October 28, 2009

Vincent E. Calametti, P.E.
Division Engineer
Alabama Department of Transportation, Ninth Division
1701 I-65 West Service Road N
Mobile, AL 36618-1109

RE: Project No. ST-002-000-006, Connector between I-65 and I-10, Baldwin County

Dear Mr. Calametti,

We are Mobile Baykeeper, a twelve year old nonprofit organization with the mission of providing citizens a means to protect the beauty, health and heritage of the Mobile Bay watershed. We are writing on behalf our Board, Officers and more than 3,500 members to address ALDOT’s intent to conduct a corridor study to select a route for an I-65/I-10 Connector. This is a major undertaking that requires very close scrutiny from both your department and the community at large. Unfortunately, we were not able to attend the public meetings held last week to view the materials on display. We respectfully request more information on this project including any maps you are making available to the public, continued notice of public meeting, and the decision making timeline.

A significant issue that should be considered in the construction of such a road is a major investment by the State of Alabama's Forever Wild Program, The Nature Conservancy and other conservation groups in 19,000 acres of native Alabama forest habitat along the Perdido River. This investment was made to preserve and restore one of the last areas in Baldwin County with potential to support a fully functioning longleaf forest ecosystem. Conservation groups deliberately focused their moneys and efforts in a section of the county relatively free of development and roadway impacts. More purchases have been planned to expand this conservation area into a 30,000 to 50,000 preserve that would be adequate to preserve all of the longleaf ecosystem components into the 21st century.

This investment could be threatened in multiple ways. Even small alterations to runoff as a result of road construction can severely impact the area's complex small-stream and sheet flow hydrology, which feeds the rare bog ecosystems on properties immediately adjacent to the easternmost route. Collection of multiple small streams and sheetflow in culverts can severely impact the health of acres of downstream wetlands,

as was evident in the U.S. 98 corridor project in Mobile County. At least 17 stream crossings are evident in the easternmost Baldwin County corridor. Two or three crossings are in place on the dry ridge that underlies the westernmost corridor.

Prescribed fire management is essential to the restoration and maintenance of all aspects of the longleaf pine ecosystem, and numerous studies have shown that such forest systems do not survive without frequent fires, with a typical return interval of three times each decade. Because of the complexity of smoke-management issues and other fire-management concerns, the placement of a high-speed, high-traffic corridor next to the Forever Wild preserves is very likely to eliminate the ability to maintain the health of the ecosystem that millions of dollars have been spent to preserve.

This conservation area has also been tagged as a critical refuge for the gopher tortoise, already listed as threatened in counties east of the Mobile Basin, and now proposed for listing in areas west of the basin, and for the threatened indigo snake, slated for reintroduction to this conservation area. Special provisions for these endangered species, including fences, will no doubt be required in the construction of any road. But such structural adaptations will not be beneficial if the roadway impacts the fire regime or the hydrology which is critical to the maintenance of these endangered creatures.

Alabama's last breeding population of black bear has been noted utilizing the Perdido River longleaf corridor. A number of conservation groups in Alabama and Florida, including The Nature Conservancy, have identified the Perdido River longleaf corridor as not only an ideal nursery and foraging habitat for the black bear, but also as a critical link between the remnant Alabama populations of black bear and populations in Florida. Recent university studies have indicated that if the small remnant populations of Alabama black bear remain isolated from populations in surrounding states, inbreeding and genetic bottlenecks are likely to threaten the survival of Alabama's population. Still other studies conducted in Florida have indicated that largest killer of black bears within the state is road mortality from high speed roadways.

We encourage ALDOT to conduct comprehensive studies of the collective environmental impacts of the proposed road project. A thorough analysis of direct, indirect, and cumulative impacts of projects like the I-65/I-10 Connector is required pursuant to the National Environmental Policy Act. Eastern Baldwin County is currently relatively rural, and a project of this scope is going to have significant impacts, both as a direct result of the new roadways and indirectly through the acceleration of growth. Economic and physical growth are not inherently negative things, but unplanned development can have lasting and often unforeseen negative impacts on the region’s culture and environment.

Additionally, we are aware of similar study being conducted by the Baldwin County Highway Department to construct a similar I-65/I-10 Corridor, albeit along a more westerly route. What differentiates the ALDOT plan from the Baldwin County plan? Please send your rationale explaining specifically why and how these two preliminary routes were chosen.

This project must be viewed as one large undertaking. We assert that any permitting that may take place for this project should be submitted as one single plan, with an accompanying Environmental Impact Statement. We also affirm that any wetlands taking possibly associated with such a project should not be reviewed and permitted for fill in a piece-mail fashion as that is a direct violation of the Clean Water Act.

Thank you in advance for consideration of these comments and our requests for further information. Please feel free to contact us with any questions you might have or to discuss these comments.

Sincerely,

Casi (kc) Callaway                                                                                       Donna Jordan
Executive Directory & Mobile Baykeeper                                                  Program Director

Cc:
J. Patrick Courtney
Alabama Department of Environmental Management
U.S. Army Corps of Engineers