Friday, April 9, 2021
Povertyville Section of Vermont--Time for Historic Burlington-Winooski Axis Urban Renew to String of Pearls?
4/9/2021 Draft Burlington-Winooski, the Two Centuries Old Historic Economic Axis Engine Declines to Vermont’s Povertyville Section—Ready for Renewal from the 1980-to-Date Devolution towards a String of Urban Pearls for the 21st Century? …A future Burlington-Winooski as a Shining 15-Minute Shangri-La Urban Corridor “The gods of the valleys are not the gods of the hills” Ethan Allen 1770 “There must be a radical redistribution of political and economic power in this nation and in this town” Mark Hughes, director of the Vermont Racial Justice Alliance speaks as Burlington officials and 30 organizations declare “Racism a Public Health Emergency” July 2020 The Current Burlington-Winooski Axis Decline Extends Back Decades Since the early 1980s about every Vermont major economic indicator save the education export economy crept slowly down or stagnated in Vermont. This mirrored the trends of loss of good paying manufacturing jobs which spurred the post-World Ward II economy upward ending about 1980 then moving to decline—what significant real growth incomes occurred in the last four decades in the slow-growth states of the northeast and mid-west rust belts tilted to the well-to-do. This recent trend impact on the historic economic centuries old engine of Vermont represented by the Burlington waterfront to Winooski City riverside “axis” has been most pronounced and profound. During both the post-World War economic boom ending about 1980, subsequent decline population and wealth shifted away from built-up Burlington and Winooski to the suburbs and rural Chittenden County towns. For almost two centuries the two cities remained the economic engine of Vermont but since the 1980s their role faded. For Vermont, the 1960s investments by then Governor Hoff in being the first state in the nation to buy their critical major rail operator (the Rutland Railroad) and literally birthing the ski industry with two unprecedented major speculative public ski road investments—helped the state avoid the empty storefronts and dominating skeletons of former manufacturing facilities as the 1980s and 1990s progressed. Springfield in 1960 was the home of a major portion of the machine tool industry of the nation! A critical player in the manufacturing industry of the day. The Springfield incomes of a unionized workforce were the highest in the state and the slow but sure economic decline as the industry atrophied left the community begging a state prison to rescue its depressed economy. Compared to northeastern New York and all Maine except for the area a two hour drive from the Boston metro, Vermont faired relatively fairly well only because of the ski/tourism and educational economic sectors growth until the plateau of the ski economy in the 1990s followed by education plateau in student numbers beginning in 2010. For Vermont that buffering of economic and social stagnation arose from the baby boom education bulge in its colleges during the 1990s and first decade of this century which plateaued in 2010 and now succumbs to the demographic collapse of college age population. And yes that boomers boomers were the first ski generation. The education industry future seems even more murky as record lows in birth rates in the northeast and nationally continue. Not even mentioning distance learning and the competitive disadvantage of norther New England state universities with the highest tuitions in the nation. Private St. Michael’s College, for example, planned ahead for the student bust and carefully with full participation of the college community managed the 16% decline from 1,900 students a decade ago to the 1,600 today. UVM and the State colleges systems did not plan—as is obvious now—as educational bankruptcy measures are in place for the state colleges and UVM’s modest 3% drop in students in fall 2020 signals the first statistical slight downtrend dating back to the peak year 2010. UVM’s current approach to the future appears unplanned and undirected. The drop of direct employment by IBM in Essex Junction of about 8,000 at its peak in the 1980s to now about 2,300 at successor Global Foundries—still the State’s largest private employer—gives the best evidence of the past and continued manufacturing decline. UVM rates as the largest Vermont employer excepting state government itself. The pandemic has given all a pause to reflect on our economic and social history, and ask the question where do we in Burlington Winooski “axis” go from here in a predominantly rural state where among many challenges is the requirement to sharply reduce non-renewable resources to stop global warming? Of course, Vermont never really possessed non-renewable energy resources in the first place. Note that over half the Vermont non-renewable resource consumption centers on petroleum fuels used to power the motor vehicle dominated transport sector. Longer History View and Recent Arrival of “Povertyville” To ask the question where do we go from here, consider Vermont and most important the driving engine throughout our history being primarily the story of the economy of Burlington and Winooski. Those two communities began with transportation centered along the Burlington waterfront accessing markets by water and Winooski riverside manufacturing production driven by the Winooski River waterpower. The Burlington waterfront where transportation to markets occurred was centered—first just to the lake and northward to Canada, then with the Erie and Champlain Canals accessing markets south the New York City and the west in the 1820s, then amplified by the arrival of the railroads in the mid-1800s, finally redirected into the “modern” highway oriented economy with the completed interstates here in 1982. That original economic engine spread from the Burlington waterfront to the Winooski falls area—more or less defined today by the King Maple neighborhood and Old North End (ONE) in Burlington onto really the entire geographically small Winooski City itself, where former manufacturing along the riverside drew from the immediate residential areas fanning outward to that City’s borders. It is fair to say that Burlington/Winooski with its waterfront as a harbor for exchange and movement of goods along the the manufacturing along its own and adjoining Winooski mills not only became the “economic spine” of the Vermont economy during Ethan Allen era ending about 1800, but also became a permanent dominant economic fixture of the state. First, reflecting the changing economy during the era of waterborne traffic until the railroads came into prominence, then the auto age emergence early last century followed by the interstate. Ironically, the completion of the interstate coincided with the overall crest and shortly thereafter relative stagnation of the Vermont economy which endures today—the Burlington Winooski axis being the primary victim. From the beginning of the interstate era the historical “spine of the Vermont economy,” Burlington and Winooski population and influence declined. Once the majority of Chittenden County population, Burlington now amounts to less than a quarter—both Winooski and Burlington populations outside of Burlington’s New North End have been in decline for decades. Again, a surge of students population growth from 1990 to the present day helped to mask this population downtrend trend. From 2000 to 2010, the Burlington population small population growth was entirely attributable to the increase in the college age numbers along with a small but important immigrant population of New Americans. The slow deterioration in Vermont through suburban carcentricity was mirrored by the decline of historic built-up Burlington and Winooski into a poverty belt. Today Census data shows King Maple/Old North End/Winooski City feature poverty rates of residents of 26-29% compared to under 12% for Chittenden County and Vermont. This poverty belt seems an unlikely candidate for a caterpillar to butterfly transformation—but that is the very opportunity which appears to exist through undertaking some key public investments today. These investments do not differ a great deal from the kind of investments which led to the successful transitions in the past, including those of Ethan and Ira Allen period themselves. And one must not forget the native American population which Ethan himself engaged with in his full lonely winters near Salisbury trapping furs to take back each spring to sell in order to support his family back home in Massachusetts. (Little wonder Allen stood up for his Indian allies when all were captured in the ill-fated foray to capture Montreal and his subsequent imprisonment as an enemy combatant by the British.) Housing The renewal of the historic Burlington-Winooski corridor remains central to this thesis in order to repair, remediate and expedite a natural economic and community potential ignored for decades. That both transportation and housing elements are key to this process can no longer be ignored. The decision to expand bike lanes and shift road space away from parking has been well underway now for years. Those changes are significant and show a change in community viewpoints but still incremental—in the right direction but only point to the larger issue of community renewal requiring a far more extensive change in transportation infrastructure combined with changes in housing. Housing programming must address the low and moderate income. Housing is not a subject here but the raising of the issue nationally and in Vermont to a priority is a clear indicator that transportation change must also be matched by making safe and sanitary housing available to all regardless of income. That President Biden and Vice-President Harris who proposed universal housing vouchers (30% income rent max) is an encouraging sign of kind of movement critical in the housing area. Enter the 15-Minute City Approach to Urban Design, Urban Life Transportation and land use go together—it was the lake as a transportation mode and waterpower of the Winooski River as a power source for manufacture that created with the presence of developable land adjacent the Burlington-Winooski axis in the first place. Consider for a moment past compact community design thinking in town and city planning. Creating complete new towns and idealized city designs became a cottage industry in the late 1800s in England with “Garden Cities of Tomorrow” by UKer Ebenezer Howard the leading proponent and movement leader who actually built more than one “new town.” Several more have been built since in a practice that can be found now scattered across the globe in one form or another. Reston, VA near Washington was one such American “new town” experimental community developed in the 1960s. Howard ’s base design involved a circular community with a one-mile radius featuring a public “white palace” and park in the center with rings outward of retail/commercial, housing, and heavy industry with rail—passenger and freight—at the periphery. All told 30,000 residents would live within the “garden city”—slice off the New North End, compact the rest around the waterfront here in Burlington and that is not so far off from the “garden city” concept and population. What is important is the garden city was accessible to just about everyone on foot, easily accessible when you add provision today for light rail and bicycles. Cars which consume about 25% of urban lands today in satisfying parking and road street needs prevented compact development worldwide. Just the opposite, particularly in America. The car age and pro-car policies and subsidies for homeownership jointly produced American sprawl since World War II. Canada is a perfect counterpoint as their urban areas are at least half again more dense, explained in great part because Canada does not subsidize either homeownership or cars. Canada levies a $1 Cdn per gallon of gasoline, a national tax used for general fund purposes—it has no federal highway program. It has no significant homeownership help. The U.S. has used its under 50 cent gas tax to support the highway system! The U.S. sprawl was created by intentional public policies and expenditures! The garden city from an urban planner perspective really is the pre-cursor to the “15 minute city” ideas advocated by urban planners today—to the extent feasible meet as many human needs within a 15 minute walk/bike/transit trip within a small geographic area (see https://www.15minutecity.com ) Burlington-Winooski: Pedestrians, Environmental Justice, Remediation and Structural Redesign There exists a confluence of forces making the Burlington-Winooski poverty corridor, Povertyville, ripe for a hoped for community transformation and renewal. The corridor already has in place a significant density, an historic rail network radiating in three directions from the Burlington waterfront. Except for re-establishing light rail in a configuration not that dissimilar to that of a past trolley history, a safe walkable/bikable/transitable area is easily installed. The major barriers to transportation the in Burlington and Winooski “poverty corridor” remain like most older urban center lack of walkability, about century removed from trolley service, and presence of numerous, dangerous/delaying new fangled traffic signals. Until this century with the late in the game U.S. use of the modern roundabout technology using stone age materials, little was done to repair the car-ravaged urban environment of modern America. Simply for decades to accommodate the car we wiped out existing urban space, much of it to park cars and build parking garages. Older urban space increasingly became the home of low income and BIPOC populations—symbolized by the traffic signal which when compared to a modern roundabout, especially kills, injures, delays pedestrians and overall pollutes, uglifies and heats the planet. The forces today at work include emergency demands for reductions of non-renewable resources both because they are unavailable in states like Vermont and because of commitments at all governmental levels to reduce consumption of them in order to stop the increasing world temperatures rising with just the continuation of status quo. That half Vermont use of non-renewables sits in the transport sector dominated by the car and clearly reigning in car subsidies—particularly parking and general government funds—means transportation will be a continuing dominant element of public policy in regard to global warming. Cutting car subsidies and homeownership subsidies which promulgated sprawl are not enough. There must also be a commitment to safe, energy efficient transportation—read transit, walking and bicycling which only thrive in relatively dense corridors and communities. The old urban areas and corridors have all the ingredients to respond to the demands and opportunities for a reduced carbon life—in a word the densities already exist there. High densities, transit services such as they are, and potential for walkabilitating through use of roundabouts are obvious. Except for the Church Street Marketplace neither Burlington or Winooski score particularly well on walkability—the 20 high crash state intersections mostly in the Old North and downtown alone testify to that. It was the very threat of cutting King Maple in two with the Champlain Parkway which led to our understanding of how the traffic signal in built up areas becomes a weapon of economic, social, and racial injustice—and the converse principle—how to reverse the historic destruction of livability forced onto the urban fabric by accommodation of the car through traffic signals which in turn literally injures the low income/BIPOC residents at higher rates than whites and embodies the context of both unlivable urban space as well as heightened incentives for use of motor fuels on most to move to lower density areas. In a word transportation inefficiency—read poor walking, biking and transit conditions—worked and works now directly opposite to efficient density and energy/resource use reduction which only density can provide! So the now two-year process of Environmental Justice discussion of the Champlain Parkway leads to an understanding of both the opportunity to renew Povertyville, but also its absolute necessity. That absolute necessity does mean a makeover of transit too, primarily in the form of light rail infrastructure! Without light rail combined with density there can be no successful economic renewal and only a continued shift of population to other northeastern metro areas who will have solved the transportation/energy equation. Nationally in a slow but sure fashion light rail has begun to return to major urban areas. It is the arch enemy of the car! Nearby, when Vermonters are allowed in Montreal again they will see nearly completed light rail line ready for use next year, the current $6 billion project already is set for a $10 billion expansion! Beginning in 2022 one no longer will have to drive onto Montreal island, no longer have to braves the wilds of to get to Trudeau International Airport. Just jump on the automatic light rail line at the large retail complex the Vermont side of the Champlain Bridge and safely, quickly, and comfortably travel to downtown, Trudeau Airport and a dozen other locations. See map and schedule—Brossard southern terminus to downtown set to open in 2022: https://en.wikipedia.org/wiki/R%C3%A9seau_express_m%C3%A9tropolitain Base information: https://rem.info/en/light-rail Already being expanded: https://www.rtands.com/rail-news/extended-light-rail-line-in-montreal-will-be-one-of-the-longest-in-the-world/ Burlington along with adjoining towns went through a light rail study in the 1990s with an agreed on first step a line between the waterfront and UVM/UVMMC via the Marketplace. Extensions to the airport and University Mall and even to Essex Jct. via Winooski were examined. The base cost of the first section from waterfront to UVM/UVMCC was about $80 million—not much different than the current $109 million planned investment in the Champlain Parkway. So, initial studies were undertaken and preferred routes determined for light rail in the 1990s. Has anything changed in the City since? Economically, socially, population, etc. Other than the trends outlined here what have been the changes—(1) increase, plateau then declines in college students; (2) stagnant “povertyville corridor” population and incomes; (3) regular decline in primary tech jobs reflected in transition from IBM to Global Foundries; and (4) Chittenden County population growth almost entirely outside Burlington and Winooski cities boundaries. One other trend is important to note. While senior population remained about 12% of the Vermont population through 2010, the major change in demographics—senior population doubling to 1 in 4 residents by 2030 and non-senior population declines (only in Chittenden County does non-senior population remain relatively constant). The statewide population rapidly slowing growth turned shifted into a slight decline 2010-2020. The implication is quite clear, only bringing in a significant change in direction of public investment can one expect these trends to suddenly change—particularly as far as the historic Burlington-Winooski corridor. Systemic change was demanded at inflection points the 200-plus years of the Burlington/Winooski axis and systemic change is required today. There must be a working with neighboring towns, a collaborative effort to change the economic and community structure of the still dominant economic driver of Vermont, the Burlington-Winooski axis. Some Thoughts on Light Rail Routes A complete background on Burlington trolley services history, the 1990s study and future potential along with exploration of the “bus rapid transit” (BRT) fad, can be found here in a paper prepared at the time of the last City Transportation Plan (dated 2011). https://www.burlingtonvt.gov/sites/default/files/Burlington_Streetcar_Briefing_Report_FINAL.pdf (BRT is notoriously expensive, energy inefficient and consumes wide swaths of urban land.) The original trolley routes were, first, Burlington waterfront to Winooski along North Winooski and Riverside which for the first few years in the 1880s were horse drawn then electrified. A line was added out along North Avenue to Ethan Allen Park, a Main Street line to UVM, and the Winooski line eventually extended to the rail connection at Essex Junction. The 1990s study included a connection to the airport as an important potential line. The study was very much in isolation without consideration of economic trends, demographics or the faintest hint of a non-carcentric community design—the idea of light rail was an add-on, a very expensive extravagance. Discussions during both the Railroad Enterprise District, recent Pine Street Coalition outreach on Champlain Parkway design and the North Avenue Corridor Plan process found significant support for a north-south light rail line, something not considered in the 1990s plan. In purely historical and community development, the prime high rail line would repeat the Burlington waterfront to downtown Winooski. That would directly address the Burlington-Winooski axis, i.e., Vermont Povertyville. The “Winooski line” would move through the Marketplace via College, then along North Winooski Ave, Riverside Ave and at Colcheter turn left to Winooski downtown. The natural waterfront to UVM-UVMMC also starts for a block or so with the Winooski line then ascends. The question is whether this line is shifted over to Main Street (a 1990s route suggested) and onto University Mall and new South Burlington “downtown.” The third line would follow the suggested north-south route from Flynn School at the north end to the South Burlington border at Pine street then very likely along Perimeter Road southward through KMart Plaza, Palace Theater, etc. Walkability, Racism and Remediation of ONE, King Maple and Winooski Downtown Light rail for the Burlington-Winooski axis is not an add-on but part of a larger multi-modal redesign starting on walkability and safety on the streets. The pedestrian mode remains the apartheid mode when it comes to street engineering and the task of remediation of this in Povertyille remains very much both a transportation undertaking and one to repair decades of transportation racism still a daily experience for the BIPOC and low income who comprise a large segment of this and other older Vermont urban spaces. Weekly in Burlington a pedestrian or cyclist suffers an injury in a car crash in addition to two crash injuries to car occupants. Nationally the U.S. road fatality pandemic amounts to 21,000 excess deaths in a nation once first, now 18th in highway safety—Burlington experiences one fatality on its streets every three years, the majority since 1998 pedestrians (3) and cyclists (1). Discussed elsewhere, the 20 high crash Burlington intersections, all but one signalized and concentrated in Povertyville each average 1.5 injuries yearly and account for 28 injuries a year while five downtown Vermont roundabouts, the new standard intersection, record about one injury a decade, all non serious in the first 52 years recorded. The point is the renewal of the Burlngton-Winooski corridor depends on both integration of a light rail network but also reparations and remediation to the area which has suffered decades of pollution and high rates of pedestrian, bike and vehicle injuries. And the victims in Povertyville of discrimination in the apartheid mode, walking, continue to be disproportionately people with black and brown skins. Tony Redington TonyRVT99@gmail.com @TonyRVT60 TonyRVT.blogspot.com A walk safety advocate, Redington is a policy development specialist with 20 years experience with the NH and VT state transportation agencies, author of several transportation research papers including some on the subject of modern roundabouts, and five years as a statewide housing planner and director of the New Hampshire Housing Commission. Since moving to Burlington in 2011 has lived car free. An Aside—Mostly Living the 15-Minute City 1976 to Date Except for about four years 1980-1984 when residing in suburb 6 miles from Concord, NH, have lived the 15-Minute City life in Concord, NH, Montpelier, VT, San Francisco (North Beach), Montreal (adjacent Atwater Metro, cycle track network) and now Burlington (within a block of the Marketplace). In all locations shopped within two-three blocks from just about all basic needs ranging from food stores, shopping, schools, employment, etc. In all that time generally never used a car to travel to work, most all vacations from 1990s on via Amtrak and extended public transit (mostly in Canada’s metro areas), and mostly (like today) within a few feet of a bus stop, a few blocks to a transit center. In Burlington, Montpelier, San Francisco and Montreal presence of a major supermarket or two was critical to the 15-minute life along with a job. In all four cities a car was not only no needed, it was relatively useless and not cost effective. Yes, the bicycle fills in the “mobility” need year round except in 0 degree weather. And as important our family learned the 15 minute life experience in Montpelier, how to use public transit, and how to live carless. Living and modeling the 15-minute City life can be inherited! So to me, the 15-minute City has been most of my adult life—it certainly was the bulk of my life growing up in Keene, NH where most years I lived within a few blocks downtown and all schools including high school. My favorite grades 1-2-3 were spent about 2 blocks from two doors north of Union Street to Court Street to School Street. Home to middle school was about six blocks and to high school varied from a couple of blocks to a half mile. All Keene home addresses were less than six blocks from the central shopping district on Main Street. Until college except for one year in the suburbs, the 15-minute life! Interestingly Keene is now home to five going onto seven roundabouts likely the highest concentration of any New England city. The historic traffic circle there—Central Square—is now bounded at the other end of the commercial/retail Main Street by a neat two-lane roundabout which acts as a gateway to the downtown and Keene State College with a the post office on one corner and the College on another—downtown three north south Main Street sidewalks on its way to renewed walkability. Tony Redington
Thursday, February 11, 2021
Pine Street Coalition Demands Reopening of Environmental Justice Process, Allow Consideration of Alternative Designs as Per Regulations
TO: FHWA, VTrans, City of Burlington FROM: Pine Street Coalition DATE: 02-11-2021 RE: Demand to Re-open Environmental Justice LSDSEIS Comment Period on the Burlington, Vermont Project MEGC-M5000(1) Southern Connector/Champlain Parkway Project and Present Alternatives for Public Comment The Pine Street Coalition, on behalf of itself and its members, hereby demand that you re-open the comment period on the LSDSEIS Environmental Justice review of the Burlington, Vermont Project Megc-M5000(1) Southern Connector/Champlain Parkway Project Chittenden County, Vermont. The reasons for re-opening the comments include, but are not limited to, the following: 1. The Covid-19 pandemic gave rise to a governmentally-declared state of emergency in the State of Vermont which encompassed the comment period time, curtailing participation, particularly by affected persons intended to be protected by environmental justice principles. On March 13, 2020, Vermont governor Phil Scott declared a state of emergency relative to the Covid-19 pandemic. That state of emergency continues through the present time. The state of emergency impacts every aspect of citizens’ participation in civil society. Child care and transportation that enable in-person participation in hearings is restricted. As noted in the letter of Steve Goodkind appended to the Pine Street Coalition comments, this marks the first time that a NEPA document published for comment for a Burlington public works project was not made available in hard copy at City Hall and public libraries; it was only available online. A December 2020 Vermont Department of Health Data Brief details the disproportionate impact of Covid-19 on Vermonters who are Black, Indigenous, and People of Color. Chittenden County had the highest rate of Covid-19 among BIPOC communities, at a rate much higher than the state average. June and July 2020 represented the peak instances of Covid-19 cases among BIPOC Vermonters. https://www.healthvermont.gov/sites/default/files/documents/pdf/COVID-19-among-BIPOC-Data-Brief.pdf The LSDSEIS – a 556 page technical document -- was digitally distributed for public comment on July 10, 2020. The only public hearing on it was held – online via a web conferencing application, with a small number of in-person seats available to persons who preregistered – on July 29, 2020. Comments closed on August 24, 2020. This time period coincides with the peak instances of Covid-19 cases among BIPOC people in Chittenden County. Families were preoccupied with keeping their loved ones alive, accommodating schooling and working from home, loss of work and income, and profound disruption to the fabric of their lives. Despite the highly unusual circumstances of a state of emergency -- in which in-person gatherings were strictly limited, where hard copies of the document were not available, in which the only access to the documents was online, and access to the hearing was either online or required advance online registration (only one person, Pine Street Coalition member Steve Goodkind, attended in person) while the low-income people of the affected community have lower rates of internet access and were, in many instances, coping with working from home and children at home, and in which the affected environmental justice community was disproportionately affected by Covid just at the time of this hearing – you afforded only the minimally-prescribed 45 day comment period. This was a time for expanding the comment period beyond the minimally-prescribed 45 days and for taking other steps to ensure that voices of the affected community were heard, such as making paper copies available on request. The affected Black, Brown and immigrant community members were unable to meaningfully participate in the LSDSEIS comment period within the timeframe and under the logistical constraints presented. We therefore demand that you re-open the comment period for a period of at least 60 days, and take reasonable steps to make the LS DSEIS available in hard copy to members of the community, and engaged in further measures to ensure that the voices of the affected community are heard. 2. The presentation made at public hearing by FHWA, VTrans and the City of Burlington stated that these agencies had already made both a determination regarding Environmental Justice and selection of a single project design prior to accepting comments. No alternatives to either the project design or the environmental justice determination were presented Only one public hearing was held on the LSDSEIS, on July 29, 2020, via Zoom (presenters at the ‘outreach meeting’ in September 2019 did not even advise the public that the purpose of the meeting was to accept comments pertaining to environmental justice). At that one public hearing, a PowerPoint presentation was made to the public prior to acceptance of comments. That PowerPoint presentation states, at Slide 36: The FHWA, VTrans and City of Burlington announced its determination of no disproportionate impact BEFORE accepting any comments from the public, and a month prior to the close of the comment period. Such process turns NEPA on its head. The fundamental objective of NEPA is to ensure that the decisionmaker is informed by the NEPA process including public comment prior to making a decision. Here, the FHWA, VTrans and the City of Burlington announced its decision before you had heard from the people whose input is mandated by NEPA and Environmental Justice policies. The announcement of that determination precluded consideration of any other alternative – and indeed, no alternatives whatsoever were presented as part of the LS DSEIS process. Despite recission of the 2010 RoD, and despite the fact that the purpose of Environmental Justice review is to obtain comment from the affected communities on the impact of the various alternatives, the public was presented only with what is designated the “preferred alternative” in the LS DSEIS. No information was shared, and no comments sought, on any alternatives other than this one “preferred alternative”. Agencies “must, in fact, consider all of the alternatives discussed in an EIS.” 40 CFR §1505.1(e) and CEQ FAQs #1. The object of identifying a particular alternative as the “preferred alternative” is so that the public can be aware of the agency’s position when making its comments on the range of alternatives. 40 CFR §1502.14(e). Presenting ONLY the “preferred alternative” with no other options in the LSDSEIS wholly deprives the affected community of any meaningful opportunity to participate and comment in the decision-making process. Because the 2010 Record of Decision has been rescinded, all the Alternatives considered in the 2009 EIS document should be under consideration and open to comment. Those Alternatives include Build Alternative 1, which the same agencies—FHWA, VTrans and the City of Burlington – are now proceeding with in a separate NEPA process. The Railyard Enterprise Project, without the segment of the proposed Parkway running on Pine Street between approximately Marble Avenue and Main Street, is precisely the alternative that will alleviate harmful impacts to the Maple-King community. The LSDSEIS, with no alternatives, was released to the public on July 10, 2020; the public hearing was held July 29, 2020. Supplemental scoping for the Railyard Enterprise Project which bears directly on the environmental justice aspects of the Champlain Parkway project was released August 5, 2020. The public in general, and the affected Environmental Justice community in particular, should be given information about and opportunity to comment on this alternative. CONCLUSION: The Covid-19 pandemic and related state of emergency, with its particularized impacts on the BIPOC community in Vermont, deprived affected members of the environmental justice community of opportunity to meaningfully participate in this LS DSEIS commenting process. The announcement by FHWA, VTrans and the City of Burlington that an environmental justice determination had already been made and an alternative already selected prior to accepting public comment inverted the NEPA process and excluded the public, including the affected members of the environmental justice community, from meaningful participation in this LS DSEIS commenting process. We therefore demand that FHWA, VTrans and the City of Burlington: 1. Release a revised LSDSEIS which sets out a range of alternatives presently under consideration, including the Railyard Enterprise Project/Build Alternative 1; 2. Disseminate public outreach materials indicating that a range of alternatives is under consideration, and that selection of an alternative as well as a determination regarding environmental justice impacts will be made AFTER public comments are received and considered; 3. Re-open the public comment period, after releasing these described documents, for a period of at least 60 days, while making all efforts to ensure that the documents are made available in the affected community and that comment is actively solicited (not merely accepted), taking into consideration the logistical constraints of the Covid-19 pandemic. Pine Street Coalition, By Their Legal Counsel, /s/Cindy Ellen Hill, Esq Cindy Ellen Hill, Esq. Hill Attorney PLLC, 144 Mead Lane Middlebury