Friday, August 2, 2019

The Mobile River Bridge SDEIS did NOT evaluate 14 alternatives

ALDOT is incorrectly stating that their decision document evaluated 14 alternatives.

Only the No Build alternatives and four build alternatives derived from a previous NEPA document were considered in the SDEIS. None of the other alternatives from the 2014 EIS were considered in 2019.

The inaccurate statements were made during this interview, which aired on August 1, 2019.

A lot of people want to know if there’s another option other than the proposed toll bridge to cross Mobile River and Bay. We went straight to the source and found out there were actually fourteen options.
“The main thing that was against those alternatives were they didn’t meet the purpose and need, and the cost to put in those alternatives exceeded the for-built alternatives we narrowed it down to,” said Edwin Perry, Mobile River Bridge Project Director.

The 14 alternatives mentioned by reporter Cherish Lombard and Mr. Perry appear in the 2014 EIS. That EIS did an acceptable job of alternatives evaluation and most likely identified the best plan.

Mr. Perry says that the 2014 alternatives did not meet the purpose and need (Section 2 of the EIS and this SDEIS). This suggests that the alternatives evaluation this time around is new, and it is not.

Section 2 from the 2014 EIS:

In the Mobile area, there is a need to increase the capacity of I-10 to meet existing and future traffic volumes and to provide a more direct route for vehicles transporting hazardous materials, while minimizing impacts to Mobile’s maritime industry. 

This SDEIS has the following Section 2:

The purpose of this project is to increase the capacity of I10 to meet existing and projected future traffic volumes and to provide a more direct route for vehicles transporting hazardous materials, while minimizing impacts to Mobile’s maritime industry. This section has been updated to provide revised traffic projections from the design year 2030 that was presented in the DEIS to the currently proposed design year of 2040.

These two statements of purpose and need are nearly identical. They both say something needs to be done to increase capacity, improve hazardous material transportation and minimize maritime industry impacts at the same time.

What has changed is a misguided conclusion that the bayway must be replaced at a cost increase and that the only way to pay for the replacement is to impose a toll on users of the project.

Neither the 2014 EIS nor the SDEIS have tolling or storm surge protection as a need or purpose.

In Comment 1 of my SDEIS review, I wrote:

However, the SDEIS describes a completely new project bearing little resemblance to any of the alternatives considered in the 2014 EIS, which is purportedly being supplemented with this decision document. The key difference between the projects envisioned by the two documents is in the planning frameworks and the seriousness of consideration of alternatives. The 2014 EIS examined alternatives that widened the Bayway, with only token consideration given to total replacement. This SDEIS examines no widening alternatives and only examines total replacement.
The SDEIS does not supplement the 2014 EIS—it replaces it. If this is not the case and ALDOT is convinced that the SDEIS is the proper vehicle to evaluate new information, then the SDEIS should be revised to evaluate the alternatives considered in the 2014 EIS with the same seriousness and willingness to accept them as it does the replacement alternatives.

Later, in Comment 4:

None of the build alternatives in the 2014 EIS included design/construction of toll systems. None of them called for full-scale replacement of the existing Bayway. All of the build alternatives in the SDEIS call for tolling systems and all call for complete replacement of the existing Bayway.
There is no comparison of modified 2014 EIS alternatives to new alternatives developed in light of the new data.

The statements presented in the WKRG story are incorrect and misleading.

The readers and viewers of this story are led to believe that a full scale alternative evaluation was conducted and that the recommended plan in the SDEIS is the only one that meets the stated need and purpose.

This is absolutely not true.


Unknown said...

Obviously, we can NOT afford the proposed project, so OTHER less expensive options would be better than nothing and better than one NO ONE can afford. NO TOLLS!

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