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 8: The SDEIS incorrectly states that availability of funding affects project viability.
Basis: Section 3.7.2 states: ”[b]ecause of the funding challenges ALDOT and the Federal government are currently experiencing, the project is only viable if the corridor is tolled.” This is incorrect. Funding availability has no bearing on economic or financial feasibility. Under NEPA, any economically and/or environmentally feasible alternative is considered viable. The project is either viable regardless of how it’s funded, or it’s not.
Furthermore, there is no evaluation showing that all reasonable non-tolled alternatives are economically infeasible and thus provide no net economic benefit over the no action alternative. The SDEIS does not evaluate tollfree alternatives at all.
Without resolution, this issue could halt finalization of the SDEIS.
Read the full report here.