Wednesday, August 21, 2019

UPDATED: Governor Ivey and bridge proponents suffer major setback as Transportation Tax Project is put on hold

See update below.

Make no mistake about it--Wednesday's unanimous vote to table all items related to construction of ALDOT's Transportation Tax Scheme represents a major setback.

The vote by the Mobile Metropolitan Planning Organization to approve the whole Transportation Improvement plan was quietly expected to sail through a process mandated by a federal law known as MAP-21. Succinctly, MAP-21 requires federal spending to be approved by a local transportation planning group, in this case the South Alabama Regional Planning Commission's MPO.

However, the Facebook Group Block the Mobile Bayway Toll got wind of the gravity of Wednesday's decision and quickly swung into action. MPO members (almost all of whom are locally elected officials) were deluged with comments and fervent requests to either table or remove the specific projects related to the Transportation Tax Scheme.

The MPO carefully and openly considered the merits of the public's concerns and called timeout.

The items tabled today will be held in abeyance until after Alabama Toll Road, Bridge, and Tunnel Authority holds a special meeting on October 7, 2019. ALDOT may not receive or spend any funds on the tabled items until they're approved.

First, this is a setback because this delay likely wrecks ALDOT's schedule. The three private sector contractors cannot submit their final proposals until all clearances have been received. ALDOT had planned to receive those proposals by the end of the calendar year and award a contract in early 2020. That looks unlikely.

Second, this delay also gives creative minds about six weeks to come up with different design and funding concepts for the project. It also gives ALDOT time to conduct at least a cursory coastal storm surge risk analysis on the Bayway modification vs replacement controversy.

This will force project planners to reconsider their alternatives analysis and that in turn has a likelihood of resulting in at least an addendum to the environmental documents approved on August 16. This is another schedule wrecker.

Further, this gives steadfast and well-funded bridge opponents more time to prepare their complaints and file their lawsuits against the project. Those lawsuits will happen if ALDOT and FHWA try to move this project forward as is.

So yes, Wednesday's decision was a very big deal.

Update: The implications on the project schedule were made explicit yesterday by ALDOT Director John Cooper. Cooper was in an informational meeting with area elected officials held after the MPO meeting:
ALDOT’s Transportation Director John Cooper says Mobile Metropolitan Planning Organization’s (MPO) decision to table the vote for funding and the Eastern Shore MPO's consideration to remove the project from the transportation improvement plan (TIP) stops them from requesting proposals. It's tricky because he says officials would want a final proposal first before putting it back in the TIP.
"We can't deliver on what you have asked us to do in the position you have put us in," Cooper said. "We can't bring you a final plan without it in the TIP."
Just as I said. The schedule is wrecked.

Tuesday, August 20, 2019


FACT: The $2.1 billion Mobile River Bridge & Bayway Project has a benefit-cost-ratio less than 1-to-1 and will consume far more economic resources than it produces. The No-Build alternative is more favorable.[1]

FACT: In 2019 dollars, the Bridge alone will have a $6.8 million annual negative impact on the Mobile maritime industry. The economic impact to other sectors (tourism, healthcare, construction, retail trade, etc) is unknown.[2]

FACT: The economic value of storm surge risk to both the existing Bayway and the proposed new Bayway is undisclosed and unknown.[3]

FACT: The Traffic & Revenue Study improperly uses arbitrary inflation rates in its forecasts and uses a lower inflation rate for cost growth and a higher inflation rate for revenue growth, producing artificially distorted net revenues.[4]

FACT: The Africatown/Plateau Community and Downtown Mobile will face higher traffic congestion costs and increased accident risk cost from drivers avoiding the MRB&B transportation tax.[5]

FACT: Mobile and Baldwin area law enforcement and judicial administrative systems face unknown burdens and unknown costs in enforcing transportation tax payments.[6]

FACT: The project includes bicycle, pedestrian and other recreational features that serve neither the stated project purpose or need and have no identified methods of paying for themselves.[7]

FACT: A new toll is a de facto tax increase. Enforced tolls and enforced taxes are treated identically by consumers and businesses in the marketplace. Consumers seek to avoid taxes where practical and/or constrain spending elsewhere. Businesses pass the full cost to consumers through price increases and accept the risk of lost sales. The cost of everything increases.

CONCLUSION: The MRB&B Project represents a bad investment for Mobile & Baldwin Counties, the State of Alabama and the Nation.

Read the full report on the project here.

[1] Draft Environmental Impact Statement, 2014, Table 9, indexed to 2019 dollars using CPI 2012-2019.
[2] Ibid.
[3] Supplemental Draft EIS, 2019, Appendix G.
[4] I‐10 Mobile River Bridge and Bayway – Draft Traffic & Revenue Study Report, May 2018.
[5] Ibid.
[6] Alabama Senate Bill 347.
[7] Final Environmental Impact Statement and Record of Decision, 2019.

Sunday, August 18, 2019

Bridge Economics in Alabama

There are three things certain in life: Death, taxes and the determination of people to avoid both.

Yes, this is going to be a snarky post with a little good ol' smart-assery. Hey... this stuff needs to be said and I have the un-buffered medium with which to say it.

Remember: I am not opposed to tolling as a concept for financing projects with the demonstrated economic benefits needed to support it. I am opposed to projects that do not have the economic benefits that the toll seeks to monetize. Ramming infeasible projects through just because you can is a recipe for economic disaster. Bad tax policy has a bad habit of making bad things happen. Duh.

Tolling defenders claim that the toll is not a tax--you can simply use another route to make the trip. This makes about as much sense as saying sales taxes aren't taxes because you can simply choose not to eat. Or not to wear clothes. Or not to use deodorant. Or not take your anti-psychotic medication. You can choose to be hungry, naked, smelly and crazy and go tax free, right? Your choice.

Come on, folks. If the government makes you pay for the privilege of doing something, it's a tax.

From an economics perspective, a tax and a toll evoke the same response in how businesses and consumers behave in the marketplace. For consumers, the cost is a new item in their budget constraint. To the extent feasible the consumer will avoid paying it and will forego buying something else to pay what cannot be avoided. For businesses, the full tax burden will be added to the cost of the goods sold and the owners will absorb the risk of reduced sales as a result.

A toll and a tax are interchangeable in a model of any economy burdened by either.

So, henceforth this space will use the term "tax" when referring to the cost burden of this project. When you correct the terminology you change the narrative.

"Toll" is a four-letter word.

Even famous people avoid taxes. We're not famous here, but we have our ways.

Under current Alabama law, anyone aged 19 and over can buy a car without being required to simultaneously register the vehicle with the state. This is because Alabama law requires car owners to provide proof of liability insurance when registering their vehicle. Not surprisingly, cars are cheap in Alabama and they're easy to obtain. Look around -- $99 sign and drive (SAD) car dealerships are thriving from one end of the state to another. They don't care about your credit and they might not even check to make sure your driver's license is valid.

Those cars will become very popular if the Mobile River Bridge & Bayway project is built as a taxed route. No tag means no tax.

Alabama drivers are also notorious for failing to renew their vehicle registration, and part of that is because they have also failed to renew their liability insurance. For many, paying the first period's insurance premium and defaulting on the plan is part of the SAD game. But the state still has a name and address for that tag, expired or not. That tag promptly disappears.

This will also be a popular choice among commuters in Mobile and Baldwin Counties, especially among lower income folks. These are the people for whom a new $90 monthly tax has crowded the budget constraint.  Do they renew registration and insurance? Do they look for work in a place with no transportation tax? Do they take a look-see at what others are doing to avoid the tax?

We can also reasonably expect the emergence of a black market dealing in fake or stolen license tags and stolen or hacked electronic transponders. Craigslist and similar sites will surely have any of these on offer.

Tough choices will be made by consumers and businesses and none of them will be beneficial to the revenues of the tax collector.

The ALDOT/FHWA team has decreed that the number of invalid tags using their project will amount to about 5%, and that average weekday traffic on the 2030 established and taxed project will be about 70,000 vehicles. Doing some math gives us approximately 3,500 tax violators per weekday.

If we conservatively assume 48 4.5 day work weeks, we could see 756,000 accused tax cheats every year.

Goat Hill has a plan for all these tax cheats. Alabama Senate Bill 347 flew through the 2019 legislative session, giving the state the power to assess administrative fees on unpaid tax violators; to non-renew vehicle registration of vehicles for failure to pay a tax violation and assessed administrative fees; and to further provide reciprocal agreements with other states or jurisdictions that have also pursued the madness of directly taxing drivers.

What percentage of the 756,000 tax cheats will bite the bullet and pay up? Half, maybe?

That leaves the other half as unrepentant tax cheats in the eyes of the pointy heads in Monkeytown. They are coming after you, you rebellious Gulf Coastians.

This is going to be our administrative and judicial nightmare:
  • There won't be enough local yokels or state troopers on the road to pull over and either ticket or tow the tax dodgers. 
  • There won't be enough room in the impound lots for tax dodging vehicles to be held pending resolution. Towing companies will feast on the carnage.
  • Traffic court dockets will be jam packed with transportation tax dodgers. Our municipal and district court systems will have much less docket space for the real public safety threats like DUIs, reckless drivers, scene leavers and drug traffickers. Real bad guys will get away.
  • What will be done with the people who are on their third or fourth tax cheat citation? Jail them?
  • Vehicle registrations will plummet while $99 SAD auto sales will be steady or climbing.
  • There will be thousands more unregistered and uninsured vehicles on our roadways every year. This is a serious threat to the personal and economic well-being of every safe driver on the road.
  • People will inevitably lose their cars and will also lose their jobs. Another $99 SAD?
  • Traffic on the tax-free route will skyrocket and traffic on the taxed route will drop. 
  • The Africatown Community will be swamped with tax-avoiding but otherwise decent and courteous drivers on the tax free route.
  • The taxed route operator's revenues will suffer, leading to an inevitable increase in the tax rate. The increased tax rate will then drive even more consumers to either constrain their other spending or (more likely) join the growing hordes of tax cheats.
  • The economic output of Mobile and Baldwin Counties will drop. Home prices will fall. Sales tax collections will contract.
  • The Alabama Gulf Coast will be less competitive in recruiting new business. Who wants to locate in an area with depressed personal income, slumping housing prices and higher-than-average unemployment?
This has a very good chance to be the economic picture of the Alabama Gulf Coast in about 10 years, if the MRB&B project is built as planned. 

It doesn't have to be this way. If the ALDOT and FHWA team go back to the drawing board, they can develop an economically feasible plan.  That plan would likely follow the lead of the 2014 EIS, which never recommended taxing the plan's users. That plan would also seriously consider the economic effects of hurricane and storm damage risk. Don't hide behind a leeway-laden standards recommendation. Don't fearfully try to design away 100% of the risk posed by an improbable storm event occurring with an unlikely sea level rise. Instead, compute the expected annual risk of a wide array of alternatives and seek the plan that best balances cost with risk reduction benefits.

The only other alternative is the no-build alternative. The people of the Alabama Gulf Coast are used to storms and hurricanes. We're used to the occasional weekday traffic jams on the Bayway. We know better than to try making an optional Bayway trip on check-in days during the summer tourist season. 

We're ok with it as is.

Saturday, August 17, 2019

ALDOT and FHWA probably violated their own guidance by Doc Dropping environmental clearance

Pardon me while I go policy wonk on you.

On August 16, 2019 ALDOT and FHWA published a combined Final Environmental Impact Statement and Record of Decision (FEIS/ROD) on the proposed Mobile River Bridge and Bayway. This surprised a lot of people, who believed that the changes made between the 2014 EIS and the May 2019 Supplemental are significant enough to make them follow standard NEPA procedure and wait 30 days between publishing the FEIS and executing the ROD.

FHWA guidance allows for "accelerated decisionmaking," but under some fairly strict limitations.

Section 1319(b) "Single Final EIS and ROD Document"
Section 1319(b) directs the lead agency, to the maximum extent practicable, to expeditiously develop a single document that consists of an FEIS and ROD, unless certain conditions exist. Traditionally, and in accordance with the CEQ Regulations (40 CFR 1506.10(b)(2)), FEIS and ROD documents are issued as separate documents with a minimum 30-day period between the FEIS and ROD. Section 1319(b) directs the lead agency, to the maximum extent practicable, to combine the FEIS and ROD into a single document unless:
  1. The FEIS makes substantial changes to the proposed action that are relevant to environmental or safety concerns; or
  2. There are significant new circumstances or information relevant to environmental concerns and that bear on the proposed action or the impacts of the proposed action.

Could demolishing approximately 7 miles of 4-lane Bayway and replacing it with roughly the same length of 8-lane Bayway be a substantial change to the proposed action? One might think that the approximate $1 billion cost increase of doing so is "significant new information."

Could completely changing the proposed action from a toll-free bridge to a toll-bearing bridge and Bayway be considered significant?

Could the economic effect of imposing a maximum $6 toll to pay for the new bridge and new Bayway bear on the impacts of the proposed action?

I guess it depends on who you ask, but I'd love to hear an answer from someone here.

There are still a number of unresolved issues with the decision documents:

  • ALDOT and FHWA have still not provided a demonstration that this project's economic benefits equal or exceed its economic costs. A calculation of the crude benefits estimation in the 2014 DEIS (indexed to 2019 dollars) and compared to the estimated cost of this monstrosity produces an embarrassingly low benefit-cost-ratio of less than 0.50-to-1.0. This would mean that $0.50 would be removed from the economy for every $1.00 invested in the project (this doesn't even account for the drain imposed by the toll plan).
  • They have still not provided a complete risk analysis of replacing the existing Bayway, choosing instead to hide behind a suggestion that it be raised to withstand not just a Hurricane Katrina but the Mother of all Gulf Hurricanes. What is the expected annual risk of leaving the Bayway at the current height and adding lanes to it?
  • They have still not addressed the glaring and potentially unethical use of various inflation rates for cost and revenue forecasts. At best, someone should be permanently barred from doing any more cash flow forecasts on this project. At worst, someone could face charges for fraud.
  • et cetera

These comprise just a handful of the 19 issues I raised with the draft decision document last month. None have been addressed and they are in the public record.

As an extra point, here's an interesting story from's John Sharp from 2014. Please read it.

Tuesday, August 13, 2019

The Facebook Group "Block the Mobile Bayway Toll" is pure American greatness

In less than three months' time, a Facebook Group begun in opposition to a plan to finance a new bridge project for the I-10 corridor between Mobile and Baldwin Counties has grown from a handful of the plan's skeptics into a grassroots movement of just under 50,000 members.  By the time officials release their updated plans in late August or early September 2019, the group's membership will likely top 50,000 and could even begin approaching 100,000.

The bridge project sparking the group has been discussed and planned since the mid-1990's. For about a quarter century transportation planners, business leaders and elected officials have contemplated a fifth route over the  estuary separating Mobile and Baldwin Counties (I'm including the I-65 "Dolly Parton" bridge). Only very recently was the possibility of a toll bridge even whispered about, and even then only in small circles. In 2018 the whispers became a rumor. In early 2019 the rumor became a reality and the boldfaced announcement of a $3 to $6 cost has led to revolt.

Alabama State Auditor was the primary originator of the group, acting on his own time and through his personal Facebook profile. He's enlisted the support of a few assistants but the group discussion essentially runs itself. It's like a 24/7 townhall meeting or non-stop assembly in the public square.

Keep in mind that the American Revolution was a movement that transformed world politics and it all began from a tax dispute. The United States of America owes its existence to the determination of a bunch of unruly, ungrateful and unsophisticated simpletons who believed that their alleged betters most certainly did not know what was best for them. No, this rough-hewn bunch of rednecks had different ideas, and the faraway elites were either going to pay attention or pay a price.

Despite all of the high-minded ideals of equality, neutrality and secular social welfare propounded by today's pointy-headed progressives, the one thing that Americans still love more than anything else is a good old-fashioned rebellion. 

No one in the Facebook Group is advocating an armed revolt. The people of Alabama's only coastal counties are peaceful and law abiding ladies and gentlemen. But facing the unfair burden of a $6 fee for the simple privilege of traveling from one side of Mobile Bay to the other is just too much to bear.

As I am writing this, there is breaking news of a public opinion survey of the two affected counties. According to a sample of 1,495 registered voters, 77% are opposed to the toll bridge plan and 23% support it. There are about 300,000 registered voters in the surveyed population. At least 50,000 of them are motivated enough to have joined a social media group to show their opposition. That number is growing by hundreds each day. The group is active and vocal in their stance. The people have an unfiltered voice and they're speaking loudly.

"No Toll!" stickers and yard signs are popping up everywhere on both sides of the bay. Call-ins to local radio talk shows are all about "that toll bridge." Local TV stations have at least one segment on the subject in every broadcast and have dedicated sections of their websites for stories related to the bridge. It will be the most talked about item in the news for 2019. It will certainly carry into 2020, a Presidential election year that turns out voters in big numbers.

No state or local official who hopes to win reelection or reappointment ignores public sentiment like this. The current bridge and bayway plan may make perfect sense to perceptibly faraway officials in much the same way that the 1765 Stamp Act and 1773 Tea Act made perfect sense to Parliament and King George III.

Whether you are reading this as one of the three-fourths opposed to the plan or the one-fourth in favor, You have to marvel at the fact that the American public's penchant for speaking up and taking action is alive and well.

Tell a bunch of Americans to do what they're told and they'll tell you to go to hell and help you get there.

It's a beautiful thing. It's America, baby.

Sunday, August 11, 2019

To stop the toll bridge, stop talking about the $2.1 billion alternative...

... and start talking about the alternatives not considered by ALDOT and the Federal Highway Administration.

The National Environmental Protection Act (NEPA) doesn't prohibit unwise decisions. It only prohibits uninformed ones. This truth is worth remembering as we talk about this project to each other and to elected and appointed officials because this decision as proposed is uninformed.

In a rambling op/ed essay submitted to Alabama media outlets last week, Governor Kay Ivey wrote as if the $2.1 billion plan that includes replacing the existing 4-lane Bayway with a new 8-lane structure is the only viable option. It is not.

That plan calls for the new structure to be elevated and built to "withstand the 100-year design storm including the 100-year sea-level rise." (SDEIS Vol I, p. 32)  In layman's terms, this is a structure built to hold up in a hurricane with a 1% chance of occurring in any year and driving a water level that is only going to occur sometime between now and 100 years into the future. (Assuming of course that one accepts the United Nations' climate change projections.)

In Joe Sixpack terms, this is like offering only the Champagne Option to a guy with just enough money to buy Miller Lite.

This was the only alternative that was modeled by ALDOT's coastal engineering team. There were no other alternatives considered. In fact, Appendix G (SDEIS Vol II) didn't model the existing Bayway to determine what combination of storm surge and sea level rise would cause enough damage to it to render the expected risk unacceptable. That is, we don't know the expected annual risk of leaving the existing Bayway as it is. So how can we know whether the expected annual risk of the proposed structure is acceptable?

Why shouldn't we demand it be built to a standard that survives the 200- or 500-year storm with 200- or 500-year sea level rise?  Why is the 50-/50- standard not acceptable?

For that matter, will a modified, storm-armored and expanded 6-lane Bayway reduce expected annual risk enough to be economically feasible? Economically feasible without a toll, perhaps?

Governor Ivey wrote, "[to] those who say the bridge can be built without a toll, I simply ask you to show us how."

We should reject the premise of this request. It assumes that "the bridge" must be built as proposed. Accepting the premise causes plan opponents to talk about finding different means of paying for it when the discussion should be about alternatives to it. It further assumes that the public is unwilling to accept a level of risk simply because officials deem it unwise to do so.

Last week in this space, we saw that nowhere in the public process of preparing the necessary NEPA documents is it stated that this project's economic benefits are equal to or greater than its costs.

The Benefit-Cost Ratio is a mathematical expression of a project's worth to taxpayers. A BCR greater than 1-to-1 means that the project will improve our economic well being. A BCR less than 1-to-1 means that the project will harm our economic well being. A toll would only make our state's agony worse.

Until this project's BCR is proven to be greater than 1.0, the statement "the cost of doing nothing is too high" is patently false.

How much will it cost us to do nothing, Madam Governor? More importantly, how much will it cost us to do something else? We don't know.

Remember... NEPA doesn't prohibit unwise decisions. It only prohibits uninformed ones.

Read my full review of the project's NEPA documents here.

Friday, August 9, 2019

Tolling for the Mobile River Bridge is a symptom, not the problem

The largest public outcry over the planned Mobile River Bridge and Bayway is over the proposed $3 to $6 toll on the interstate route between the Virginia St interchange in Mobile and the US 98/90 interchange in Daphne.

But the toll plan is a symptom of a deeper and complex problem. Tolling causes the greatest public angst in the same way that pain causes the greatest personal objection to a deteriorating knee or hip joint. If you treat the symptom you might alleviate some of the pain for a little while.

If you don't get treatment for the real problem--you will never really be free of the pain it's causing you.  Sometimes, addressing real problems means making a sacrifice or two, and facing some hard decisions about what you want vs what you really need.

The real problem with the Bridge & Bayway plan is a poorly executed feasibility investigation and an unnecessary belief that 100% of risk can be avoided with overbuilding. 

There are less costly alternatives that have not been evaluated. There is a level of storm surge vulnerability that we are willing to accept that is well below what might happen in the 100-year storm with 100 years of sea level rise driving it.

This project's problem isn't the toll. This project's problem is a failure to meet a basic NEPA requirement to evaluate a full range of alternatives. It won't be the tolling pain that kills the project. It will be the NEPA failure.

By now, it should be clear that nowhere in the public process of preparing the necessary NEPA documents is it stated that this project's economic benefits are equal to or greater than its costs. 

The Benefit-Cost Ratio is a mathematical expression of a project's worth to taxpayers. A BCR greater than 1-to-1 means that the project will improve our economic well being. A BCR less than 1-to-1 means that the project will harm our economic well being. A toll would only make our state's agony worse.

Until this project's BCR is proven to be greater than 1.0, the statement "the cost of doing nothing is too high" is patently false.

Even if a Federal Leprechuan drops a $2.1 billion pot o' gold in the heart of Crichton, it will still only finance a bridge and Bayway that is overbuilt and unnecessary. 

Reformulate your plan Madam Governor, and you will cure the problem.

Read on for a little sophomore-level economics geekiness.

So, why hasn't the BCR been shown to be favorable?

A part of the answer is on the cost side of the BCR. For some reason, the engineering side of the planning team has adopted a belief that 100% of risk can and should be avoided, and that it's possible to design, build and operate a risk-free system.

In this case it's storm surge risk caused by hurricanes and tropical storms. The planning team has decided that the existing Bayway "is vulnerable to storm surge." The team has also decided that to solve this problem, a new Bayway will be built and elevated, designed to withstand the 100-year flood event that could occur after 100 years of sea level change.

The 100-year flood has a 1% chance of occurring any year. The 100-year sea level rise is expected to occur between now and 100 years into the future. So, we are being asked to pay for a new Bayway designed to hold up in a 1% chance storm that might occur up to 100 years from now. 

That's expensive.

Another part of the answer is that the planners have never truly attempted to investigate the full range of potential beneficial economic effects. Natural resource and public infrastructure economists have developed many tools to measure project benefits, from travel cost savings to risk reduction and from improved labor productivity to more enjoyable recreation experience. All of these are measurable (or at least estimable). 

But no serious investigation of economic benefit has ever been done. There have been reconnaissance level look-and-see efforts, but no real seeking of the answer to the question of why this is a good idea. Simply asking us to accept that it's a good idea is not good enough to ask us to pay more than $1,000 each year.

Engineers and politicians are lousy economists. They are better off finding qualified economics professionals and letting them do that heavy lifting. Then, the engineers and politicians can ask them how they can (and cannot) tell the public why their plan is a better idea than doing nothing.

A couple of other theoretical points that should make sense to most folks:

Proposing a toll system operated by a third party frees the planner from the incentive to consider system total costs. The planners are indifferent to rising costs because their budget constraint is minimally affected. 

Overbuilding--also referred to as freeboarding--frees planners from making a tough decision on what is an acceptable and affordable risk. Mandating that a third party adhere to a design standard that avoids all but insignificant risk frees the planner from responsibility to achieve that level of performance. 

Risk seekers or risk buyers will load that system up to the cost of carrying the risk of very low frequency events. This means that the third party will hedge their bets. They will try to meet the standard, but they will also price in the costs of system failure. 

Wednesday, August 7, 2019

It sure looks like Governor Ivey is "All-in" on a tolled Mobile River Bridge & Bayway project.

Never mind the fact that the documents the state of Alabama is basing this decision on are deeply flawed.

Never mind that nearly 50,000 grassroots Alabamians are dead set against the project. For Governor Kay Ivey, it's "Damn the public, full spead ahead!"

Monday Ivey announced that a meeting of the rarely convened Alabama Toll Road, Bridge, and Tunnel Authority will take place October 7th in Montgomery.
“That bridge is a vital project for commerce and public safety,” Ivey said. “That’s the reason for having the toll bridge road authority meeting – so that people, local, public, press, state leaders can come and share their concerns, but more importantly bring us solutions. We have to have the Bayway and the bridge built for commerce and public safety.”
Ivey was in Mobile to speak at a small business breakfast hosted by the Mobile Area Chamber of Commerce.
What she's not saying is that the real "witching hour" date is most likely August 30, 2019. That is the last Friday in August and the start of the long Labor Day weekend. It also happens to be the time frame for wrapping up the EIS, as revealed by ALDOT in their public meetings last May.

It's a safe bet that ALDOT will file a Final EIS on that date, claiming that the agency has addressed all public comments on the project and seek to have a Record of Decision (ROD) entered in the Federal Register.

There is a 30-day waiting period between finalization and formal entry of the agency's decision. For federal highway projects, the ROD is formal clearance for awarding contracts and beginning the pre-construction efforts.

The October 7, 2019 date will be well after the 30-day waiting period has passed. That means the time for any more meaningful public participation will have passed.

So, unless a court forces the agency to do so, ALDOT will not re-formulate the alternative plans. They will attempt to ignore the glaring technical and policy issues in their SDEIS. They will probably not listen to swelling public opposition to the project, and they will march along an ill-conceived and poorly executed plan to build a bridge that they can't pay for and nobody wants.

PS: Click here for an old but still very useful guide to the NEPA process.  This is aimed at the general public, but it's not "dumbed down" at all. Good stuff.

Tuesday, August 6, 2019

Five Quick Facts, not rumors, about tollroad economics

Five Quick Facts, not rumors, about the economics of a toll bridge:

1. Tolls directly harm state and local tax revenues. Tolls impose an additional cost on all in-person transactions, reducing sales and reducing sales taxes.

2. Tolls are always regressive. Tolls represent a greater portion of disposable income to lower income users than higher income users. And, those with lower incomes are more likely to be compelled by work obligations to either pay the toll and use the road or find less efficient alternate routes.

3. Tolls harm economic competitiveness. The state imposing the toll drives up the cost of everything, placing the affected state or area at a competitive disadvantage compared to areas with toll free transportation.

4. Tolls harm labor mobility. A wage earner is less likely to accept better employment located across a tolled roadway if the wage offered does not cover toll cost.

5. Tolls incentivize law-breaking. Counterfeiters and other black market operators will thrive. Counterfeit tags, tagless vehicles, tag-sharers, tag-concealers and phony transponders will all respond to a tolling regime by finding new and innovative ways to beat the toll.

Read my full review of the Mobile River Bridge SDEIS here.

New York Times catches flack for being truthful

Actually, both of the headlines above the fold were truthful. It was China's desperation move in foreign exchange markets that triggered yesterday's hiccup in financial markets, and President Trump really did make a spirited endorsement for unity in the face of tragedy.

But the far left doesn't want truth, y'all.