Sunday, August 11, 2019
To stop the toll bridge, stop talking about the $2.1 billion alternative...
... and start talking about the alternatives not considered by ALDOT and the Federal Highway Administration.
The National Environmental Protection Act (NEPA) doesn't prohibit unwise decisions. It only prohibits uninformed ones. This truth is worth remembering as we talk about this project to each other and to elected and appointed officials because this decision as proposed is uninformed.
In a rambling op/ed essay submitted to Alabama media outlets last week, Governor Kay Ivey wrote as if the $2.1 billion plan that includes replacing the existing 4-lane Bayway with a new 8-lane structure is the only viable option. It is not.
That plan calls for the new structure to be elevated and built to "withstand the 100-year design storm including the 100-year sea-level rise." (SDEIS Vol I, p. 32) In layman's terms, this is a structure built to hold up in a hurricane with a 1% chance of occurring in any year and driving a water level that is only going to occur sometime between now and 100 years into the future. (Assuming of course that one accepts the United Nations' climate change projections.)
In Joe Sixpack terms, this is like offering only the Champagne Option to a guy with just enough money to buy Miller Lite.
This was the only alternative that was modeled by ALDOT's coastal engineering team. There were no other alternatives considered. In fact, Appendix G (SDEIS Vol II) didn't model the existing Bayway to determine what combination of storm surge and sea level rise would cause enough damage to it to render the expected risk unacceptable. That is, we don't know the expected annual risk of leaving the existing Bayway as it is. So how can we know whether the expected annual risk of the proposed structure is acceptable?
Why shouldn't we demand it be built to a standard that survives the 200- or 500-year storm with 200- or 500-year sea level rise? Why is the 50-/50- standard not acceptable?
For that matter, will a modified, storm-armored and expanded 6-lane Bayway reduce expected annual risk enough to be economically feasible? Economically feasible without a toll, perhaps?
Governor Ivey wrote, "[to] those who say the bridge can be built without a toll, I simply ask you to show us how."
We should reject the premise of this request. It assumes that "the bridge" must be built as proposed. Accepting the premise causes plan opponents to talk about finding different means of paying for it when the discussion should be about alternatives to it. It further assumes that the public is unwilling to accept a level of risk simply because officials deem it unwise to do so.
Last week in this space, we saw that nowhere in the public process of preparing the necessary NEPA documents is it stated that this project's economic benefits are equal to or greater than its costs.
The Benefit-Cost Ratio is a mathematical expression of a project's worth to taxpayers. A BCR greater than 1-to-1 means that the project will improve our economic well being. A BCR less than 1-to-1 means that the project will harm our economic well being. A toll would only make our state's agony worse.
Until this project's BCR is proven to be greater than 1.0, the statement "the cost of doing nothing is too high" is patently false.
How much will it cost us to do nothing, Madam Governor? More importantly, how much will it cost us to do something else? We don't know.
Remember... NEPA doesn't prohibit unwise decisions. It only prohibits uninformed ones.
Read my full review of the project's NEPA documents here.