Cary Moon, founder and director of the People's Waterfront Coalition, did yeoman's work poring over the draft environmental impact statement on the deep-bore tunnel, which was released publicly on Wednesday. In her detailed analysis, Moon makes a strong case that the state, at every turn, skewed its criteria so that only the deep-bore tunnel would make the cut.

"This project EIS rewrites the goals so they are tailored to the tunnel alternative, and rewrites the official statement of purpose and need so that only a capacity-replacing highway (tunnel or elevated) can win," Moon writes.

"This EIS makes a mockery of the [State Environmental Policy Act] process by tailoring the goals, criteria, and evaluation to fit just one alternative, and excluding consideration of transit or other approaches."

For example, the state didn't study the recommendations that came out of a lengthy stakeholder process in 2008, which included not just the bored tunnel but the I-5/surface/transit option.

The analysis also ignores numerous other cities that have removed urban highways and found that doing so actually decreases traffic, greenhouse-gas emissions, and congestion, because people change their behavior to adapt to life without the highway. "WSDOT's computer models are just not an accurate measure of future human behavior."

And, as I noted in my post yesterday, the state acknowledges in the report that it "updated" the purpose and need statement for the tunnel to refer explicitly to "capacity," not "mobility." The I-5/surface/transit proposal wouldn't preserve the viaduct's car-carrying capacity, but it would improve mobility, by investing in transit and improvements to I-5 and surface streets downtown. The new DEIS also removes "environmental stewardship" and "fiscal responsibility" as goals of the project.

Additional issues Moon raises about the report, some of which I covered yesterday:

• The analysis of traffic in the deep-bore tunnel, astonishingly, doesn't include tolls. This is important not just from a revenue perspective, but from a traffic diversion perspective. The state's separate tolling analysis assumes that $400 million of the state's $2.8 billion contribution will come from tolls as high as $3.50 for a one-way trip. Tolls that high would shift as much as 40 percent of the projected traffic on to surface streets, Moon says. That's in addition to the 30,000 cars that would shift to surface streets and I-5 because the tunnel lacks any downtown exits.

• The shoulders in the proposed tunnel would be just two feet wide on one side, six feet wide on the other. "How does that work for clearing wrecks or getting a firetruck or an ambulance in there?" Moon writes. Additionally, there will be no way for handicapped people to escape the tunnel in case of a fire; instead, they'll have to wait in designated "refuge areas" for emergency personnel to come get them out.

• Twelve historic buildings in Pioneer Square will be at risk of damage due to ground settling and water movement during construction.

• As I noted yesterday, the tunnel would increase greenhouse gas emissions because it facilitates private auto use, in direct defiance of state policy that mandates emissions reductions of 50 percent below 1990 levels by 2050. That kind of reduction requires a reduction in private auto use, which produces 31 percent of emissions statewide (and half of emissions in the Puget Sound region).

On the political side, Moon argues that the sequencing of tunnel approval by the city—the city council could vote as early as Monday to sign an agreement with the state that does not contain language demanding a change in state law to let Seattle off the hook for cost overruns—is "crazy."

"City leaders have been backed into a corner, with pressure to decide now or else. With only one solution on the table. Without even knowing the impacts, or having an open dialog with the public to consider whether the benefits outweigh the costs and risks. Without having a chance to negotiate adequate solutions or mitigation. What a mess. This is not how SEPA law is supposed to work, it's not good project leadership."

Moon goes so far as to suggest that the city back out as a lead agency on the project: "It's that bad."

That's unlikely, but the city council is undeniably in a tricky political situation. A lot of voters don't like the tunnel; a majority or a plurality, depending on how you ask the question, really don't like the idea that the city could be on the hook for cost overruns. Five council members are up for reelection next year. If tunnel opponents continue the cost-overruns drumbeat—and there's no reason to imagine they won't—the issue could end up haunting incumbents next election cycle.