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 3: Cumulative impacts to the local or national economy have not been sufficiently addressed. This is a NEPA requirement that has not been met.
Basis: The 2014 EIS is appended by a Martin Associates study that attempts to describe an estimation of economic impacts associated with the various bridge alternatives. None of these alternatives evaluated or included complete replacement of the Bayway, since there were no Bayway replacements given serious consideration in the 2014 EIS.
Additionally, the Martin study only addresses negative impacts and does not estimate potential economic benefits of the project, doesn’t explore project costs and doesn’t mention risk and uncertainty.
The Martin Study also fails to address potential impacts to Mobile-Baldwin County economic interdependence. These two counties are unique in Alabama in that they share proximity to Mobile Bay and the five rivers delta exclusively. The bay and the delta are a primary resource for the economic output and competitiveness of the two counties.
The economic livelihood of Mobile County is closely tied to that of Baldwin County, and vice versa. There are many people who live in Baldwin and commute to Mobile for work. The reverse is true as well. Imposing a toll on Mobile and Baldwin County commuters will have a significant impact on the productivity of both county economies. A toll (or a tax) on Mobile County drivers is a toll (or a tax) on Baldwin County economic output and vice versa. The SDEIS does not address this issue.
Further, the Martin study describes only local impacts and is limited to an unreasonably small number of sectors in the economy. The Martin study does not address impacts to the national economy at all and fails to address impacts to commercial navigation though to Mobile Harbor Ship Channel and Turning Basin. The U.S. Army Corps of Engineers recently completed a study on the feasibility of deepening this project. Yet the SDEIS is silent on how the two projects may interact during construction and/or during maintenance operations of either or both.
The 1997 and 2012 economic evaluations are both too old, too superficial and too incomplete to determine what net economic benefit accrues to the proposed project. The communication of both detrimental and beneficial economic impacts is crucial to gaining local, state, regional and national acceptance of such a large, complex and expensive project.
Without resolution, this issue could halt finalization of the SDEIS.