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 6: The SDEIS contains only top-level construction cost estimates and the costs disclosed lack enough detail to be evaluated for reasonableness and realism.
Basis: Project costs have more than doubled since publication of the 2014 EIS, from $773 million to $2.1 billion, a highly significant escalation. While the shift away from Bayway modification to Bayway replacement can account for some of this increase, the public must be provided with a transparent accounting of costs. Section 4.4.4 is the only section of the SDEIS that discusses project costs and it does so in only the broadest and briefest terms.
There is no cost appendix to the SDEIS. There is no breakdown of project cost by feature, year, task, etc. This is an unacceptable lack of full disclosure under any reasonable interpretation of NEPA. The public has had no opportunity to examine the detailed cost estimate of the recommended plan or any of its alternatives.
Public disclosure and review of project costs is necessary under NEPA guidance.
Without resolution, this issue could halt finalization of the SDEIS.