Wednesday, July 17, 2019

Mobile River Bridge Plan is Fatally Flawed: Reason 1

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.

Comment 1: The SDEIS may not be the correct designation for the MRB&B decision document because it replaces rather than supplements the alternatives evaluation of the 2014 EIS.

Basis: A Supplemental EIS is normally prepared when there are (a) substantial changes to the proposed action (new alternatives with attendant new impacts) or (b) new information or data revealed about the impacts of originally proposed alternatives (alternatives more or less impactful than previously described).

Implicit in the NEPA guidance on determining what type of document is best suited is the notion that new alternatives will be added to the range of measures previously considered. An SDEIS is an opportunity to reopen a previous plan formulation process using new information. It is not a basis for starting it anew. It is expected that the full range of both old and new alternatives will be given equal consideration.

However, the SDEIS describes a completely new project bearing little resemblance to any of the alternatives considered in the 2014 EIS, which is purportedly being supplemented with this decision document. The key difference between the projects envisioned by the two documents is in the planning frameworks and the seriousness of consideration of alternatives. The 2014 EIS examined alternatives that widened the Bayway, with only token consideration given to total replacement. This SDEIS examines no widening alternatives and only examines total replacement.

The SDEIS does not supplement the 2014 EIS—it replaces it. If this is not the case and ALDOT is convinced that the SDEIS is the proper vehicle to evaluate new information, then the SDEIS should be revised to evaluate the alternatives considered in the 2014 EIS with the same seriousness and willingness to accept them as it does the replacement alternatives.

Without resolution, this issue should halt finalization of the SDEIS.


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