Friday, July 15, 2022

The Mobile River Bridge is still not a good investment for the Mobile-Baldwin Community

Three years later, the MRB&B project is still a bad investment. The South Alabama Regional Planning Commission and members of both the Mobile and Eastern Shore Metropolitan Planning Organizations (MPO's) have done a lot of work planning and  cooperating with ALDOT to come up with a plan calling for somewhat reduced tolls for a $2.7 billion project. They believe the project can be completed in under seven years from dirt fly to ribbon cut. But the project's federal decision document has glaring and potentially fatal flaws. 

The following is the complete text of my public comments, uploaded to the comment form on the SARPC website today (minus contact info).

1. The SDEIS is NOT the correct designation for the MRB&B decision document because it replaces rather than supplements the alternatives evaluation of the 2014 EIS.
2. There is no economic analysis demonstrating that the project produces an economic OR financial benefit that is equal to or greater than the project costs.
3. Cumulative impacts to the local and national economy have not been addressed. This is a NEPA requirement that has not been met.
4. The alternative formulation and screening process required by NEPA is virtually nonexistent in the SDEIS, and a range of potentially feasible alternatives were not considered.
5. The evaluation of potential storm surge risk to the existing Bayway in Appendix G is incomplete without a consequence analysis, and storm surge risk is a key factor in the decision to examine any replacement alternatives for the Bayway.

These are HIGH SIGNIFICANCE and LITIGABLE issues that must be resolved without delay.

(The comment form has a 1,000 character limit)

A likely feasible alternative plan has never been evaluated. The recommended plan still has a benefit-cost ratio less than 1-to-1. The storm surge risk analysis is still halfway done. Cumulative impacts to the local and national economy have not been addressed. Any of these issues are litigable, which means that the project is likely to land before a U.S. District Court Judge or Magistrate and ALDOT's counsel will have to explain why a restraining order should not be issued forthwith.

I have offered twice to facilitate a thorough independent expert panel review (IEPR) of the project's planning and decision documents. The offers were made to representatives of both SARPC and ALDOT.  The offer was refused (politely but firmly) both times. The review would have a high probability of resolving the issues I have identified. It would probably find issues that have escaped my notice. 

I have more than three decades of experience conducting, reviewing and either defending or criticizing large infrastructure projects. I have been on both sides of the review process over the last 13 years. More than two dozen projects around the U.S. worth over $200 billion. All went through the process and not one was made worse by the effort. 

I believe a new route across the Mobile River and Delta is badly needed. I believe that a feasible plan can be developed. I believe that tolling cannot be dismissed. I do not believe the current recommended plan is the best buy alternative.

I produced a brief, single page Economic Impact Fact Sheet in 2019 and circulated it among MPO members and other stakeholders. Almost all of these have remained essentially the same but it needs updating. I intend to reevaluate this in the coming days.

I apologize for not keeping this blog active and that's unlikely to change anytime soon. I'm not getting younger and as I age, I'm finding more analog pursuits to enjoy. my megaphone may be dusty but it still boots up.  When I feel it's necessary to speak out, I will. -DL


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