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 2: There is no economic analysis demonstrating that the proposed project produces an economic OR financial benefit that is equal to or greater than the project costs.
Basis: Economic feasibility drives almost all government participation in public infrastructure projects. Transportation, flood/storm risk reduction, navigation, recreation and even many environmental restoration/enhancement projects are expected to produce a measurable output that has a value making it worth the expected cost. In projects with outputs that can be valued monetarily, a benefit cost ratio (BCR) is computed. A project is considered feasible if its BCR is greater than 1.0 to 1.0.
The only feasibility evaluation that attempted to determine a BCR for a new bridge system was conducted in 1997, for which there is only an Executive Summary available for public review. That feasibility study represents at best a reconnaissance level of detail and cannot be used to justify the project proposed by the SDEIS.
The 2014 EIS includes no evaluations of economic feasibility.
This means that there are no recent analyses of project benefits vs project costs available. Neither the public nor decision makers at the local, state or federal levels can understand why this project makes good economic or financial sense. We have no means to measure this project’s worth vis-à-vis the myriad of other competing uses of scarce public resources.
Without resolution, this issue should halt finalization of the SDEIS.