NEPA Range of Alternatives. The plaintiffs claimed that the alternatives analysis was inadequate because the Final EIS only analyzed two alternatives in detail – the No Build alternative and the six-lane alternative; they claimed the four-lane alternative also should have been studied in detail in the Final EIS. The court rejected this argument: it held that the applicable regulation (40 CFR 1502.14(a)) – “does not use the word ‘range’ or establish a minimum number of alternatives which must be examined” but instead “mandates examination of the reasonable alternatives, together with a brief explanation as to why other alternatives were eliminated.” The court held that FHWA had complied with this regulation, because it reasonably eliminated the four-lane alternative based on a finding that “did not meet the first of the project’s three essential goals: that of improving the mobility of people and goods across Lake Washington in the SR 520 corridor.” Purpose and Need. The plaintiffs also claimed that the purpose and need was too narrow, because the purpose was defined as improving mobility for people and goods across Lake Washington “within the SR 520 corridor from Seattle to Redmond.” They argued that the purpose should have been defined simply as improving the flow “across Lake Washington,” which would allow the purpose to be met by shifting some traffic to I-90, a parallel route. The court upheld the purpose and need statement, finding that “the goal of improving mobility in the SR 520 corridor is not an unreasonably narrow one.” Cumulative Impacts. The plaintiffs also claimed that the EIS did not adequately assess cumulative impacts on wetlands, wildlife habitat, and recreational values. The court concluded that “the cumulative effects section, while fairly brief, is adequate, in large part because there are so few other future projects which would have an incremental impact to be considered as cumulative to this project.” Section 4(f) Avoidance and Minimization Analysis. The plaintiffs challenged the adequacy of FHWA’s Section 4(f) analysis. The court decision does not describe the specific arguments made by the plaintiffs, but simply concludes that “The Section 4(f) analysis here, with its original treatment of both 4–Lane and 6–Lane alternatives in the DEIS, together with exhaustive treatment of the 6–Lane Alternative and Montlake Area options in the FEIS, is sufficient to meet the statutory requirements.” Clean Air Act Hot-Spot Analysis. The plaintiffs alleged that the EIS did not adequately analyze “hot spots” for carbon monoxide (CO) levels as mandated by the transportation conformity regulations n 40 CFR 90.116. Specifically, the plaintiffs argued that the hot-spot analysis should have focused on certain “choke points” where congestion was likely to occur. The court found that the hot-spot analysis was adequate because it focused on three worst-case locations, as determined based on traffic modeling for the year 2030. The court concluded that the plaintiff’s allegation “amounts to no more than a disagreement with the choice of locations to be monitored for CO. Such a disagreement over methodology does not give rise to a claim under NEPA.”