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 4: The alternative formulation and screening process required by NEPA is virtually nonexistent in the SDEIS, and a range of potentially feasible alternatives were not considered.
Basis: General practice in public infrastructure project planning calls for development of a very broad array of alternative plans and then to screen alternatives that don’t meet planning objectives, violate planning constraints or present technical or environmental hurdles too great to overcome. The SDEIS references a screening process conducting in the 2014 EIS.
However, the SDEIS explains that new geotechnical, hydrologic and engineering issues have been identified for the no-build alternative and each of the 2014 EIS’ build alternatives. The iterative process of alternative plan formulation calls for using this new information to restart the screening process to see if the new data affects carry-forward potential of the old alternatives. This was not done. The SDEIS simply scraps the alternatives evaluated in the 2014 EIS.
None of the build alternatives in the 2014 EIS included design/construction of toll systems. None of them called for full-scale replacement of the existing Bayway. All of the build alternatives in the SDEIS call for tolling systems and all call for complete replacement of the existing Bayway.
There is no comparison of modified 2014 EIS alternatives to new alternatives developed in light of the new data.
Alternatives not considered or discussed in the SDEIS include such measures as armoring or retrofit of existing Bayway spans during new construction and build alternatives not requiring any modifications for tolling.
This Comment and Comment 1 are related, but they are not the same. Comment 1 relates to the purpose of an SDEIS and what is expected in reformulation. This comment relates to the conduct of an EIS as if the formulation was started anew.
Without resolution, this issue could halt finalization of the SDEIS.