 145,400 vehicles (rounded to the nearest hundred).

8.  Could the CRC project proceed as planned with the bridge simply LRT ready?

No. Building the project without light rail would not meet the project’s purpose and need, as

documented in the analysis performed under the National Environmental Policy Act (NEPA) and

approved in the federal Record of Decision.  

Clark County ! Steve Stuart

9. What would be required procedurally (including potential time, additional approvals and from

who, and analysis required) for FTA to switch funding for CRC high capacity transit from LRT to

BRT (or if it would be even allowed)? *(updated)

Bus Rapid Transit was studied and not selected because light rail performed better. Going back and

choosing a different high capacity transit mode would first require agreement by the project’s

partners in Washington and Oregon to initiate the change. The agreement reached by project

sponsors and stakeholders on the current LPA occurred over a six year period between 2005 and


Amending the LPA requires describing the design changes and the associated environmental impacts

in a NEPA re!evaluation document. FTA and FHWA would review the document and decide on a

course of action. If the re!evaluation finds no new significant impacts, FTA and FHWA would amend

the Record of Decision and the project proceeds. If a change to the preferred alternative results in

new and significant impacts, a supplemental EIS is required. A supplemental EIS would likely require

12 to 24 months to complete, depending on the scope and degree of environmental and public

involvement required.  

The New Starts Full Funding Grant Agreement would be delayed until completion of the

supplemental EIS because it cannot be awarded without a current Record of Decision. A new grant

application would be submitted, which FTA would re!evaluate. With a 12 to 24 month schedule

delay, FTA has stated that federal funds may not be available for the CRC Project.


DRAFT – 5/13/13  


10. I would like an explanation of what an MOS (minimum operational segment) is, and how the Clark

College terminus was determined to be that?

A minimum operable segment (MOS) is defined in the FTA New Starts program as the shortest of

alternative segments considered for a high capacity transit project. The MOS must remain effective

as a stand!alone project, attracting riders but minimizing costs. FTA urges consideration of one or

more minimum operable segments as separate alternatives.


The four potential terminus options in the draft EIS (Clark College MOS, Mill Plain MOS, Kiggins Bowl

Terminus, and Lincoln Terminus) were each analyzed with one representative park!and!ride lot

configuration unique to its alignment and terminus. The costs, transit ridership estimates, cost!

effectiveness, and environmental consequences for each alternative are documented in the draft EIS

and final EIS. Detailed findings can be found in the Transit Technical Report and appendices.


In July 2008, the Vancouver City Council and C!TRAN Board of Directors, along with the boards and

councils of other regional partners, endorsed a LPA with a terminus at Clark College, following a 60!

day review period, public hearings and the recommendation from the 39 member CRC Task Force.


City of Vancouver ! Tim Leavitt

11. Explain why the CRC LPA decided on light rail transit (LRT) as the preferred high capacity transit

mode instead of bus rapid transit (BRT).  

Light rail was selected over bus rapid transit by the Vancouver City Council, C!TRAN Board,

Southwest Washington Regional Transportation Council, Portland City Council, TriMet Board, Metro

Council, and the bi!state CRC Task Force for the following reasons:  

 Light rail will travel faster than bus rapid transit within the project area (averaging 17 mph

versus 14.5 mph, including stops) because it will have signal priority, shorter wait times at

stations, and quicker acceleration. Bus rapid transit would travel in exclusive lanes, but would be

mixed with general traffic on local streets outside the project area, and would be delayed due to

congestion in those areas.  

 Light rail has more capacity and will carry 6,100 people over the I!5 crossing northbound during

the peak period, while the alternatives with bus rapid transit would only carry 5,150 to 5,350


 Integration with the existing system will allow transit users to travel between Vancouver and

Portland without a transfer. Transfers add travel time and decrease trip reliability and


 Operation and maintenance costs for light rail are 25 percent lower per rider compared to bus

rapid transit due to the need for more drivers on more buses.

The locally preferred alternative was endorsed by FHWA and FTA in the Record of Decision.



DRAFT – 5/13/13                 

Clark County ! David Madore  

1. How many pages comprise the FEIS. How long would it take the average person to read all of


The FEIS with full appendices is approximately 1,400 pages. It includes a 39 page summary which

provides a meaningful explanation of the project, its impacts and mitigation. The time it takes to

read these documents has not been estimated.  

History and LPA Selection

2. Provide a concise definition of the LPA that received the ROD. Should a SEIS be done due to the

significance of the change of scope, phasing, and basic financing changes made since the ROD?

There has been no change to the LPA as identified in the ROD, nor have there been significant

changes to the financing plan.


The full build LPA, is described on pages 1 and 2 of the ROD includes:

  A new river crossing over the Columbia River and I!5 highway improvements.

  Improvements to seven interchanges, from south to north: Victory Boulevard, Marine Drive,

Hayden Island, SR!14, Mill Plain, Fourth Plain and SR 500. Related enhancements to the local

street network.

  Improvements to the existing I!5 mainline bridge over North Portland Harbor

  A variety of bicycle and pedestrian improvements throughout the project corridor.  

 Extension of light rail transit from the Expo Center in Portland to Clark College in Vancouver

and associated transit improvements.  

 Transportation demand and system management measures to be implemented with the

project, including the use of tolls.


As the co!federal leads, FTA and FHWA will determine if a supplemental EIS should be produced for

the project if any changes are made. To date, a supplemental EIS has not been deemed necessary.

The final EIS indicated that due to funding constraints the LPA may be phased and that actual

phasing would not be known until the timing and availability of funds are finalized, which would

occur sometime after the ROD.


3. Does the Federal Government require LRT on a replacement bridge for the I5 crossing?

See response to question 5.


4. Does the Federal Government require "high capacity transit" on a replacement bridge for the I5


See response to question 5.

DRAFT – 5/13/13

5. Does the Federal Government require any transit (beyond buses in mixed traffic) on a

replacement bridge for the I5 crossing?

Local project sponsors selected light rail as the preferred option in 2008 because the benefits were

greater than other options studied, including BRT. See question 1 by Ms. Freeman and question 11

by Mr. Leavitt for more information.


Federal requirements (23 CFR Part 450) require planners analyze alternatives including transit prior

to expansion of single occupancy vehicle travel facilities.  

From the outset, the public and local agencies were involved in crafting the project’s Vision and

Values Statement and Purpose and Need Statement. Both documents identify limited transit options

and poor transit reliability as one of the six elements project designs must address. Subsequently, all

six local agency partners—including the City of Vancouver, Southwest Washington Regional

Transportation Council, C!TRAN, City of Portland, Metro and TriMet—unanimously agreed in June

2008 on the overall project components, including light rail as the transit element. The process to

select the LPA and was validated by FTA and FHWA in 2011 with the Record of Decision.


6. The latest version of this project eliminates four freeway interchanges and the entire SR!500

interchange for this phase. Call this the LPA2. Provide a map showing the LPA2 components and

the cost of each basic section.

See response to question 9.


7. Who authorized the changes that changed the LPA to the LPA2?

See response to question 9.


8. Did the project sponsors authorize the changes that converted the LPA to the LPA2? Which

sponsors? Provide documentation showing the authorization from each project sponsor.  

See response to question 9.


9. Did the staff notify the project sponsors? If so, provide copies other notices and information

detailing the communication to each one.

The CRC project has not made changes to the Locally Preferred Alternative. The LPA and the process

to select it was approved by the FTA and FHWA in the Record of Decision in December 2011.  

10. Does the CRC staff recognize the authority of the project sponsors to approve or disapprove such

changes? If so, what authority do the project sponsors retain? Define the present definition and

authority of the project sponsors.

In process.


11. Do the project sponsors retain the authority to stop this project by withdrawing their support or

by objecting to unauthorized changes by the CRC staff

In process


DRAFT – 5/13/13                  !"#$ . &' %(




12. Since the CRC staff changed to the LPA2, has the staff also obtained authorization from and

informed the FHWA, ODOT, WSDOT and both state governors of those changes?

Please refer to the response in questions 6!9 above.


Cost, Finance and Funding

[Project Costs]

13. Provide the projected costs for the parking facilities.

Based on 2010 estimates, the total cost range for the three park and ride structures is $158 million

to $176 million in year of expenditure dollars. This cost range includes design, construction and

accounts for risk and inflation. It does not include the cost of acquiring property. It’s important to

note that these costs are specific to the CRC project. The range includes some allowances for mixed

use development on the ground floor and architectural treatments, as per the recommendations of

a CRC advisory committee and requirements of the City of Vancouver.


14. Provide the projected costs for the toll collection facilities.

Tolling implementation costs cover initial planning efforts; design and procurement of tolling equipment

and  infrastructure;  installation  and  testing  of  tolling  equipment  and  infrastructure;  customer  service

center modifications  and  additional  facilities  locally  for  customer  service  and  administrative hearings;

and, communications and public education. The project’s cost estimate  includes $45 million  for  tolling



15. Provide the projected costs to collect the tolls (gross verses net revenue).

The development of net toll revenue estimates from gross toll revenue estimates accounts for more

than just the cost to collect tolls. First, adjustments are made to incorporate non!account fee revenue,

rebilling fees, self!initiated payment costs, and adjustments for uncollectible revenue.  

Then, deductions are incorporated for collection costs. Collection costs include operating and

maintenance expenses for toll collection equipment, customer service center functions, centralized

state operations costs and credit card fees associated with processing electronic transactions. Toll

collection costs are estimated to reflect the nature of the cost, e.g. statewide collection activity costs

may be estimated on a per transaction basis to proportionately share these costs between facilities

based on their relative usage of these statewide activities. Toll collection cost ranges for the preliminary

scenarios are estimated as follows:


  $15M ! $21M in fiscal year 2022, the first year after completion of the facility

  $33M ! $39M in fiscal year 2040, outer year with established revenue and traffic  

In addition to toll collection costs, routine annual facility operations and maintenance (e.g. incident

response, mowing, snow removal, striping, litter pickup), and insurance premiums for coverage of the

physical structure of the bridge as well as business interruption (loss of revenue) are also allocated

before deriving net revenues.



DRAFT – 5/13/13                  !"#$ / &' %(


16. What are the costs for each of the major basic components of the project? Each interchange, the

bridge, each parking facility, total light rail costs?


Columbia River Bridges, including approaches – $1.2 billion

Deck truss structure that includes the landings for mainline I!5 on both sides of the river. The limits for

the landings extend approximately 3,600 feet into Oregon on Hayden Island, and approximately 4,600

feet into Washington in Vancouver.


Oregon ! Marine Drive Interchange – $325 million

Improvements include a single point urban interchange to increase mobility through the interchange

and onto I!5 directly in both directions (north and south).   

Oregon ! Hayden Island Interchange and connector – $270 million

Improvements include full interchange ramps to access Hayden Island and a new structure/bridge to

connect Hayden Island to the improved Marine Drive interchange.  

Washington ! SR 14 Interchange – $250 million

Improvements include the connection to the major east/west state route in Washington at the north

shore of the Columbia River.  

Washington ! Mill Plain – $80 million

These improvements include upgrading the Mill Plain and I!5 interchange to allow for more vehicular

and freight capacity to move through the interchange.  This interchange is the primary access point to

the Port of Vancouver.


Washington ! Fourth Plain – $100 million

This interchange is an alternate freight access point for the Port of Vancouver, and is also the primary

interchange connection to the light rail terminus park and ride (Clark College).  Some capacity

improvements are planned at this interchange to accommodate those uses.


Light rail transit – $820 million

Improvements include extending the MAX Yellow Line from the Expo Center in the Marine Drive area of

Oregon to the Clark College park and ride terminus in Vancouver (3 miles). The light rail will share two

major structures, the mainland connector, and the southbound (western!most bridge) Columbia River

bridge. The costs includes track, stations, three park and rides, light rail vehicles, modifications to a

maintenance facility and operations center and modifications to the Steel Bridge. Park and ride costs are

$158 to $176 million. Capital construction is funded by an $850 million FTA New Starts grant which can

also include a portion of the bridge structure costs estimated at $1.2 billion. The FTA finance plan

identifies $925 million of light rail costs that are transit eligible.  

17. Provide the total debt service payment schedule (principal and interest) for each year until the

debt is repaid in full that will cover all debt for this project.  

The total amount of debt service for the project depends on the funding contributions and bond

authorizations to be enacted by the Oregon and Washington legislatures, and is consistent with the

delivery of other state transportation projects. Attachment A provides preliminary estimates of the

debt service for toll bonds under several scenarios.   

18. Provide the total cost for this project including all finance costs, interest rates, and interest to be

paid for the life of for each loan.

Direct design and capital construction costs are provided in response to question 16. Attachment A

provides estimates of finance!related costs associated with toll bonds and TIFIA loans for several


DRAFT – 5/13/13                  !"#$ ( &' %(


different scenarios. As stated in response to question 17, the debt service for the state contributions

depends on future decisions regarding funding contributions and bond authorizations to be enacted

by the Oregon and Washington legislatures.


19. On February 19, 2013 Tiffany Couch asked for the Base Cost Estimate that would support the costs

Kris Strickler testified about in Oregon, regarding a modified CRC project. See attached email. On

March 20th, Ms. Couch received the following email indicating that a Base Cost Estimate for a

more modified project cost did not exist, instead she was given a different document, not

responsive to her request. It appears that the $2.8B projection being testified about matches the

same modified project as per the November 2012 FFGA application (see attached). Wouldn’t a

base cost estimate be necessary in order to then fill out the attached FFGA application? Please

provide the Base Cost Estimate for the modified proposed project.


There has been no change to the LPA. The base cost estimate for the initial construction program

identified in the 2012 New Starts update was provided in the table delivered to Ms. Couch. (See

Column 5.)  

The following project elements were identified in the New Starts application as those that need to

be constructed first to achieve significant transportation benefits and are necessary to operate the

light rail system:  

 The new river crossing over the Columbia River and the I!5 highway improvements, including

improvements to three interchanges (Marine Drive, Hayden Island and SR 14/City Center), as

well as associated enhancements to the local street network.  This includes 4th Plain

interchange improvements needed to support the light rail system.  

 Extension of light rail from the Expo Center in Portland to Clark College in Vancouver, and

associated transit improvements, including transit stations, park and rides, bus route and

station changes, and expansion of a light rail transit (LRT) maintenance facility.

  Upgrades and modifications to the Steel Bridge and transit command center.

  Purchase of 19 light rail vehicles (LRV), public art and other transit!related procurements.

  Bicycle and pedestrian improvements throughout the project corridor that connect to the

transit system.  

 Toll system for the river crossing.

  Transportation demand and system management measures to be implemented with the



20. Attached is the summary of the CRC’s base cost estimate, the actual base cost estimate from

which the summary is derived, as well as the maps you often share with legislators and public

officials reporting the costs of the project. According to your CEVP report, the Base Cost Estimate

is the cost of the project before it is escalated for risk and inflation.

a. Why are the costs of the interchanges for Oregon and Washington, per your Base Cost

Estimate, MORE than the maps you are showing legislators?  

b. When you escalate the costs of the Oregon and Washington interchanges from this Base

Cost, won’t the disparities between the actual costs and what you are reporting on your

map be greater?

c. If the project costs are now different than the ones shown, please provide the current


The provided base cost estimate summary allocating cost to various project elements was not

developed by the project and inaccurately assigns project costs. Costs may have simply been

allocated based on their titles, without an understanding of their relationship to the project design

(e.g. whether a line item related to the river crossing and approaches versus an interchange).

Detailed assumptions underlying the summary are not shown.  

The current project cost estimate, in escalated, year of expenditure dollars including risk and

inflation, includes $595 million associated with Oregon roadway and interchange improvements,

$435 million associated with Washington roadway and interchange improvements, $1.2 billion for

the replacement bridge and its approaches on both sides of the river, and $820 million for light rail

transit extension. Capital construction is funded by an $850 million FTA New Starts grant which can

also include a portion of the bridge structure costs estimated at $1.2 billion. The FTA finance plan

identifies $925 million of light rail costs that are transit eligible.


21. The newly revised project, as per the attached FFGA application is a deviation from the Record of

Decision approved in December 2011. Who approved a project that deviates from the FFGA


There has been no change in the project description as described in the final EIS and ROD.


22. Per the FEIS and the current CRC plan shown in the following link, please provide the available

detail including the document section, page number and line number referenced that provides the

following basic information:  

Chapter 2 of FEIS includes a project description and sequencing plan description. Section 2.1, p. 2!4

to 2!5 includes a description of the project’s LPA and the potential for phasing construction.  

23. There is a contradiction between the latest document that the CRC submitted (attached) to the

FTA and the letter from Amy Grotefendt, of ODOT, speaking on behalf of the CRC staff, to Clark

County Commissioner Steve Stuart on April 19, 2013. That letter says "There have been no

changes to the project definition." The letter goes on to claim that nothing else has changed. The

latest document submitted to the FTA says in bold type "Significant Changes Since Last Evaluation

(November 2011): The project's capital cost decreased from $3,507.87 million to $2,796.91 million

per a local decision to implement the project in phases." The initial phase will include all project

elements required to make the LRT, highway, and tolling facility fully functional. Improvements at

four highway interchanges, as well as the entire interchange at State Route 500, will be deferred."

Since no funding is provided for anything that is deferred, the effect is to effectively delete all

work except that which has not been deferred. Unless the project is funded and built as previously

approved by the Record Of Decision, claims that the deferred (deleted) interchanges are

disingenuous. Provide a clear compelling answer that reconciles these inconsistencies.

Deferral or phasing of elements of the CRC project is a function of funding. The Washington

Legislature is currently considering a transportation package that would provide construction

funding for the Washington portion of the CRC project. The Oregon Legislature and Governor have

already approved state funding for the Oregon portion of the CRC project.  


DRAFT – 5/13/13                  

Elements described in the New Starts application include the minimum number of improvements to

be included in the first sequence of the project construction, while maintaining eligibility for federal

transit funding. The construction program described in the New Starts application does not dictate

phasing for other elements of the project as described in the ROD. The FTA Full Funding Grant

agreement (FFGA) is only one source of funding needed to complete the full scope of the project as

defined in the ROD. The local funding provided by both state legislatures and other Federal Aid

Highway funds provided by FHWA will complete the full scope of the project.

Read the rest of the answers in the PDF:

PDF of CRC’s answers

In May 2013 the C-Tran Board of Directors submitted a number of questions to the CRC.

Here are the first few answers, with the complete set answers in this PDF.

CRC’s answer to C-Tran   Comments on CRC’s answer   Trimet’s projections accuracy   Correcting false claims about the CRC