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 16: The assumptions regarding historical, existing and expected future traffic patterns and growth do not appear realistic.
Basis: Negative growth in traffic between 2005-2014 assumed to be related to increased gas prices and the 2008-09 financial crisis and recession. This assumption does not address technological growth during this period (eg, iPhone introduced in 2007) and remote work capability. Also, 2004 and 2005 were the years of Hurricanes Ivan and Katrina respectively, which temporarily altered traffic patterns due to recovery efforts (debris management, construction, temp relocations, etc).
Using the 10-year period between 2005-14 thus does not likely reflect the true underlying historical traffic growth. The T&R Study should explore a more detailed economic setting that addresses the effects of back-to-back storm years, reduced traffic flows due to technological growth and other external factors affecting traffic on the I-10 corridor between the AL/FL line and the AL/MS. Line.
Without resolution, this issue is unlikely to halt finalization of the SDEIS.
Read the full report here.