December 17, 1999

Dear Mr. Olson:

Please include these comments on the Highway 131 Final Environmental Impact Statement as part of the public record.

Our concerns upon reviewing the FEIS are generally that it is too massive a reconstruction project to suit this low volume rural road that is adjacent to environmentally sensitive and significant recreational areas.  Through these comments, our purpose is to make recommendations and provide rationale for making design modifications that would balance safety with preservation of rural and scenic character. 

The project requires greater flexibility in design, justified in order to meet unique environmental and community concerns.  In previous comments and letters, we requested that certain design considerations remain unresolved at the conclusion of the environmental assessment process.  We understand that approval of the FEIS will set the constraints for the
environmental impacts of the road, but that it does not finalize geometrics, and does not mean that environmental impacts cannot be further reduced.  Our expectation from conversations and correspondence with you is that we will be included in a design modification committee which will address these issues.

We greatly appreciate the materials that you made available upon request, which have made these thorough and detailed comments possible.  The van tour that you organized of STH 131 was especially helpful to aid our complete understanding of all the design modifications that have been made to the proposed alignment so far.  We think that certain aspects of the proposed alignment are acceptable, and we have therefore refrained from commenting on them.  Namely, the approaches to blind curves and the bridge approaches are improvements to the safety of the road.  The following comments represent design modifications that we 
feel are extremely important to incorporate into the final alignment of the road. 

Preservation of  rural and scenic character 

The Kickapoo River Valley is an area of state-wide environmental and recreational significance.  The Valley deserves special attention and sensitivity to preserve the unique features which make the area such a special place to visit, namely its rolling topography and quiet.  As a recreational destination, it is attractive because visitors can enjoy the unglaciated landscape up close.  They can hear the river, birds calling and the wind in the trees.  These values are threatened by the construction of an arterial highway, and so is the value of the area as a tourist destination.  If the reasons people visit are degraded by the proximity of a loud, fast highway, it will cease to be a wonderful place to visit.  It is an aesthetically pleasing experience to travel along the existing road - this experience must be preserved.  The reconstruction as designed will have a massive impact on the scenic and rural character of the road. 

In the spirit of building a road that is safe and preserves the character of the area, we urge the following:

• While you can’t keep trucks out, you can slow them down by signing the road at 45 mph. 
• Make the road a pilot project for the new state Scenic Byways program.  This will allow a balance between preserving rural and scenic character and regional economic development, and make the road eligible for federal funds to enhance tourism value.

Safety for recreational users

We are greatly concerned that the road has been “over-engineered” in excess of what is necessary to accommodate projected average daily traffic, and what is justified by the crash rate.  Adjacent to significant recreational areas, the road will bear local traffic related to recreational use, such as vehicles pulling horse and canoe trailers, bicyclists, horse riders, and hikers.  The wider, flatter, and straighter the road is, the faster vehicle speeds it allows.  Even if the road is posted at 45 mph, studies show that if  visual cues tell drivers it is possible to go faster, they will travel the fastest speed the road allows.

To ensure that the road is safe, we urge that you: 

• Use design geometrics for 45 mph or slower and 8% grade or greater along the entire corridor, not just on certain portions. 
• Reduce the width of paved shoulders to 3 feet, which is consistent with paved shoulders along STH 131 north of Ontario and south of Rockton, and acceptable for bicyclists. 
• Move the river access and parking area from the proposed location adjacent to STH 131 across from County P, and instead upgrade the unpaved road on County P east for this purpose.  The proposed location allows vehicles to turn on and off STH 131 to the east and the west, a traffic pattern similar to an intersection, creating traffic crossing the highway.  It would be safer to direct recreational traffic to turn east on County P, moving recreational traffic and pedestrians further away from the highway.  This will also minimize environmental impact by using the existing access point, and preserve the scenic quality of the area to the west of STH 131. 
• Where ever you haven’t already done so, further reduce the overall width of the road through methods such as using steeper cut slopes and preserving natural boundary features like outcrops, hemlock growth, and the river.

 Flexible design to preserve environment and topography

We understand that some design modifications have been incorporated into the proposed alignment.  However, it is clear that this project brings substantial environmental degradation to the valley.  There are extensive areas of fill in low-lying areas and wetlands, especially around bridges.  We believe that still greater changes could be made that preserve more of the area’s topography by more closely following the existing footprint of the road, vertically and horizontally. 

We recommend the following  design modifications:

• Use design geometrics (vertical and horizontal design curves) for speeds under 45 mph, and grades greater than 8%, on the following portions of the road:  from 83,600 to 84,960, from 86,600 to 87,640, and from 88,080 to 89,880.  The tops of the ridges and the small dips between them could be more closely followed by treating the crest of the hills separately, rather than filling and cutting to form one large hill.  This would preserve the small dips which would be filled in the current alignment, such as the one by Hay Valley Road.  Some of the curves, such as the one at 86,600, could be preserved.  We urge that you explore methods of gaining flexibility to do this.  Some options might be using speed limitation signage at curves, re-classifying the road as a rural collector or using rural collector standards for those portions, or designation as a scenic byway. 
• Follow the existing road centerline through Rockton to 82,800.  This would minimize the impact on the wetland area at 82,700.
• Instead of the massive wetland fill area by Dutch Hollow Road at 83,200, we urge you to build a land-bridge instead.  The proposed underpass tunnel would be replaced by an open trail going under the land bridge, and using a terrace high on the slope on either side of STH 131.  This option would preserve the wetland area (which the proposed alignment would divide into two hydrologically isolated units), the significant wildlife corridor, and make a safer, more attractive trail experience for equestrians and snowmobilers than a tunnel.
• Replace the proposed land bridge by re-aligning the road to the east such that it re-joins the current road by the outcrop at  Winchel Valley Road, at 85,700.  This option would make it possible to preserve the outcrop and avoid the noise and expense of the land bridge.  It would also preserve a grove of  hemlock trees, remove a blind curve, and allow the road to follow the slope of the hill rather than cut across a narrow valley.  We are concerned that as the project cost grows, the land bridge design may be modified to stay within budget.  If the length of the span is reduced, it will entail significant fill material, creating a barrier for wildlife movement, and adversely impact the wetlands, wooded areas, and river.

Thank you for your thoughtful consideration of these concerns and recommendations.  We look forward to working with you on a technical advisory committee where we may discuss these issues further.  Please notify us when you are prepared to schedule the meeting.

Sincerely,

Andrea Broaddus
New Transportation Alliance
222 S. Hamilton St., Suite 1
Madison, WI  53703

Caryl Terrell
Sierra Club
222 S. Hamilton St., Suite 1
Madison, WI  53703

Rich Bogovich
Wisconsin’s Environmental Decade
122 State St., Suite 210
Madison, WI  53703

Rob Kennedy
Citizens for a Better Environment
511 S. Baldwin St.
Madison, WI  53703