I submitted an independent review of the Supplemental Draft Environmental Impact Statement (SDEIS) to the Alabama Department of Transportation (ALDOT) on July 10, 2019. As of this writing, ALDOT has not acknowledged receipt of my report, containing 19 specific issues with the project's decision document. The SDEIS is the most important document pertaining to the project. The bridge and bayway replacement cannot go forward without it.
The document is fatally flawed.
Since ALDOT has neither publicly nor even privately acknowledged that they are aware of these 19 specific problems with their decision document, I am sharing them with you, one at a time.
Note: Comments 12-19 are all about the Traffic & Revenue Study, which is the key to how the toll structure was developed. This is Economics 205 level stuff.
Comment 19: The T&R Study is silent on risk and uncertainty, key factors in the judgment of the ability of the project to perform as expected economically and financially.
Basis: The word “uncertainty” is used only once in the T&R Study—in the preparer’s disclaimer of any warranty on the study’s projections or estimates. The word “risk” is used in a similar fashion and only once.
A reasonably thorough discussion of the probable impacts of a project’s non-performance is required under NEPA. None of the important variables subject to uncertainty and capable of increasing risk are even identified. What is the probability that future traffic flow will fall short of forecasts? The correct answer is that we are uncertain. What difference between forecast and actual traffic is enough to drive the concessionaire to insolvency? The correct answer is if we don’t know, we had better find out because we are at risk. Here, the study avoids these discussions altogether.
Without resolution, this issue could halt finalization of the SDEIS.