Mobile Long Range Transportation Plan
February 23, 2010
Transportation Planning Coordinator
South Alabama Regional Planning Commission
P.O. Box 1665
Mobile, AL 36633
Dear Sir:
We are Mobile Baykeeper, a thirteen 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 the recommendations outlined in the South Alabama Regional Planning Commission and Mobile Metropolitan Planning Organization’s Long Range Transportation Plan. The potential impacts to the neighborhoods, schools, and businesses of Mobile County outlined in the Plan are vast. This document will guide the decision making process of various city, county, and state agencies for the future growth of Mobile County through 2035. It is imperative that the final Plan will allow the citizens of Mobile County a better commute as well as allowing economic development, all the while enhancing all citizens’ quality of life. Through our review of the MPO Plan, Mobile Baykeeper has concerns regarding the MPO’s limited consideration of several environmental, social, and economic factors, as follows:
1. The Plan started with statistics from 2007 with projections through 2035. Between December 2007 and December 2009 the unemployment rate in Alabama grew by 7.2%. In 2007, growth was at an all time high. The median property value for homes in Mobile was $137,000, while today the average is $120,000 with almost half the number of houses selling. According to the Bureau of Transportation Statistics, total U.S. highway vehicle miles traveled nationally in September 2007 was 246.12 billion, while the amount of miles traveled nationally for September 2009 (the last record available) was 240.72 billion.
2. Taking the changes, especially in vehicle miles traveled, into account, we must ask if traffic on I-65 between Saraland and Celeste Road will really increase from 44,600 vehicles (annual average daily traffic-AADT) to 105,100 as defined in the plan. Several other roadways mentioned in the Plan are predicted to more than double, as well. What is the rationale for these projections while the national trend is fewer cars on the road?
3. Another concern for Mobile Baykeeper is Interstate 65. There is mention of widening I-65 from Saraland which is 6-lane south to Government which is 4-lane, which could cause even more congestion to an already jam packed street with accidents occurring on a daily basis. What are the traffic projections for it if the Saraland to Celeste road is expected to more than double? Why was I-65, which has been described by the Transportation Planning Director as “over capacity now”, completely excluded from this plan for expansion.
4. The Plan does include a very controversial project with a $281.9 million price tag for the I-10 Bayway connector bridge. The bridge is highly contested in the downtown business and residential district for the problems it could add to the area, not to mention the environmental impacts that could occur to Mobile River and the Mobile Tensaw Delta during and after construction. With a bridge underutilized just north of the proposed area, residents and business owners debate the necessity of these risks and expenses. There is $6.6 million for the study Volkert will do for ALDOT included as a priority 1 project. We assume this is an addition to the 2003 study published by Volkert for ALDOT which studied an I-10 Bridge. Another issue that is not covered is the widening of the actual Bayway itself after a bridge is built. What are the costs and the long range plans for that?
5. While we understand that as the Plan does not specify new road alignments and for many widening projects, actual work is not imminent, we are concerned about the lack of discussion on potential wetland impacts associated with these construction projects. We acknowledge that the Plan does have some general discussion on avoidance and mitigation in transportation projects. We also appreciate the mapping of environmental and sensitive resources. However, this mapping clearly illustrates to us that some of the areas for consideration in the plan are in close proximity to critical wetland areas, particularly near Highway 98 and Snow Road as they drain to Big Creek Lake. Does the MPO have even a rough estimate of the acreage of wetlands that may be impacted by the Plan’s proposed projects? This Plan should adequately consider infrastructure development’s impact on our vital wetland resources and water supply.
6. How does SARPC determine which projects to undertake? What gets your road on this list? We were told that the public raising concerns would get a road removed from this list, but do not understand all factors associated with how and why roads are selected and removed as the plan only speaks in generalities about this.
7. Unnecessary idling increases fuel consumption and air pollution, a major area of concern for Mobile County in the immediate future. Where is the funding for upgraded, smarter traffic signals that would have the capability to adapt to traffic congestion, enabling us to travel with less “stop and go?” A preliminary study in Munich showed that smart signals can almost double gas mileage for some vehicles.
8. Speaking of air pollution – where is the review of ozone data? Mobile County will likely be deemed in violation of Air Quality Standards for ozone by the Environmental Protection Agency after ADEM adopts the new recommended standard after August of 2010. A plan for transportation should focus on ways to help us commute smarter, thus decreasing the impacts to air pollution. The Plan should be proactive, not reactive, as seems to be the approach taken to the pending ruling from EPA. Additionally, if everything goes as expected with ozone, Mobile County will be in non-attainment within the first three years of the 25 year plan. Many of the proposed roads cannot be built under those circumstances and the entire discussion is omitted from the document.
9. That leads to a discussion about bike path planning. While federal funding mandates that every new road project includes bike and pedestrian paths, there are still no bike or pedestrian paths included in the new Highway 98 (for example), nor is there a plan to include them on the many stretches of road which would allow bikers to commute to school and work. It is also unclear if the current plan only includes funding for signage, and if so where those signs would be. According to the biking community, signs are for cyclists rather than pedestrians and signs are not effective in protecting a cyclist. Additional lanes and well marked roadways provide a better, safer route.
10. Mobile Baykeeper and other groups are also concerned about how the bike paths were developed. What was the process for data gathering and what groups were involved in route research and selection? Did you reach out to communities who bike, bike shops, bike/running clubs?
11. What outside data resources were utilized for the compilation of the Plan? Was information compiled by agencies such PARCA considered? Did you use any models other than the very dated REMI model?
12. What is the comment process? It appears that you are taking comments through the meeting where you pass the plan. What is the process for reviewing and incorporating the comments? What is the process for responding to the comments? The Federal Highway Administration’s public comment process was established to promote comments to be made to the receiving agency and incorporated into the document. If you sincerely wish to have public involvement on a 25-year transportation plan, you must provide citizens, especially those in the affected areas, an opportunity to speak and be heard. If comments are few on this plan, it is because people know they will simply end up in the recycling bin.
We understand fully that none of these projects will be built this year, but the time is now for careful consideration of all environmental, social, and economic factors to arrive at a Long Range Transportation Plan that fosters sustainable development. This document paints a picture of what Mobile County could look like for the next 25 years. Mobile Baykeeper is not opposed to growth or expansion of transportation infrastructure. The MPO and SARPC should provide the citizens of Mobile County with guidelines that constitute the best possible planning for our community in the long term. We feel strongly that growth can and should occur in a planned and sustainable manner.
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
Executive Director & Baykeeper
cc: Vince Calametti
Mobile Baykeeper Board of Directors
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