Public Interest Transportation Forum -

Three years after the 2011 U.S. DOT issuance of two Records of Decision that describe the government decisions on the alignment of the future light rail extension from Seattle to downtown Bellevue, a new environmental challenge describing negative construction and operations impact on the Mercer Slough Nature Park was filed by Bellevue residents, and then defeated by Sound Transit.

by John Niles

Update: The Seattle Times reported on January 18, 2015 that in December 2014 [commercial property developer] Kemper Development Company, [civic organization] Building a Better Bellevue, former Bellevue Mayor Don Davidson and Mercer Slough advocate Geoffrey Bidwell filed a petition with Washington State’s Shorelines Hearings Board "to vacate Sound Transit’s shoreline-district permits for East Link." The group claims new information about how light rail will be built in the area requires another environmental-impact study. The case was heard in late April, and the Board ruled against the challenge. No further appeal has been announced.  The legal filing (89 page pdf) is posted here.  A two-page  flyer sent to 20,000 Bellevue households in March 2015 is posted here. A detailed map of the Mercer Slough is posted here. An analysis of the rejected tunnel route that would avoid the described negative impacts to the Mercer Slough is posted here.  The Sound Transit legal justification that prevailed is posted here.

Records of Decision (RODs) providing U.S. DOT's response to citizen comments on the Final EIS for East Link published in 2011.

City of Bellevue has its light rail planning home page here.

City Attorney for City of Bellevue raised East Link environmental concerns in August 29, 2011 letter to FTA (pdf). One of the RODs responded to this.

Sound Transit's East Link light rail home page here.  Construction has not yet begun.  Operations to transport commuters are planned to commence in 2023.

Bellevue citizens "Building a Better Bellevue" supported the preferred track alignment of the City Council majority.

Bellevue citizens lining up to support Sound Transit's track alignment to "Move Bellevue Forward" have a page here.

A Final Environmental Impact Statement was published by Sound Transit on July 15, 2011. Some of the comments received at U.S. DOT were considered and responded to in the two Federal Records of Decision, which collectively amount to U.S. Government approval of the route on environmental grounds.

These comments pushing back on the Sound Transit preferred alignment alternative were submitted to U.S. DOT:


Washington Trucking Association


Coalition for Effective Transportation Alternatives (CETA)


Eastside Transportation Association (ETA)


Transportation engineer Jim MacIsaac, P.E.


Kemper Development Corporation


Transportation Engineer William Popp, P.E. (Data to support City of Bellevue's preferred B7 alignment.)


I-90 User Coalition


East Side Rail Now, SEPA appeal


Bill Hirt, Bellevue resident


Renay Bennett, Bellevue resident


CETA to White House Council on Environmental Quality


Building a Better Bellevue


Further comments from Building a Better Bellevue

CETA earlier filed a comment with the Environmental Protection Agency based on the draft EIS data that the construction of East Link would release more greenhouse gas into the atmosphere than would be saved by people riding on the light rail once it began operation in the 2020s.


Most elected officials and citizens are not aware of what the East Link EIS actually states. For example, it reveals that traffic congestion across both Lake Washington bridges in 2030 will be made slightly worse, not better, if East Link light rail were to be built and put into operation. It also forecasts that the daily regional addition to transit ridership as a result of the billions to be spent for East Link is only 10,000, which is not enough to reduce congestion.


Coalition for Effective Transportation Alternatives (CETA) commented on a supplemental draft EIS in a short memorandum dated January 10, 2011 that notes that even with light rail, bus transit is forecast by PSRC to carry 63% of the weekday transit load across Lake Washington in 2040. Independent assessments from professional engineers indicate that buses could carry all of the forecast transit demand with multiple routes and reliable travel times as good as or better than what is contemplated for the single light rail line.


The Final EIS reveals that Sound Transit, Washington State DOT, and Federal Transit Administration offer a surprising opinion: "the East Link Project would have an overall beneficial impact on trucks traveling on I-90. As more people choose to use light rail, truck travel times during peak hours would be maintained or improve overall, and the ability for trucks to cross Lake Washington on I-90 would be maintained."  This finding was unsuccessfully challenged in an administrative appeal on the SEPA version of the Final EIS.


An earlier study on impacts from Washington Policy Center in 2007 used data from the WSDOT Center Roadway Study of July 2006 that is referenced by the ST EIS. The conclusions from Washington Policy Center are quite the opposite of the "overall beneficial impact" for freight that ST found. Policy Center concluded from WSDOT data that significant traffic impedance indeed occurs when lanes are removed, matching intuition. Quoting, "Freight vehicles would suffer the most. During the morning peak drive, the number of freight trucks able to cross into Seattle would drop 24%. Leaving Seattle during the afternoon peak drive, trucks would see a 19% reduction in capacity." The comment above from Eastside Transportation Association reaches the same conclusion based on the WSDOT work earlier.

Description of East Link issues as of early 2011 by KING-TV is here.  Transcript of a report on radio station KUOW on July 5 is here. A lawsuit from Eastside interests that tried to block light rail on the I-90 bridge was rejected by the Washington State Supreme Court.


Bellevue citizens in favor of the City Council majority's B7 preferred track alignment provided additional information on its characteristics and costs. City of Bellevue's Council majority supports alignment B7 that goes beside I-90 and I-405, and elaborated with research by an independent consulting firm, ARUP.  A City Council minority is siding with Sound Transit's July 28 selection of different alignment B2M which goes up Bellevue Way and 112th Ave. NE. Bellevue citizens in the association Building a Better Bellevue have refined and improved B7 features to design alignment B7R and they have done analysis to show that it is more affordable than B2M while attracting just as many riders. 


U.S. DOT Federal Highway Administration comments (pdf) on the East Link light rail draft EIS, mostly focused on the impact to the Interstate 90 corridor. Sound Transit's summary of FHWA comments:

"FHWA’s concerns focused on the feasibility of light rail on the floating bridge and associated air space and lease agreements necessary for temporary and permanent use of I-90 and I-405. FHWA also expressed concern for operational and construction safety measures. FHWA requested additional information on the feasibility of an expansion joint to accommodate light rail, highway operations and potential safety impacts from the project, safety impacts from construction on I-90, impacts from changes to HOV facilities, and use of the HOV lanes by Mercer Island single occupant vehicles (SOVs). They outlined the areas where Sound Transit would be required to receive FHWA approval before progressing, namely, HOV commitments to Mercer Island, feasibility of expansion joint, allowance for pedestrian crossings and stations located over interstates, and locating the substations on FHWA facilities or land owned by FHWA."


The FHWA letter states, "FHWA believes that the analysis on highway operations and safety is too focused on the transit element and does not go into enough depth and detail on the impacts to the highway·impacts resulting from this project."


The FHWA letter also states, "Page 3-10, Screenline 2: This section states that the future vic [volume to capacity] ratios in the peak direction is expected to become slightly higher than with no build, but overall conditions on I-90 would improve with the project. FHWA is not sure we agree with the conclusion that overall conditions improve with the project at this time. We have not yet completed our review of the traffic analysis, so we will likely have additional comments related to our opinion on how I-90 travel lanes will function in the future."



Comments by King County Metro Transit on the East Link light rail draft EIS, focusing largely on impacts to bus service between Seattle and the Eastside suburbs (pdf). 
Part 1 comments of February 2009.   Part 2 comments of March 2009.


Comments filed by Coalition for Effective Transportation Alternatives (pdf), noting that a strong express bus alternative should have been included, given the high cost, poor environmental performance, and weak customer attraction of light rail.


Comments filed by Kemper Development Corporation (7 megabyte pdf), a leading commercial developer and property owner in downtown Bellevue. These comments also recommend a stronger bus alternative.


Comments from Eastside civic activist Bill Hirt, who is following up with a series of essays presented to Bellevue City Council

All of the alternatives shown below were analyzed in the Final EIS. Traditionally, the greatest emphasis is given to Sound Transit's preferred alternative, which is shown on map provided on this Sound Transit web page.  However, because of new input from City of Bellevue City Council since November 2009, additional alignments were studied by Sound Transit and the City Government for the tracks within that municipality. The results of City of Bellevue's study of an alternative alignment are posted here.

Background: Sound Transit's East Link Environmental Impact Statement (EIS) assesses the impacts on transportation, energy, air quality, and other parts of the physical environment caused by constructing and operating a new light rail extension connecting Seattle, Mercer Island, and the east side of Lake Washington.

For example, this document reports on page 3-9 that East Link light rail will reduce vehicle miles traveled (VMT) in the region by 200,000 per day in 2030, compared to not building this train.  That's a change from 93,666,900 VMT per day to 93,470,700, a reduction of about one quarter of one percent. This difference does not amount to a significant change in traffic congestion.

The proposed East Link passenger railroad would cross the Lake in the center roadway of Interstate 90, which would become part of an 18 mile dedicated right-of-way between Seattle and Redmond.  Funding for this extension was passed by voters on November 4, 2008 in the Proposition 1 ballot measure.  PITF describes the East Link light rail impact on the I-90 bridge here.  The draft environmental impact statement describing the light rail effects was held back from publication until after the funding measure was passed in the election.

This EIS does the following:


Describes the alternatives and their potential impacts


Provides environmental information to assist decision-makers in selecting the project to be built


Identifies measures to avoid and minimize impacts, and, when necessary, compensate for adverse impacts

The East Link corridor is divided for planning purposes into five geographic segments:


Segment A, Interstate 90 (from the International District Station in downtown Seattle to Mercer Island and Bellevue via I-90 across Lake Washington);


Segment B, through South Bellevue, having 5 potential alignments;


Segment C, through Downtown Bellevue, having 6 potential alignments;


Segment D, Downtown Bellevue to Overlake Transit Center, having 4 potential alignments;


Segment E, Overlake Transit Center to Downtown Redmond, having 3 potential alignments.

The EIS also considers a No Build Alternative and four potential locations for a light rail maintenance facility alternatives (three in Segment D and one in Segment E).

Below are detailed maps of the five segments, showing the various alternatives under consideration.























Note: In a letter dated July 23, 2008, Sound Transit has assured the Washington State Department of Transportation that "Sound Transit has responsibility for the cost and risk to construct and maintain electric light rail on the I-90 bridge."  Further detail on issues related to light rail on the I-90 bridge are posted here.

Next is shown City of Bellevue's map of its preferred transit alignment through the Bel-Red corridor as shown by Planning Director Dan Stroh at a conference on September 16, 2008, posted at

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Last modified: June 20, 2015

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