letter to the u.s. department of transportation about adams county rail station

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SULLIVAN GREEN SEAVY LLC Barbara J.B. Green 3223 Arapahoe Avenue, Suite 300 Boulder, CO 80303 Phone: 303-355-4405 Fax: 303-322-5680 [email protected] November 19, 2010 United States Department of Transportation Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator 12300 W. Dakota Avenue, Suite 310 Lakewood, CO 80228 Re: Gold Line Federal Station Relocation Dear Mr. Roaspep: This letter has been prepared on behalf of our client, Lobo Inc., and the parties listed in Attachment 1 to this letter, in response to the Denver Regional Transportation District (RTD) proposal to change the location of the Federal station on the Gold Line project. We understand that RTD has proposed to move the Federal station from the east location that was evaluated in the EIS process and approved within the Record of Decision (ROD) (Federal East), to the west location that was NOT assessed in the EIS process and not approved within the ROD (Federal West). In a letter dated June 30, 2010 to RTD FasTracks Environmental Manager Liz Telford, FTA made a Finding of No Significant Impact (FONSI) for the proposed change, and determined that the proposed change would not require a supplemental Environmental Impact Statement. The FTA relied on a Reevaluation prepared by RTD dated June 8, 2010 (“Reevaluation”). For the reasons set forth in this letter, we are concerned that FTA has not followed the proper procedure to allow the change in location to proceed, and in any event, the Reevaluation upon which it relies is seriously flawed. 1. There is No Basis to Issue a FONSI. A FONSI is not the proper regulatory mechanism . A FONSI is not the appropriate

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Page 1: Letter to the U.S. Department of Transportation about Adams County rail station

SULLIVAN GREEN SEAVY LLC Barbara J.B. Green 3223 Arapahoe Avenue, Suite 300 Boulder, CO 80303 Phone: 303-355-4405 Fax: 303-322-5680 [email protected]

November 19, 2010

United States Department of Transportation Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator 12300 W. Dakota Avenue, Suite 310 Lakewood, CO 80228 Re: Gold Line Federal Station Relocation Dear Mr. Roaspep: This letter has been prepared on behalf of our client, Lobo Inc., and the parties listed in Attachment 1 to this letter, in response to the Denver Regional Transportation District (RTD) proposal to change the location of the Federal station on the Gold Line project. We understand that RTD has proposed to move the Federal station from the east location that was evaluated in the EIS process and approved within the Record of Decision (ROD) (Federal East), to the west location that was NOT assessed in the EIS process and not approved within the ROD (Federal West). In a letter dated June 30, 2010 to RTD FasTracks Environmental Manager Liz Telford, FTA made a Finding of No Significant Impact (FONSI) for the proposed change, and determined that the proposed change would not require a supplemental Environmental Impact Statement. The FTA relied on a Reevaluation prepared by RTD dated June 8, 2010 (“Reevaluation”). For the reasons set forth in this letter, we are concerned that FTA has not followed the proper procedure to allow the change in location to proceed, and in any event, the Reevaluation upon which it relies is seriously flawed. 1. There is No Basis to Issue a FONSI. A FONSI is not the proper regulatory mechanism. A FONSI is not the appropriate

Page 2: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 2

regulatory mechanism to evaluate the proposed change in station location. The FTA rules that apply to issuing a FONSI are found at 23 C.F.R. § 771.121. Those rules apply to a decision regarding whether an Environmental Impact Statement (“EIS”) is required in the first instance. In order to make that determination, FTA must rely on an Environmental Assessment (“EA”). Based on the EA, either an EIS will be required, or a FONSI will be issued. In this case, NO Environmental Assessment has been prepared for the station relocation and thus, no FONSI can possibly be issued. Moreover, an EA has its own public comment requirements. A Reevaluation is not the proper mechanism to support a post-ROD change in the Preferred Alternative. The only documentation of the impacts of the change to Federal West is the so-called Reevalaution prepared by RTD. A reevaluation is not the proper mechanism for evaluating a post-ROD change in the Preferred Alternative. The Re-evaluation Regulation is found at 23 C.F.R. § 771.129 and it does NOT apply to post-ROD changes to a preferred alternative. At best, the Re-evaluation Regulation applies to whether the FEIS remains valid prior to the issuance of an approval or grant. Moreover, there was no opportunity for public comment on the Reevaluation.

In sum, FTA appears to have used the FONSI process to determine whether the Preferred Alternative can be relocated, improperly issued a FONSI without an underlying EA and the attendant public comment, and relied on a reevaluation that is not the proper vehicle for changing a preferred alternative station location after a ROD has been issued. 2. A Revised Record of Decision is Required Before Federal West Can Be Pursued. The purpose of a ROD is “to present the basis for the decision as specified in 40 C.F.R. § 1505.2, summarize any mitigation measures that will be incorporated in the project and document any required Section 4(f) approval in accordance with part 774 of this chapter.” 23 C.F.R. § 771.127(a). The November 2009 ROD issued by FTA for the Gold Line Corridor Project documents the basis of decision for Federal East. Because the ROD does not designate Federal West for the Federal station site, and the ROD is based on an FEIS that has assessed Federal East instead of Federal West, a new ROD is required that is based on a new environmental assessment of the west location. Even when FTA wishes to approve an alternative which was not identified as the preferred alternative but was fully evaluated in the final EIS, a revised ROD is required. See 23 C.F.R. § 771.127(a). Obviously, when an alternative was NOT fully evaluated in the FEIS, a new EA and a new ROD would be required.

Page 3: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 3

3. Even if the Reevaluation were the Proper Mechanism to Support a Change in the Preferred Alternative, It is Fatally Flawed.

As a result of the Gold Line EIS process, public involvement during the DEIS process focused on Federal East. Federal West has no public scrutiny and comment because the west location was discarded during the Alternatives Analysis.

The Reevaluation states that the developer and Adams County had several local community meetings to discuss their development plans. “The results of the public meetings were that the community is generally supportive of those plans. . . .” (Reevaluation pg4). Response. This statement is NOT CORRECT. For example, at the Adams County Planning Commission meeting on August 26, 2010, according to the public record the developer noted one person favored relocation of the Federal station to the west location.

The Reevaluation incorrectly identifies benefits to relocating the Federal station to Federal West (Reevaluation pg 4): Cost Savings. The Reevaluation concludes that the developer will accommodate some of the costs on the west site for the project.

Response. Federal West costs have not been fully analyzed – the developer’s share is not documented, so analysis of costs is not complete. In fact, it is possible that additional costs incurred with Federal West will include more extensive construction of infrastructure, i.e. streets, utilities and water; construction of a minimum of two pedestrian bridge structures not accounted for in the ROD; construction of a larger elevator than would be required at Federal East and not accounted for in the ROD; mitigation of wetland impacts not accounted for in the ROD; construction and reconstruction of parking facilities; and more extensive installations to satisfy handicap access requirements. Decrease in environmental impacts. The Reevaluation concludes that Federal West “has fewer environmental impacts than the site to the east.” Response. This conclusion is NOT CORRECT. In fact, avoidance of environmental impacts has been the justification for selecting Federal East in the Preferred Alternative.

Page 4: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 4

- Federal East causes positive environmental impacts with mitigation of any hazardous sites connected with the east site’s industrial use; Federal West causes negative environmental impacts to jurisdictional wetlands, wildlife, migratory birds, and Clear Creek.

- Federal West may include environmental impacts from tearing up and disposing of

surface parking after development occurs. - “The Federal West Station Alternative was eliminated to avoid disturbances to wetlands,

which could only be avoided with additional infrastructure investments.” See pg 5, letter from Susan K. Hall (URS) to Margaret Langworthy (US Army Corps of Engineers, Denver Regulatory Office) dated February 12th, 2009.

The Reevaluation states that RTD has required the developer to engineer the station area to 30% to be consistent with the FEIS level of engineering, and that this engineering must show avoidance/minimization of any environmental impacts (particularly jurisdictional wetlands and open waters at Clear Creek). (Reevaluation pg 9). Response. This is NOT SUFFICIENT for purposes of changing the preferred station location under the Preferred Alternative contemplated by the FEIS and the ROD. There has to be a complete discussion of any mitigation before the Preferred Alternative can be changed.

The Reevaluation states that“*t+raffic mitigation in the FEIS and ROD for the Federal east site included adding separate right and left turn lanes at 60th Avenue (the main road accessing the station from Federal) in 2015 and signalization of that intersection by 2030. The traffic impacts would be the same for the Federal west site since the volume of traffic for the project remains the same. The Federal west site would require the same mitigation as the Federal east site.” (Reevaluation pg 11).

Response. This assumption is WRONG. Moving the station to Federal West DOES change the flow of traffic, and the traffic studies did not include mitigation for Federal West. - at Federal East the bulk of traffic approaching from the highway would be making a right

turn into the station; by moving the station to Federal West, the bulk of traffic approaching from the highway would have to make a left turn into the station.

Page 5: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 5

- the bulk of the residential traffic (including Berkeley and Regis) will approach the station by heading north on Federal Boulevard; by moving the station to Federal West this traffic would need to make a left turn.

- Federal East has options for additional east-west and north-south connectivity with the

addition of through streets connecting to Pecos and 60th, easing congestion. Federal West is only accessible from a single Federal Boulevard turn-in; traffic conditions will be affected by the site’s proposed narrow streets and the high density residential, business, pedestrian and bike traffic.

- The Reevaluation fails to evaluate the deceleration rate for the train and how far back

from the station the train needs to start slowing down. The Reevaluation fails to identify or evaluate impacts to Lowell Boulevard that this could create. Lowell is already impacted by multiple train crossings. The addition of FasTracks will exacerbate the problem.

Potential impacts to Federal West access which are related to the planned 100-year bridge at Federal Boulevard and the downstream channelization have not been evaluated.

The Reevaluation states that “there will be a pedestrian structure from the station platform to the parking area such that any potential impacts to open waters or wetlands will be avoided.” (Reevaluation pg 14). Response. In fact, there will be two pedestrian structures at Federal West, and they will not completely avoid impacts to open waters or jurisdictional wetlands. The impact to wetlands was NOT evaluated in the EIS process or in the Reevaluation.

Concerns regarding parking provisions in the Clear Creek floodway were resolved by moving the parking facility to the furthest east location, outside of the floodway. The EIS and the Reevaluation do not establish whether or not Federal West parking, platform and appurtenant structures are in the 100-year floodplain and if there will be impacts.

The Reevaluation states that the number of parking spaces needed for the project are the same for both Federal East and Federal West, therefore the new impervious surface created for the park-and-ride would be the same for both locations and the water quality analysis done for the EIS, relative to Federal East is applicable to either location. (Reevaluation pg 17).

Page 6: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 6

Response. This assumption is based on the premise that both sites are equal and comparable in nature. This is NOT TRUE. Federal East, being industrial, cannot be equally compared to Federal West which abuts to jurisdictional wetlands, historically protected Kershaw Ditch and Clear Creek and will increase contaminated runoff loadings to Clear Creek, while Federal East does not.

The Reevaluation states that, with storm water controls, the FEIS indicated that there would be no violations of water quality standards associated with the additional runoff directly caused by the parking for Federal East. Therefore, there would be no violations of water quality standards associated with the additional runoff directly caused by having parking on the west side. (Reevaluation pg 17). Response. This statement has no basis. It is incorrect to assume that no problem on the east location equals no problem on the west location. On-site detention is required (per FEIS mitigation) for the Federal station on either site.

Handicap access is not addressed for Federal West, which poses significantly greater challenges for the physically challenged, and RTD design guidelines specify that the site selected should minimize or negate the need for vertical circulation.

The Reevaluation states that “the Gold Line FEIS noted that the project would not cause any regional air quality impacts for criteria pollutants and would result in a net decrease over the No Action Alternative. Hot Spot analyses completed at station areas for the EIS also showed no impacts. Since the parking/traffic would be essentially the same with the Federal east and Federal west sites, there would be no difference in the hot spot analysis for either site.” (Reevaluation pg 11). Response. There is no basis to assume that there would be no difference in the hot spot analysis for the two sites; Federal East is industrial while Federal West is in a basin by a lake and wetlands, and is directly above Clear Creek.

The Reevaluation states that the noise analysis completed for the FEIS indicated that there are no noise impacts in the area of the Federal station. The Reevaluation states that there is moderate impact to a residence near Lowell Boulevard (1,948 feet west of Federal West). The closest sensitive receptors to the Federal West is neighborhoods 960 feet to the north, well outside of the FTA screening distances for rail rapid transit, rail rapid transit stations and parking facilities. (Reevaluation pg 13).

Page 7: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 7

Response. These statements are WRONG. The noise analysis completed in the FEIS did not include Federal West. Federal East comprises industrial land use, with the attendant noise and truck traffic; Federal West comprises residential land use and open space, and is peaceful and serene by comparison. Sound mitigation for the nearby residences of Aloha Beach has not been addressed. Also, RTD is tearing down a mature riparian buffer that has helped with sound issues.

The Reevaluation states that “the Section 106 consultation for the Gold Line EIS included the area of the Federal west station option within the Area of Potential Effect (APE) . . . There were no listed or eligible properties within the APE in the Federal west station location and therefore no historic properties are affected.” (Reevaluation pg 12). Response. This conclusion is WRONG. Lake Sangraco was not included in the study area, even though it is classified as “historic” and located closer to the tracks. Moreover, the Kershaw Ditch is eligible for listing in the National Register of Historic Places (NRHP) under Criterion A. On September 8, 2008, the Colorado State Historic Preservation Officer concurred that the linear resource is eligible for listing in the NRHP, and that this segment retains sufficient integrity to support the overall eligibility of the entire resource. The original Kershaw Ditch runs from Lowell Boulevard to Clear Creek, a segment of which is located under Federal West. These historic properties have not been accounted for.

The Reevaluation states that a “Phase I Site Assessment was completed for the Gold Line EIS. There were 2 sites within the footprint of [Federal East]; a landfill within the footprint of the station (the full acquisition) and a registered UST site at 5901 North Federal . . . The Federal east site is within a methane overlay district; the Federal west site is not. No sites were found within the Federal west footprint.” (Reevaluation pg 13). Response. The registered UST site is actually located outside the current Federal East footprint. Early in the EIS Alternatives Analysis screening process, two east locations were considered for the Federal station; one of these eastern sites was discarded around the time Federal West was brought forward for consideration. The UST site is in the area of the discarded eastern site.

The Reevaluation states that there are no community facilities within the areas surrounding the station, and that there are fewer than 20% low income households and 45% minority households within ½ mile of the station. “Access to transit would be enhanced for these

Page 8: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 8

communities and would be a benefit. Therefore, there are no environmental justice impacts for the Federal west station location.” (Reevaluation pg 13). Response. This is not an accurate assessment of the community facilities around Federal West. The original “study area” for these statistics was based on Federal East. It is possible that moving the station to the west location will change the dynamics and these statistics. For example, a reduction in the ridership population is possible due to commuter access issues created by the west location.

The Reevaluation states that there would be no additional wetland impacts by relocation of the station from Federal East to Federal West (that impacts to .02 acres of jurisdictional wetlands in this area are caused by the structure over the creek and not the station area), therefore there will be no requirement to amend the existing 404 Nationwide Permit for the project. (Reevaluation pg 14). Response. This conclusion is NOT CORRECT. The rationale for selecting Federal East under the Preferred Alternative reflected that jurisdictional impacts associated with Federal West were avoided by selecting the east location. - Chris Proud, CH2MHill, in a June 29, 2007 email to Rena Brand, Corps of Engineers, states

that “*a+ll station locations are located in developed, urbanized areas and, at this time, have no impacts to wetlands. As we move forward with a preferred alternative, these sites will be refined and ultimate locations determined in the project's next phase. A fatal flaw for a station site would be impact to wetlands. We would design around, or select sites so there were no wetlands impacts at station sites. The goal of the project is to stay within the ROW and developed areas. . . .”

- In a letter from Timothy T. Carey, Corps of Engineers, dated August 29, 2008 Mr. Carey

notes that “*t+he DEIS indicates that you are currently in negotiations with Union Pacific Railroad regarding the amount of clearance between the existing tracks and your proposed set of tracks. If they require a 50 foot track center, the additional wetland impacts for the project may exceed the 0.50 acre threshold and require an Individual Permit rather than a Nationwide Permit.” RTD responded that “*d+ue to avoidance and minimization efforts the project impacts have been maintained to less than 0.5 acre qualifying the project for a Nationwide Permit.” *FEIS Vol. II, Response to Agency and Public Comments for the Gold Line Corridor and Commuter Rail Maintenance Facility, pg. 55]

Page 9: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 9

- the size of the jurisdictional wetlands from Sangraco spillway to Clear Creek has been underestimated.

- the wetlands affected on Federal East are non-jurisdictional.

Urban Drainage and Flood Control District (UDFCD) identified impacts to the Lake Sangraco spillway and channel, which is the outlet for the Hidden Lake watershed. The EIS assumes that the Preferred Alternative will include the Federal East station location. The impacts to Lake Sangraco, Lake Sangraco spillway, and the abutting wetlands were NOT evaluated for Federal West in either the EIS or the Reevaluation.

The Reevaluation states that Federal West is not within the 100-year floodplain. (Reevaluation pg 14). Response. The map used in the Reevaluation shows that Federal West is not in a floodplain. However, the map used in the Reevaluation differs from the maps used in the ROD and in the FEIS. Both the ROD map and the map used in the FEIS (FEIS figure 3.10.10, shown below) DO show that portions of Federal West would be in the floodplain. Based on FEIS figure 3.10.10, it appears that features such as elevators, bridge pillars, and stairs to access the station would be located in the 100-year floodplain, and that the station would require construction of piers and other structural components in the floodplain.

Page 10: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 10

Neither the FEIS nor the Reevaluation discuss the following floodplain impacts from building Federal West:

- floodplain impacts resulting from the increased embankment on the west (from the tracks), fill in the floodplain and wetlands, and increased impervious surface along the south side of Lake Sangraco.

- rise caused by building Federal West is not accounted for, nor is the rise caused by fill

between Lowell and Clear Creek. - alteration to the floodplain from Lowell to Clear Creek.

Impacts from the “fill” that is shown in FEIS Figure 3.10.11 below have not been addressed for Federal West:

Page 11: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 11

Impacts to jurisdictional wetlands and other water features at the Federal station were avoided by selecting Federal East (impacts to jurisdictional wetlands could have only been avoided with additional infrastructure investments). The Reevaluation does not assess these impacts.

The Reevaluation states that there are no impacts to high-quality habitat or listed endangered or threatened species by the implementation of Federal West. (Reevaluation pg 17). Response. Federal West contains wild life habitat, and the impacts to the habitat HAVE NOT been evaluated.

The Reevaluation states that RTD safety and security design features would be the same as those implemented for any other park-and-ride. There will be emergency telephones in station areas and closed circuit television coverage. (Reevaluation pg 17). Response. There has been NO evaluation of safety and security for Federal West, which abuts a creek, a lake, and wooded area that will be difficult to secure. Also, it is likely that safety and security requirements and design features will differ with the addition of floodplain guidelines and restrictions.

Page 12: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 12

The Reevaluation states that construction impacts will be the same for Federal West and Federal East. Since neighborhoods are far removed from either station site, few impacts are expected. (Reevaluation pg 17). Response. Construction impacts are NOT the same. The mitigation for construction impacts found in the ROD, as well as the FEIS, address Federal East. Federal West presents a different scenario, and must be mitigated differently. Federal East contains industrial land use while Federal West comprises a natural environment with residential housing across the lake. Construction will have a much greater impact on wetlands, wildlife, and migratory birds at Federal West than at Federal East. Construction associated with Federal West will have a greater impact on Clear Creek which will be directly adjacent to the construction site. Also, the Reevaluation does not evaluate impacts and mitigation for the south bank of Sangraco, as well as the possibility of construction affecting the lake itself or the potential sedimentation, erosion, noxious weed invasion to wetlands, and destruction of established riparian buffers.

Visual and aesthetic resources were not addressed in the Reevaluation. The visual impact associated with Federal West is far greater than with Federal East: the visual change would be minor for Federal East because the project is being constructed within existing industrial and commercial land uses. Under Federal East, impacts have been reduced because the majority of the project would be located in a railroad ROW. The visual impact of the project has been a concern identified in the public involvement process for the Gold Line study area, especially with respect to overhead catenary and the architecture of the transit stations. Public input under the EIS process identified concerns and allowed the team to address, avoid, or minimize these concerns through the design process. Federal West has not been evaluated within such a process.

The FEIS concludes that the Preferred Alternative (which assumes Federal East) would be both compliant and supportive of existing and future land use and transportation planning within the Gold Line study area. Response. The Reevaluation does not establish that the Proposed Alternative would continue to “be both compliant and supportive of existing and future land use and transportation planning within the Gold Line study area” if the Federal station is relocated to Federal West.

Page 13: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page 13

Thank you in advance for your consideration of our concerns with RTD’s proposal to change the location of the Federal station on the Gold Line project. We would be glad to meet with you at your earliest convenience to discuss this letter.

Sincerely, Barbara J.B. Green

cc: Susan Borinsky,FTA Scott Biehl, FTA Kathy Sneed, Union Pacific Patrick McGill, Union Pacific Daniel Leis, Union Pacific Larry Svoboda, EPA Region 8 Jody Ostendorf, EPA Region 8 Timothy T. Carey, Corps of Engineers Margaret K. Langworthy, Corps of Engineers Bill DeGroot, Urban Drainage and Flood Control Adams County Board of County Commissioners RTD Board Phil Washington, RTD Liz Telford, RTD William G. McMullen, RTD

Page 14: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page A1-1

ATTACHMENT 1

The following have joined as parties to this letter: Lobo LLC 3556 W. 62nd Avenue Denver, CO 80221 Molen & Associates, LLC Environmental Cousultants 2090 E 104th Ave, #205 Thornton, CO 80233 Toby Hood TDH Properties 5897 Lowell Blvd. Denver CO 80221 Hamid Taha Alpine Lumber Company 5800 N. Pecos St Denver Co 80221 Hamid Taha 3292 W. 62nd Denver, CO 80221 Precision Sample, LLC 7450 W. 52nd Ave., #M326 Arvada, CO 80002 S&W Performance 2450 W. 63rd Ct. Denver, CO 80221 Sanford M. Treat III 3532 West 62nd. Ave.

Denver, CO Eric D Durnell 3090 W. 63rd Ave. Denver Co 80221 Teresa Fanton 3417 W. 62nd St. Denver, CO 80221 Rebecca R. Kokoszka 3220 W. 62nd Ave Denver, CO 80221 Adam McClure 7598 Osceola St. Westminster CO 80030 Dr Russell Knoth 3193 West Longfellow Denver CO 80221 Mile High Sprinklers 62nd Federal Denver, CO 80221 Andrew Jordan Jordan High Pressure Washer 6241 Federal Blvd Denver, CO 80221 Great Western Erectors 6320 Beach St. Denver, CO 80221

Page 15: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page A1-2

Health Restoration Inc. 3220 W. 62nd Ave Denver, CO. 80221 Thomas B. Stevens 3316 W. 62nd. Ave. Denver, Co 80221-1907 Josh Carter 3508 W. 62nd Avenue Denver CO 80221 Jim Hohn 3465 W. 62nd Ave. Denver, CO 80221 Brian T. Bakke 3177 W 62nd Ave. Denver, CO 80221 Christina M. Neher 3100 W. 63rd Avenue Denver, CO 80221 Thomas Ramey Watson, Ph.D., 3537 W 62 AVE Denver, CO 80221-1907 Dana Gillan 6537 Bear Ridge Way Golden, CO 80403 Daniel A. Rief 3393 W 62nd Ave Denver, CO 80221

Perditta Gillan 3124 W. 62nd Ave. Denver, CO 80221 Christina Childs 3412 W 62nd Ave Denver, CO 80221 William Todd Smith 3172 West 62nd Avenue Denver CO 80221 Paul J Heffernan 3360 W. 63rd Ave Denver, CO 80221 Sandra Daley 3196 W. 62nd Ave. Denver, CO 80221 Kim Gillan 3556 West 62nd Ave Denver, CO 80221 Dennis Bosko 3153 W. 62nd Avenue Denver CO 80221 Dr. Richard E. Winnick & Associates 3000 E. 1st Ave #208 Denver, CO 80206 Katherine F. Treat 3532 West 62nd. Ave. Denver, CO

Page 16: Letter to the U.S. Department of Transportation about Adams County rail station

United States Department of Transportation, Federal Transit Administration Region 8 Terry J. Rosapep, Regional Administrator Re: Gold Line Federal Station Reevaluation November 19, 2010 Page A1-3

Lee Gillan 3124 W. 62nd Ave. Denver, CO 80221 Nigel V Alexander 3080 W. 63rd Avenue Denver CO 80221 Katie McClure 3244 west 62nd ave Denver CO 80221 JD Ryan Investments LLC 3220 W. 62nd Ave Denver, CO. 80221 Don Golden 3148 W. 62nd Ave. Denver, CO 80221 Rachel Carter 3508 W. 62nd Avenue Denver CO 80221 Shane R. Kokoszka 3220 W. 62nd Ave Denver, CO. 80221 Marty Hohn 3465 W. 62nd Ave. Denver, CO 80221 Katherine Golden 3148 W. 62nd Ave. Denver, CO 80221

Shannon M. Taha 3292 W. 62nd Denver, CO 80221 Lisbeth Roth 3417 W. 62nd St. Denver, CO 80221 Corrissa Gillan 3556 W. 62nd Ave Denver, CO 80221 Patricia Bosko 3153 W. 62nd Avenue Denver CO 80221 Pat Daley 3196 W. 62nd Ave. Denver, CO 80221 Jeff Fujiki Denver, CO 80221 Rick Gillan 6537 Bear Ridge Way Golden, CO 80403 Alan Gillan 3556 West 62nd Ave Denver, CO 80221 Concerned Citizens for Compatible Development Denver, CO 80221

Page 17: Letter to the U.S. Department of Transportation about Adams County rail station

DISTRIBUTION 11/19/10 letter to FTA: Re: Gold Line Federal Station Relocation

cc: Susan Borinsky,FTA Scott Biehl, FTA Kathy Sneed, Union Pacific Patrick McGill, Union Pacific Daniel Leis, Union Pacific Larry Svoboda, EPA Region 8 Jody Ostendorf, EPA Region 8 Timothy T. Carey, Corps of Engineers Margaret K. Langworthy, Corps of Engineers Bill DeGroot, Urban Drainage and Flood Control Adams County Board of County Commissioners RTD Board Phil Washington, RTD Liz Telford, RTD William G. McMullen, RTD emailed to the following: [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected] hard copy mailed to the following: United States Department of Transportation Federal Transit Administration, Region 8 Terry J. Rosapep, Regional Administrator 12300 W. Dakota Avenue, Suite 310 Lakewood, CO 80228 US Department of Transportation Federal Transit Administration East Building, 4th Floor ATTN: Office of Planning and Environment Susan Borinsky 1200 New Jersey Avenue, SE Washington, DC 20590 US Department of Transportation

Federal Transit Administration East Building, 4th Floor ATTN: Office of Chief Counsel Scott Biehl 1200 New Jersey Avenue, SE Washington, DC 20590 Kathy Sneed Law Department Union Pacific Railroad Company 1400 Douglas Street, STOP 1580 Omaha, NE 68179-1690

Page 18: Letter to the U.S. Department of Transportation about Adams County rail station

Patrick R. McGill Senior Counsel Law Department Union Pacific Railroad Company 1400 Douglas Street, STOP 1580 Omaha, NE 68179-1690 Timothy T. Carey Department of the Army Corps of Engineers Denver Regulatory Office 9307 South Wadsworth Bld. Littleton, CO 80128-6901 RTD Board 1600 Blake Street Denver, CO 80202 Phil Washington RTD 1600 Blake Street Denver, CO 80202 Liz Telford RTD 1600 Blake Street Denver, CO 80202 William G. McMullen RTD 1600 Blake Street Denver, CO 80202