Monday, August 5, 2019

Perspective: The Mobile Ship Channel and the Mobile River Bridge

Since 2014, the U.S. Army Corps of Engineers has been involved in the development of a plan to deepen the Mobile Harbor Ship Channel to accommodate larger vessels. The process resulted in a General Reevaluation Report (GRR) and integrated Supplemental EIS, a draft of which was released to the public in 2018. That decision document is in the process of being finalized and almost all of the significant public issues with the project have been resolved.

It's useful to compare that decision document to the one submitted by ALDOT for the Mobile River Bridge and Bayway Project, which was submitted to the public in March 2019.

It should come as no surprise that the USACE documents were as thorough as the ALDOT submissions were scant.

USACE submitted a bona fide Supplemental Environmental Impact Statement. It is not a whole scale replacement for an earlier EIS. While they didn't really have to do so for a Supplemental, USACE did a scoping investigation before beginning their decision document. Extensive public involvement was conducted so that everyone involved was on the same page as to what the decision document would contain.

ALDOT used the 2019 SDEIS as a full replacement of their 2014 EIS. They evaluated alternatives not contemplated in the 2014 document and evaluated none of the 2014 alternatives using the new data purported to be the reason for a Supplemental.

Note: You usually don't need to do Scoping for a Supplemental because the scope is defined by the original EIS. If you are making major changes to the proposed project, a new EIS is required and a new EIS means Scoping.

USACE extended public comment period for their Draft SEIS at least twice, with the last 30-day extension ending July 18, 2019.

ALDOT has yet to respond to my formal request for additional time to prepare and formally submit public comment.

USACE provided a detailed cost estimate, and annualizes costs to incorporate expected future operations and maintenance costs. Costs were estimated for land-side construction activities; dredging costs; Planning, Engineering, and Design (PE&D); Supervision & Administration (S&A); Contingencies; Supervision, Inspection, and Overhead (SIOH); and mitigation.

ALDOT has provided only the briefest summary cost estimate with no breakdown by project category or feature.

USACE used constant dollar forecasting of costs and benefits (FY 2019 price levels).

ALDOT used one arbitrary inflation rate for the forecast of toll costs and and a different, higher arbitrary inflation rate for the forecast of toll revenues.

USACE conducted a thorough economic analysis. They displayed net project benefits and computed the project Benefit-Cost Ratio, demonstrating that every dollar invested in the project would produce approximately $3 in economic benefits to the national economy. If one wanted a conservative estimate of the benefit to the regional economy, a conservative regional multiplier range of 1.15 to 1.45 means that deepening the harbor with the selected plan could have a $1.4 to $1.8 billion to the regional economy.

ALDOT provided no benefit cost analysis at all. They have not stated whether the bridge and Bayway project will have a net positive economic impact to the economy. Nor have they stated whether the project will have a net negative impact.

The total project cost for dredging the channel came to approximately $409 million. The cost for a new Mobile River Bridge and replacement of the Bayway is $2.1 billion.

Why is a cost-shared effort to dredge the ship channel so well documented while the push to build a non-federally financed new bridge and Bayway so poorly documented?

You can read a full report on my review of the Mobile River Bridge & Bayway SDEIS here.


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