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.
Note: Comments 12-19 are all about the Traffic & Revenue Study, which is the key to how the toll structure was developed. This is Economics 205 level stuff.
Comment 18: The 5% estimate for invalid tags is unrealistically small.
Basis: Alabama drivers are notorious for failure to register and/or keep registration current. Under current Alabama law, any individual may purchase a vehicle without simultaneously being required to purchase liability insurance. Since proof of insurance is required to register the vehicle and purchase a tag, a significant proportion of vehicles in Mobile and Baldwin counties do not have valid tags. While it is beyond the scope of this review to estimate tag and registration noncompliance, the percentage of vehicles with no tags will have a significant effect.
Also, a toll bridge creates an incentive to not register a vehicle or to simply remove tags prior to planned trips. This will affect out-of-state drivers as well, since a vehicle with no tag can originate from any state. There is nothing to prevent a driver from any state from stopping just outside the region, removing the tags, and replacing them once the trip is complete.
This study makes no effort to determine what percentage of the historical, existing or future vehicles in the market area are improperly tagged or simply unregistered. The 5% figure is taken from thin air.
Without resolution, this issue is unlikely halt finalization of the SDEIS.
Read the full report here.