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WSDOT does not have to wait for permission from FHA to proceed with rubberized asphalt, they have the option to produce performance-based noise mitigation designs.

WSDOT has not even scratched the surface of the interdependencies in highway design elements that contribute to or mitigate noise.

WSDOT is a bureaucracy that fears more than it innovates, in fear of the studded tire lobby, very little else seems to affect their, with the exception of fear of the fly ash concrete supply lobby, (the cement heads) who lobbied and were approved to burn scrap tires in their concrete kilns. This is purely predatory and anti-competitive private industry behavior being facilitated by a RICO-state/local government, piling-on of greenhouse-gases, waste of rubber resources.

The safety issue with 405 lane expansion that DOT is obviating correlates directly to operational highway system performance.

1. 405 is the major N-S truck corridor, due to I-5 lane restriction in the Seattle downtown mainline.

2. These 405 Bellevue lane expansions are essentially going to be truck lanes 1 and 2, i.e. MERGE lanes.

3. Truck tire spray is dramatically reduced with Rubberized Asphalt. Spray is also major contributor noise source, so it would be fair if (noise impact reduction) testing were conducted factoring in a representative basis of varying weather conditions.

4. RA application literally can improve wet roadway safety-visibility in part of existing lane 3, visibility of cars day and night, even in clear weather, is improved due to higher contrast between rubber asphalt roadway surface and lane markers.

5. Improved visibility through reduction of all vehicular tire wash (including SUV’s, land yacht pick-ups), can even provide for a marginal increase in peak hour speeds = congestion reduction.

6. 405 flow attainment has always been impacted by curves and blind hill rise approaches, take the tire spray out of the equation, also improve clear weather the visibility by reducing glare and improving contrast, especially in these new merge lanes North and South of 90, and the performance of the system can only improve.

DOT should be fully invested in RA beyond the mere disruptive technology threat to their material suppliers, because the only worse place to maintain speed and lane integrity besides a wet crowded 2-lane freeway* is a wet & crowded 4-plus lane freeway.

*Consider I-5 South of Olympia, where there have been 25-car pile-ups and fatalities in recent years, and consider I-90 Bellevue to Seattle, where lanes are about to be narrowed to much less safer margins.

RA has far more benefits than mere noise mitigation.

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