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Citizens seek action to protect our health, property, and drinking water supply


On March 22, the Acadiana Group of the Sierra Club and the WaterMark Alliance delivered a letter to local Lafayette leaders asking for immediate actions responding to contamination of our Chicot Aquifer water source and abandoned railyard site downtown. An article in The Independent by Wynce Nolley titled Green alliance offers advice to LCG on water contamination describes this letter and provides additional background information.

Express your opinions and concerns to the Lafayette mayor-president and council! Contact them by phone, email, or postal mail. Contact details for all these leaders are available in the previous post titled Who is my council member? Who is the mayor-president? How do I contact them?

The March 22 letter states in part:
"The contaminated railyard site next to our downtown and residential neighborhoods perches above water wells that provide much of our municipal water supply. Beyond the obvious risk to neighbors’ health and property resulting from this un-remediated site, we now see clear evidence that it is contaminating our aquifer. Currently, we are pumping millions of gallons of water every day from the LUS water wells near sites of contamination. This continued pumping poses a threat to our aquifer and the future health and prosperity of our city."
Evidence of contamination appearing in LUS drinking water wells was presented at a January 19 meeting organized by the Sierra Club. The measured concentrations are below EPA Designated Contaminant Levels and are measured before treatment. However, contaminants reaching our water wells “present a warning to the public and our civic leaders that action is needed” said Harold Schoeffler, chair of the Sierra Club Acadian Group. Attention has been focused on the abandoned railyard in downtown Lafayette since DOTD has revived their plan to construct I-49 over the railyard site which is known to be contaminated with toxic substances including some of those being monitored in nearby LUS wells. Schoeffler went on to say that “both property and public health require protection.” A  March 22 letter from the Sierra Club Acadian Group and the WaterMark Alliance to Lafayette Mayor/President Joel Robideaux and Council members makes the following ten recommendations:


  1. Plan and execute a study of surface contamination within the wellhead protection area of our wells. Include sampling for all contaminants that have been monitored in LUS well water, and for contaminants found at other US rail sites which are either undergoing or have been remediated.
  2. Where appropriate, partner with other state and federal agencies.
  3. Intensify sampling of well water by increasing the frequency of sampling and adding contaminants for analysis to include all known or suspected contaminants present on the surface or in the surficial aquifer (groundwater just below the surface).
  4. Make all past and current well monitoring and sampling data easily available for public review and analysis.
  5. Begin contingency planning for shutting down all wells in the vicinity of the North Treatment Plant. Abandoning some or all of these wells may be necessitated in the future to allow aquifer remediation through recovery well operation or other groundwater cleaning technology.
  6. Identify responsible parties and methods to recover ratepayer and taxpayer costs.
  7. The abandoned railyard site is a public hazard and should be posted as such. It is known to be contaminated with arsenic, asbestos, lead, and many other contaminants which endanger public health from dust and direct contact.
  8. Public access and parking of any vehicles on the abandoned railyard site should be immediately prohibited.
  9. Determine new protection measures to be fully integrated into policy.
  10. Ordinances based on LDEQ drinking water protection sample ordinances should be drafted and adopted.

Schoeffler hopes to see a response to these recommendations at future meetings of the Council and Utility Board.

The letter's civic leader recipients were:

  • Joel Robideaux, Mayor-President
  • Kevin Naquin, Council Member District 1
  • Jay Castille,  Council Member District 2
  • Patrick Lewis, Council Member District 3
  • Kenneth P. Boudreaux, Council Member District 4
  • Jared Bellard, Council Member District 5
  • Bruce M Conque, Council Member District 6
  • Nanette Cook, Council Member District 7
  • Liz W. Hebert, Council Member District 8
  • William G. Theriot, Council Member District 9

Copies of the letter were provided to Terry Huval, P.E., Director, LUS, and Craig Gautreaux, Water and Wastewater Operations. Manager, LUS. A copy of the signed letter is attached below or can be viewed online by clicking here.
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Who is my council member? Who is the mayor-president? How do I contact them?


Lafayette City-Parish Council

Do you know your Lafayette Parish Council district number and your council member's name? If not, the city-parish makes it easy to find out. Follow this link to the Lafayette Parish Council web site and click on Council Districts map or to find your Council Member

Once you know your district number, you can find contact information from the Clerk of Council handout shown here 


Mayor-president Joel Robideaux
Now, how about our mayor-president? Our current mayor-president is Joel Robideaux, His contact information from his LCG web site is:
Phone: (337) 291-8300
Mailing Address: PO Box 4017-C, Lafayette, LA 70502

When you do meet, phone, write, or email our civic leaders, I suggest that you start the exchange on a positive note. Thank them sincerely for their time and/or service to the community. Perhaps mention other areas where their support has helped you or the community. Then, ask for their help and support on the specific issue that led to you contacting them. Even when you do not succeed in getting their support, you may at least soften their opposition by showing that you have well thought out ideas.

If you do contact our leaders, and if you choose to share your experience, please tell us about it in a comment to this post.




More Evidence of Chicot Aquifer Contamination: USGS Monitoring

SUMMARY: The United States Geological Survey (USGS) established a monitoring well at our Lafayette North Water Treatment Plant in 2001. This well was drilled to a depth to sample the top of the Chicot Aquifer. The water plant and monitoring well are located near known surface contamination. Data collected from this well since 2001 demonstrate that in spite of the existence of a clay confining layer above the Chicot Aquifer, contaminants flowed down into the aquifer which is our sole source for drinking water in Lafayette Parish. These findings are consistent with other evidence, and support the recommendation that action is urgently needed to protect our Chicot Aquifer.

Introduction
Old rail lines and railroad maintenance and switching yards are typically contaminated with a long list of toxic substances including arsenic which was extensively used at rail sites as a preservative for railroad ties, poles and structures, as a weed killer, and as a pesticide. Citizens are concerned because our north drinking water treatment plant and many of our Lafayette Utilities System municipal water wells are adjacent to the old rail line and just north of the former Lafayette railyard.  

Lafayette's municipal wells draw our drinking water from the Chicot Aquifer which has been designated as our sole-source aquifer. Parish citizens have been assured that our local geology protects our sole-source of drinking water from contamination because an impermeable clay confining layer separates the contaminated surface from our water well intakes deep in the Lower Sand formation of the Chicot Aquifer. This assertion of protection has been made for decades despite clear evidence that it isn’t true. I will provide additional evidence of this contamination in a future post. Here, I describe observations of Chicot Aquifer arsenic contamination in samples from the monitoring well at the downtown Lafayette North Water Treatment Plant.

USGS Monitoring Wells
In 2001 through 2002, the United States Geological Survey installed 28 shallow monitoring wells throughout Lafayette Parish (Figure 1) to survey levels of shallow groundwater contamination (Fendick and Tollett, 2004). Wells were placed in urban, residential, and light commercial areas. These wells were drilled to a depth that reached the top of the upper sand of the Chicot Aquifer (Figure 2). This monitoring was a part of the USGS National Water Quality Assessment Program.

Figure 1. Lafayette Parish monitoring well locations from Fendick and Tollett (2004).

Cover1-Fendick+Tollett-2003-report-4118.jpg  Cover2-Fendick+Tollett-2003-report-4118.jpg
Figure 2. Photos of monitoring well installation from Fendick and Tollett (2004).

One of these wells designated well number 116 in the report (USGS site 301355092005601) was installed at the Lafayette North water treatment plant. The well was drilled to sample water from 55 to 65 feet below surface in the Upper Sand of the Chicot Aquifer. This site is near several of our municipal water wells, and is within a few hundred feet of railroad track which has been in use for over a century (Figure 3).

 
Figure 3. Google maps image showing the approximate location of monitoring well 116 as red marker in upper right of the image (personal communication, Rolland Tollett, 2017). Note the proximity of the well with the railroad track which parallels Sherman St.

Arsenic Contamination
Among all the 28 Lafayette Parish monitoring wells, well #116 at the Lafayette North Water Treatment Plant had the highest measured arsenic concentration (Figure 4.). Arsenic and creosote are the most common contaminants associated with rail operations that occurred from the 1800s up to the 1960s (Connector Comments, 2017). Arsenic was used as a wood preservative for rail ties and other wood, for killing weeds, and for killing pests. Arsenic contamination is also a legacy contaminant in areas that were cotton fields in the 1800s and first half of the 1900s. It is not the topic of discussion here, but it is interesting to note that well #113 which has the second highest arsenic concentration (Figure 4) is located at the LUS South Water Treatment Plant. The South Treatment Plant is surrounded by agricultural fields which may have legacy arsenic from pesticide applications, and has a total water production capacity similar to the North Water Treatment Plant. Pumping at both plants may be increasing the rate with which contaminants are drawn into the Chicot Aquifer.




Figure 4. Well ID numbers are displayed on the vertical axis. Arsenic concentration measured from 2001 to 2002 in micrograms per liter as arsenic from the 28 Lafayette Parish monitoring wells in Lafayette Parish show well 116 (solid red bar) had the highest concentration of 5.7 ug/L  (Fendick and Tollett, 2004).


Figure 5. Arsenic concentrations at well #116 continue to be elevated throughout all available monitoring history  (Fendick and Tollett, 2004).


Frederick and Tollett (2004) also used CFC concentrations and other data to estimate the apparent age of the groundwater in the Upper Sand of the Chicot Aquifer in Lafayette Parish. They found the apparent age of the groundwater varied with water level and ranged from about 12 to 50 years with a median of less than 32 years. Well #116 at the LUS North Water Treatment Plant had an apparent groundwater age of 41 years. Water age estimates the average time that water has been present in the underground formation. Therefore, the contaminated water contributing arsenic to the mix is probably much younger than the average age which should include at least some very old water. These CFC age estimates are further discussed by Darling (2005). Those findings provided clear evidence that groundwater recharge from surface water is common throughout Lafayette Parish, and this local recharge can lead to groundwater contamination.

Well Water Level
Data shows that the water level (termed the static head which is a measure of the pressure in the aquifer) in well #116 is dropping over time. Water level in this well in November 2001 when it was first measured was 45.72 feet below land surface. In the most recent available measurement taken in April 2014, the water level had fallen to 48.56 feet below ground surface. The observed head confirms that the well is indeed sampling within the Upper Sand of the Chicot Aquifer, and that there is a strong hydrologic connection between this sand and the Lower Sand below it where most of our drinking water is withdrawn. The large difference in head (i.e. pressure) between the surface aquifer above and the Upper Sand of the Chicot aquifer below it drives a flux of water and contaminants moving into the Upper Sand. A future post may provide further interpretations of Chicot Aquifer groundwater head measurement data.

Figure 6. Head of water observed in well #116 in feet below the ground surface is plotted. Elevation of the ground surface at the well is 39 feet (1929 NGVD). The solid red line is an Excel generated trend line through the data points which is dropping at approximately 2.6 feet per decade.

Conclusions
Lafayette Parish inherited a plentiful and sustainable drinking water resource in the Chicot Aquifer. The findings presented here, as well as numerous other lines of evidence, lead to the conclusion that the Chicot Aquifer in Lafayette is at risk. Although a confining layer may impede flow, it does not stop surface contaminants from entering and contaminating the aquifer. Data from USGS monitoring well #116 demonstrates that surface contamination in the vicinity of a number of our Lafayette municipal water wells has and does reach the Chicot Aquifer.

The Chicot Aquifer is a resource which could provide water resources for many future generations. It is our responsibility to protect this inheritance. However, neglect and mismanagement can rapidly destroy this legacy.
Acknowledgement
The data presented here were downloaded from the USGS online National Water Information System (NWIS) public data server. Except where cited, all interpretations and opinions are those of the author, Michael Waldon.

References

Fendick Jr, R. B., and Tollett, R. W. (2004). "Quality of Water from Shallow Wells in Urban Residential and Light Commercial Areas in Lafayette Parish, Louisiana, 2001 Through 2002." Water-Resources Investigations Report 2003-4118, US Geological Survey.


Why are there high levels of arsenic in some Acadiana soils?

Figure 1. "4 Sources of Arsenic You’d Never Expect"

Introduction - The issue of arsenic contamination may at first appear to fall outside the scope of I-49 Connector (The Con) questions. However, arsenic contamination of our soils is an issue that does intersect with The Con's issues. In this post I will give some background about how elevated arsenic came to be in our parish soil, how it can impact us, and what we need to do about it.

If you recall the periodic table from your school days, arsenic is chemical element number 33 with the symbol As. Arsenic falls in the table just below phosphorus in column 15, and this means that arsenic may react in ways that are similar to phosphorus and disrupt some chemical reactions that are essential to life.

Sources of arsenic contamination - Arsenic was used for many purposes in the past, but is much less widely used today. In the southern US, arsenic pesticides in the form of lead arsenate dust and other formulations were regularly used on cotton crops to control boll weevils prior to the development of organic pesticides like DDT in the middle of the 20th century (Figure 2).
Figure 2.  Dusting cotton from"A is for arsenic" Wired 6/19/2012

Figure 3. "Arsenic and Old Railyards" F. Harrison
Along side sugar cane and livestock, cultivation of cotton provided an economically important income for Lafayette farmers since the earliest days of our town then named Vermilionville (Griffin, 1959).  Cotton farming has now come to an end in Lafayette Parish (Soil Survey of Lafayette Parish, LA, 1916Soil Survey of Lafayette Parish, LA, 1977NRCS Web Soil Survey, 2017), but in many places the legacy of arsenic pesticide use remains in our soil. Today in Acadiana, many sugar cane and rice fields cover the ground where cotton once grew, and the legacy of arsenic contaminates our rice crops (C. Poterra, 2007; B. Goodman, 2011;  T. Greenaway, 2012Consumer Reports, 2012). Recent spreading of suburban development on our former cotton fields may also lead to routine but unrecognized exposure of Acadiana families to arsenic.

Arsenic was also used routinely in railroad operations to preserve rail ties and other wood, and to kill weeds along the right-of-way (MADEP, undated) so that engineers had an unobstructed view ahead and along each side of the tracks. Planned "rails-to-trails" projects have been complicated or even blocked by by the discovery of elevated soil arsenic levels leading to unanticipated clean-up costs (Ciabotti et al, 2004). The Rails-to-Trails Conservancy has published a compilation of case studies and guidance related to understanding contamination issues (Ciabatti et al, 2004), and the State of Massachusetts has recognized that repurposing of abandoned railroad routes poses a risk, and have published guidance in the form of Best Management Practices (BMPs) for the development of rail-trails (Massachusetts DEP, undated).

The railroad was completed to Vermilionville in 1880, and today continues to run through our city which is now named Lafayette. The arrival of the railroad connecting New Orleans and Houston brought jobs, growth, prosperity, and commerce to our city. Steam trains which burned bunker oil had limited range, and all trains passing through Lafayette had to stop for refueling and to take on water and sand. The Lafayette railyard grew to be a major facility employing up to 1000 workers and providing complete maintenance service for the early steam engines (Griffin, 1959). There is now concern that the downtown railyard which was abandoned in the mid 1960s (Louisiana DOTD Draft Phase I ESA, 2016) will contaminate the Chicot Aquifer and our municipal water wells (C. Taylor, 2016).

Arsenic contamination of old railyards and rail lines has been found across the US. The abandoned Union Pacific Railroad Ashland site in Oregon is likely typical (Harrison, 2008). This railyard has similarities in age and past uses to the abandoned Lafayette yard, but the Ashland site is roughly half its size and poses little risk to water supply wells or local groundwater below the surficial level. The UPRR-Ashland site operated as a locomotive maintenance and refueling station from 1887 until 1986. Also, in contrast to Lafayette, the UPRR is actively working to remediate the Ashland site.

Figure x. Cultural Thoughts
Health impacts of arsenic - Despite the fact that arsenic has been used as a poison for centuries, the more subtle chronic health impacts from long-term exposure were often not recognized in the past, to the extent that low doses of arsenic were often used as a medicine or tonic (Wikipedia-Arsenic Poisoning History). It is now recognized that chronic exposure to arsenic can cause many ailments including thickening of the skin, darker skin, abdominal pain, diarrhea, heart disease, numbness, stroke, diabetes, chronic respiratory disease, and cancers of the skin, lung liver, and kidney. There is no evidence based treatment for chronic exposure; therefore, management must be focused on reducing exposure (Ratnaike, 2003).

Arsenic standards, levels, and limits - The USEPA sets standards for allowable concentration of contaminants in drinking water. These are called Maximum Contaminant Levels or simply MCLs. In setting an MCL, EPA first determines what concentration of contaminant would cause no health effect, and terms this concentration the Maximum Contaminant Level Goal or MCLG. In setting the MCL, EPA considers the cost and practicality of treatment weighed against the public health risk for the specific contaminant. The MCLG for arsenic is zero, meaning that there is no minimum concentration below which there is no health risk. In 2000, the EPA initially proposed an MCL of 5 ug/L (micrograms of AS per liter), but considered other levels of 3, 5, 10, and 20. After comments were received and reviewed, the final and current MCL for arsenic was set at 10 ug/L with an MCLG of zero.

In the US, public water suppliers are required to test for arsenic and meet standards after treatment. However, many private wells may be untested and can be a significant risk to adults and especially to children. The short 10-minute film In Small Doses: Arsenic gives useful background information on the risks from arsenic and discusses the risk of arsenic exposure from private wells in New England.

Beyond the concern for exposure to arsenic through rice which was mentioned above, other foods can be a pathway for exposure and risk. A 2012 study by Consumer Reports provides much useful information. The FDA does not currently regulate the amount of arsenic that can be present in our food. However, Dartmouth University's Children's Health web site recommends that we should: (1) limit rice consumption, choose white rather than brown rice (2) limit apple juice consumption, drink other juices, or skip drinking fruit juice (3) read labels because rice sweetener in the form of brown rice syrup is used in many foods. Dartmouth also recommended always rinsing rice before cooking, but recent research reported by the FDA shows that rinsing rice before cooking results in very little arsenic reduction, but does reduce some valuable nutrients. Gardening on arsenic contaminated soil can present concerns. The Washington State Cooperative Extension has published guidelines for gardening on lead and contaminated soils (F. Peryea, 1999). One simple recommendation is to carefully wash garden fruits and vegetables to remove all traces of soil before eating.

In addition to arsenic exposure from food and drinking water, exposure from breathing contaminated air must be limited. For employees, OSHA sets exposure limits based on an 8-hour average concentration of arsenic in air. OSHA sets the arsenic action level at 5 micrograms of AS per cubic meter of air. Personnel working on the abandoned railyard property and along the rail line should take care to limit their exposure to contaminated soil and dust. Lawn mowing and weed control, for example, may produce dust contaminated with arsenic and other soil contaminants. And, it follows that the public needs to be assured that they are protected from dust blowing from these sites through careful management of all activities on the sites which may create dust leaving the property boundaries.

Y-49 takes a turn: Public meeting summary and video, January 19, 2017

This post compiles information from the Y-49 public meeting held on January 19, 2017 at the Lafayette Public Library. Roughly 100 citizens attended this meeting. Video of the meeting was produced by the Acadiana Open Channel (AOC), and the full two hour meeting video is available through YouTube.

In the summary that follows, direct links to the beginning of each speaker's presentation are provided for your convenience.
Meeting announcement.

Woody Martin welcomed the public on behalf of the Acadiana Group of the Sierra Club, and provided introductions of the evening's speakers.
     https://youtu.be/PTu1xtmUDGs?t=11s

Bill Goodell has been an environmental attorney for over 30 years. He shared some of the results of his investigations into contamination from the abandoned Union Pacific Railyard in downtown Lafayette, which sits above the Chicot Aquifer, Lafayette's drinking water source. His information came primarily from publicly available records. Goodell focused attention on p-dichlorobenzene (p-DCB or simply DCB) which has been monitored for several years in LUS water wells beneath the railyard. DCB does not occur naturally; it must originate at the surface. Because DCB is one of many known contaminants at the abandoned site the legal presumption is that the contamination originates from the contaminated railyard site. In 1974, the Louisiana constitution required conservation of our environmental resources and protection of the public. Public bodies have a duty to uphold this constitutional requirement, referred to as the public trust doctrine.
     https://youtu.be/PTu1xtmUDGs?t=3m44s


Kim Goodell leads the local WaterMark organization. She provided a history of citizen opposition to the I-49 Connector project and discussed the need for our political leaders to integrate the public trust doctrine into their actions. She stated that because of the public trust doctrine our local and state officials are expected to not simply be reactive, but be proactive in protecting the public from risks like drinking water contamination. Why have our local officials been less than aggressive in carrying out their constitutional duty?
     https://youtu.be/PTu1xtmUDGs?t=29m45s

Michael Waldon, PhD, is a retired from a career as an environmental engineer, hydrologist, and professor at LSU and UL-Lafayette. Dr. Waldon described the Louisiana DOTD Phase I Environmental Site Assessment (ESA) of contamination within the footprint of the proposed I-49 Connector. This includes the heavily contaminated railyard. Of the 195 properties in the footprint of the I-49 project, DOTD consultants recommend that 24 properties including the railyard need further evaluation. Although a year old, this study has not been publicly released for review, and was obtained only through a Freedom of Information Act disclosure. While we agree with the recommendation that more study is needed, the report has numerous deficiencies and failed to report important publicly available information. The report failed to discover monitoring data that show that surface contamination has reached Lafayette's water wells.
     https://youtu.be/PTu1xtmUDGs?t=52m10s

Harold Schoeffler is a leader with the Sierra Club and other civic organizations. Mr Schoeffler gave a brief history of the railroad in Lafayette. The Sabine was the first steam engine to arrive in Lafayette in 1875. Since the later 1800's the Lafayette railyard was a site for trains to take on water, sand, and fuel. Lafayette was also a major site for engine maintenance. The roundhouse, constructed in 1882, serviced steam engines for many decades. Maintenance often involved washing trains with the organic solvent trichloroethane (TCE), and removal of asbestos which was disposed of in ponds on-site. Every form of waste was dumped into the disposal ponds. The roundhouse operated until 1962. The railyard at times employed over one thousand people, and was a major source of employment in Lafayette. Mr. Schoeffler concludes that the railyard should have been cleaned up in the 1960s when it was closed. Today the wastes remain and the abandoned site still needs to be cleaned up.
     https://youtu.be/PTu1xtmUDGs?t=1h18m45s

Public comments and questions were solicited. Questions included what quantitative information is available and whether any political leaders or government employees were in attendance. The geographic extent of the impact was also discussed. Commenters suggested that attendees express their concern to our local political leaders. People were concerned about the status of compliance with Louisiana DEQ and US EPA requirements - were these agencies protecting the public? Finally, the US EPA EJScreen environmental and social justice mapping tool was suggested as a useful source for comparing the railroad site with other sites across the US.
     https://youtu.be/PTu1xtmUDGs?t=1h31m24s


Other links related to the meeting:
Article by Wynce Nolley, The Independent, January 20, 2017.  "Sierra Club: contamination in LUS water supply"

Article by Kendra Chamberlain, Louisiana Uncovered, January 27, 2017. "Lafayette citizens meet over concerns about alleged water well contamination - While city council members are MIA"

Dr. Waldon's slide presentation is separately available through SlideShare.net

The current LUS drinking water quality summary report is available for download at   http://lus.org/index.php/water/water-quality




Airport angles and increased risk

SUMMARY: Because this is an unusually long post, you may wish to skip first to the SUMMARY at the end of this post before reading the entire post.

A LOT has been written on the topic of "things you just should never do."  One of these "never do" actions is to build tall structures next to your airport. This is precisely the DOTD plan for extending I-49 through Lafayette.

In an earlier post I talked in general about the problems associated with the Connector plans relative to the Lafayette Airport. In this post. I want to get down to specifics.

Figure 1.  Google Earth image of the northwest end of runway 11-29 in relation to the intersection of Evangeline Thruway, University Ave, and Surrey St.  

Federal safety guidance defines the maximum height that objects should not exceed in the vicinity of airports. This definition is based on a number of imaginary surfaces through which no objects sitting on the ground should penetrate. Keeping aircraft above the imaginary surfaces, and all terrestrial objects below, provides for safe landings and takeoffs.

The lowest of these imaginary surfaces, the primary surface, is a rectangle at the elevation of the runway. The primary surface extends 200 feet beyond each end of the runway and 500 feet on each side of the runway centerline. Beyond each end of the primary surface there is an approach surface. The approach surface begins at the primary surface elevation and rises, for runway 11-29, at a slope of 34:1 (termed a 3% slope). That is, for every 34 feet of center-line distance the surface rises 1 foot.  At their intersection, the width of the approach surface is the same as the primary surface, 1000 feet, and is centered on the runway center-line. The approach surface widens to 4000 feet at 10,000 feet ground distance from the primary surface. That is, the approach surface width is 1000+0.3x, where x is the ground distance along the center-line away from the primary surface. There are other defined surfaces (transitional surface, horizontal surface, conical surface), but only the primary and approach surfaces are relevant to the issue of runway displacement for 11-29.

The 2002 Final EIS asserts in numerous locations that the Lafayette Regional Airport runway 11-29 will need to be displaced 350 feet to the southeast toward Bayou Tortue and Cypress Island Swamp from its present location to meet minimum federal safety requirements for an approach surface slope of 34:1 and a 17 foot margin of safety (FEIS exhibit 4-4). While the FEIS makes the assertion that the 350 foot displacement is required, it does not show the underlying data or rationale needed to support the claim. I have therefore been forced to attempt to recreate these calculations. My calculations, however, do not agree with the conclusion in the FEIS. Lacking documentation of the FEIS methods, I conclude that the 350 foot assertion is likely in error.

A history and general information about the Lafayette Regional airport may be found in the Wikipedia article titled "Lafayette Regional Airport." Additional information on the airport AirNav.com. That web page also includes a link to a useful Airport Diagram. The diagram shows that runway 11-29 is 5401 feet long and 148 feet wide. Elevation at the northeastern end (designated 11) is 37 feet; elevation at the southeastern end (designated 29) is 35 feet.

Figure 1 is an image captured from Google Earth of the northwest end (designation 11) of runway 11-29. It illustrates that the runway does end quite close to the current highway. Measurement shows that the runway currently ends roughly 600 feet from Evangeline Thruway (Hwy 90), and roughly 700 feet from the intersection of the Evangeline Thruway, Surrey St, and University Ave.

Figure 2. This image is extracted from the FEIS Plate 2a2. North in this figure is to the right, and distance along the horizontal extent of the roadway in hundreds of feet is given on the horizontal axis; elevation in feet (NGVD 29 datum) is plotted on the vertical axis. The roadway is charted as the solid black line. The 40 foot elevation is highlighted by a dotted red line. Peak roadway height at the interchange is estimated to be 45 feet. 


Finally, it is necessary to estimate the height of objects above the roadway. This could include signs, streetlights, and aircraft warning lights. The FEIS does mention this, and suggests that special signage and lighting may be necessary. Thus, I will assume that the height of the vehicles on the roadway will be the tallest objects above the roadway. There is no Federal vehicle height requirement for commercial motor vehicles (CMVs). Most eastern states, including Louisiana, set a CMV height limit of 13.5 feet on most highways. Louisiana does allow heights of 14 feet on designated highways, and oversize permits can be routinely issued for heights up to 16 feet 5 inches. Without specific guidance from the Louisiana DOTD, it is unclear what height should be assumed. Here, I will simply assume a maximum height of 15 feet for all vehicles and objects on the roadway.

Assuming the peak height at the interchange structure controls the required runway displacement, the calculation of length for the approach surface is now straightforward.  The interchange height plus object height has an elevation of 60 feet (45+15). Adding the FAA 17 foot margin of safety gives a total elevation of 77 feet. Subtracting the runway height which defines the primary surface elevation then gives a height of 40 feet (77-37). At a slope of 34:1, the length of the approach surface to the primary surface is 1,360 feet (34x40). At this point along the approach surface, the approach surface width is 1408 feet (1000 + 0.3x1,360), or 704 feet on each side of the extended runway center-line (Figure 3). Adding the 200 foot width of the primary surface at the end of the runway gives a total distance form the peak of the interchange of 1,560 feet. The present distance is estimated to be 700 feet, so the total runway displacement required would be 860 feet (Figure 4). This is 510 feet longer than the value asserted in the FEIS. This difference significantly brings into question the economic, environmental, and engineering feasibility of the displacement.

Figure 3. The more northern half of the new approach surface (black outlined trapezoid) begins with a width which is 500 feet on either side of the extended runway centerline, and 200 feet beyond the new runway end (orange line). The distance to the centerline extends to 704 feet at the proposed elevated interchange.

The calculated extension will require very roughly the destruction of 45 acres of the Cypress Island Swamp west of the airport (Figure 4), and more if embankments in the swamp must be longer than existing embankments. This considerably exceeds the 5 acres estimated in the FEIS (p 4-92).

(a)

(b)
Figure 4. The upper figure (a) shows the current airport runway at the southeast end of runway 11-29. The lower figure (b) is the same image with an 860 foot length of runway and associated area is copied onto the current end of the runway. The original image was printed from Google Earth. 
Construction would require significant fill, and consolidation of the underlying wetland soil will further aggravate the existing problems of soil stability at this end of runway 11-29.  The FEIS on page 2-10 states that "a prior runway extension of about 200' constructed in 1967 has subsided up to approximately four feet and has been removed from service." This fill will encounter even greater engineering challenges.

The new extension into the swamp will need to deal with a very significant drop in elevation (Figure 5). As much as 35 feet of fill will be required for the extension. If earthen embankments are used at the sides of the filled area, considerably more than the estimated 35 acre area of wetland may be required in order to accommodate the more extensive embankment areas.

(a)
(b)
Figure 5. In (a), the center line of the runway (red line) is extended at the southwest end of runway 11-29. The green bar indicates 860 feet from the end of the center line, and the thin white lie crossing the center line is 860 feet from the runway end. Figure (b) graphs elevation along the center line from 39 ft to 4 ft.  



Options: What are our options? They include:
  1. The No Build alternative should always be considered. If the currently planned I-49 Connector project is abandoned, it could be replaced by upgrades to the current Evangeline Thruway, and bypass to the east along the Teche-Ridge, west using the LRX alignment, or both to form an urban loop.
  2. Build the connector project as decided in the FEIS and ROD, and extend runway 11-29 as required to meet minimum FAA guidelines. This will require land acquisition and a Corps of Engineers wetland permit. Likely this alternative will further require wetland mitigation and flood mitigation.
  3. Build the connector project as decided in the FEIS and ROD, and request an FAA exemption from airport approach obstacle safety requirements.
  4. Abandon use of runway 11-29.
  5. Revise the design in of the selected alternative to eliminate roadway elevation in the vicinity of the 11-29 runway approach surface.

SUMMARY: The I-49 Connector FEIS identified unacceptable risk due to failure to meet FAA flight path obstruction guidance, resulting from the proposed interchange construction adjacent to the Lafayette Regional Airport. Without documenting calculations or rationale, the FEIS stated that in order to meet these minimum safety requirements, airport runway 11-29 would need to be displaced 350 feet southeast toward Bayou Tortue and the Cypress Island Swamp.

My calculations, based on FAA guidance, arrive at runway displacement considerably longer than that presented in the FEIS. Here, following FAA guidance, I calculated that the required displacement is 860 feet. This significant difference brings into question the economic, environmental, and engineering feasibility of the displacement. Impact of this displacement on flooding, wildlife, and wetlands should be carefully addressed and documented by DOTD.

The public attitude toward airport safety should always be conservative and circumspect. The Airport's 1975 Master Plan concludes "Conditions at the airport's periphery make expansion of its land area difficult or expensive or both." Even beyond the impacts of runway displacement discussed above, it is simply inappropriate to choose to construct any tall structures on the periphery of our airport which is already severely constrained at its location. Tall structures like the University and Kaliste Saloom interchanges constrain future airport runway alignment adjustments, and impact the ability to meet current requirements and future safety requirements should FAA guidance on safety margins or approach slopes change for any reason.

  

Degrading Acadiana's cultural treasure-Vermilionville

Figure 1. This view across the pond at Vermilionville will look directly 
up at the University/Thruway/I-49 interchange and elevated interstate 49.
This photo was taken roughly 600 feet from the proposed Con alignment.
Since opening in 1990, Vermilionville has provided a serene location on the bank of Bayou Vermilion for Acadiana citizens and tourists to learn about and share the history of the Cajun culture. Providing the illusion of an isolated rural village, Vermilionville is a major part of the educational and cultural experience that is passing our culture on to both children and adults who participate in hands-on activities and celebrations. Vermilionville is truly our premier Acadiana cultural attraction.

But, how will constructing the proposed Lafayette I-49 Connector interstate impact this cultural jewel?

To answer this question, let's look at some pictures. Figure 1 is a photo taken from the parking lot of Vermilionville overlooking one of the small lakes at the site. The Evangeline Thruway is just 600 feet away on the other side of this lake ( see camera icon in Figure 2), but it is hidden by trees which also dampen the sound of the urban traffic and add to the illusion of isolation. The plan for the I-49 Connector project (the Con) is to build an elevated interstate above the current ground level path of the Thruway (wide red line at the top of Figure 2).

Currently, traffic moves at speeds at or below 50 mph along the Thruway; after the Con is completed, traffic will move at interstate speeds along an elevated roadway. Figure 3 shows the roadway elevation as it approaches and passes Vermilionville. At speeds below 50 mph, current Thruway traffic noise is dominated by the sound of car and truck engines, but above 50 highway noise is dominated by the higher frequency roar from tires rolling along the pavement. This high speed scream of the interstate will be focused at Vermilionville by northbound traffic dropping from the 45 foot elevation University/Surrey/Frontage Road/I-49 three-level interchange, and then climbing to stay elevated above the hill just north of the Bayou Vermilion bridge (Figure 3). The Vermilionville visitor center entrance is just 1000 feet from the proposed Con roadway, and 2000 feet from the peak of the planned University-Surrey interchange. Noise levels within Vermilionville will destroy all illusion of isolation, and at times may even make normal conversation difficult.

In addition to interstate's traffic noise, cars and trucks topping the interchange will be clearly visible to Vermilionville visitors. At night, the aircraft warning lighting atop the interchange, roadway lighting, and headlights will further reduce Vermilionville's illusion of isolation and serenity.


Figure 2. This is a Google Earth view of the Thruway and Vermilionville.
The path of the Con is plotted at the top, location of the photo (Figure 1),
The Vermilionville Visitor Center, and National Park Service are shown.
Note that north is rotated to the right in this aerial photo.                         
Figure 3. This drawing is adapted from EIS Plate 2a. A side view along the proposed roadway
is drawn here plotting elevation versus roadway distance going north. The red arrow indicates 
the location of Vermilionville which is on the bank of Bayou Vermilion. The shaded area at 
the bottom is below the ground; the solid black line graphs the road elevation. The blue line 
is drawn at 40 ft elevation. The numbers along the  bottom axis (300 and 325) are distances 
along the roadway in hundreds of feet (30,000 and 32,500 feet). Note again that in this figure
north is rotated to the right in this drawing. Elevation on the vertical axis is (I assume) NGVD.

So, how does the Con's Final Environmental Impact Statement (EIS) evaluate the impact to Vermilionville, and what does it propose as solutions? Answer: Not much!

EIS Section 3.2.6 describes legal requirements placed on DOTD and FHWA by a so-called "section 4(f) properties designation." The EIS states that
Under Section 4(f) of the Department of Transportation Act 49 USC 1653(f), the Federal Highway Administration cannot approve any program or project which requires the use of land from a significant public park, recreation area, wildlife or waterfowl refuge, or historic sites (on or eligible for the National Register of Historic Places) unless: (1) there is no feasible and prudent alternative to such use, and (2) the project includes all possible planning to minimize harm to the property from such use.
Speaking of Vermilionville, Beaver Park, and other impacted recreational areas, EIS Section 4.2.3 concludes "A slight noise increase would be expected at Beaver Park for the EA-1 and RR-4 alternatives." and "In general, recreation areas in the corridor would be positively impacted due to the improved accessibility, with increased usage possible once the project is complete." So, the answer is that no negative impact on Vermilionville is considered by the EIS, and nothing will be done to mitigate any impact.

Speaking solely of Beaver Park, section 4.2.3 of the EIS commits not to action, mitigation, or re-design, but rather it commits to the possibly needing to prepare more documents:
Should design details as subsequently developed cause impacts which are not currently apparent, 4(f) and 6(f) applicability would be reviewed by the FHWA and DOTD and statements prepared, if warranted.
So, what is the best alternative for Vermilionville, Beaver Park, all the other recreational, cultural, educational, and religious sites along the Con's alignment? Simply stated:

  • Don't build the Con! 
  • Build a bypass or complete loop!


The specter of tolls on the I-49 Connector



Photo: The Advocate, May 31, 2016

The Specter of Tolls on I-49 continues. On June 4 we learned in the Advertiser's report on the end of the legislative session that "The State... opened new possibilities for creating toll roads where they might spur construction." It appears from the article that One Acadiana had lobbied for this change. The Advocate (May 31, 2016) reported that State Secretary of Transportation, Shawn Wilson, told the state legislature that tolls on state highways and bridges are an option under consideration and that Gov. John Bel Edwards’ administration is “very supportive of tolling as an option to fund transportation and to fund projects that are significant." We have also heard Secretary Wilson say that the Lafayette Connector which they are actively promoting is very significant. Could tolls on the Lafayette Connector be a part of the administration's plan? At this point it appears likely.

The specter of tolls on the I-49 Connector and all of I-49 South has been foreshadowed for years. Former Secretary of Transportation Kam Movassaghi was quoted (The Independent, April 14, 2009) saying that tolls must be considered for funding I-49 construction. An expert speaking to a meeting sponsored by One Acadiana (The Advocate, October 22, 2015) suggested that a toll of $0.19 per mile might be used to fund I-49 completion, and an Advocate article (September 22, 2014) reported that a state funded feasibility study looked at $0.18 per mile for I-49 funding. Former State Senator and then I-49 South Coalition Director, Mike Michot, was quoted in that same article saying about I-49 South "It seems unlikely a project of that magnitude will be built without the help of toll dollars."

However, tolls have been ruled to be outside the range of discussion in DOTD Community Work Group and Technical Work Group meetings held this year. When questioned, state DOTD employees and their contractors have typically refused to discuss just how the so-called Connector will be funded. The most we are now told is that the question of methods of financing will be considered at some future time after we make the decision to proceed with a selected design.

DOTD has not ruled out collecting tolls to finance the Connector, they have simply ruled it to be inappropriate as an item of discussion. Clearly charging tolls for use of the proposed I-49 Connector would impact many of the project's projected benefits, and could add new design constraints. Why has DOTD chosen to ignore this specter? We can imagine two reasons:

  1. DOTD recognizes that placing tolls on Lafayette citizens for local travel will increase the unpopularity of their already locally unpopular Connector plan.
  2. DOTD's excessively high planning projections of 100,000 vehicles per day would become even more suspect because many drivers, particularly those making frequent local trips would avoid the cost and inconvenience of tolls by taking alternative city street routes. 


A tolled I-49 in Lafayette would have significant impact on traffic levels on alternative city streets - Louisiana Avenue, University Avenue, and the degraded capacity Evangeline Thruway envisioned in most Connector alternatives.  The current traffic models being used to frighten us with onerous future projections assume free access to the proposed Connector. Until tolls are taken off the table, model projections should include tolled as well as free access alternatives in all planning projections.

Here is my own conceptual traffic model projection. A toll of $0.18 to $0.19 per mile will result in a toll of about $1.00 in each direction on the 5.5 mile Connector. For a commuting worker with a 250 day work year, this effectively adds a new $500 annual tax if they choose to commute on the toll way. Again, the Connector will become a Divider, allowing those who can afford the added cost to ride at high speed and with little traffic, while the common people of Lafayette Parish will be segregated onto the even more traffic congested city streets.

The option of tolls is clearly still on the table. Until DOTD makes the determination about whether this will be a toll road, all planning is simple fantasy.


References and further reading discussing the likelihood of tolls for Acadiana:

The Independent, April 14, 2009, Movassaghi: tolls must be considered for I-49
 http://theind.com/article-3949-movassaghi-tolls-must-be-considered-for-i-49.html

The Independent, January 12, 2012, Guest editorial: Public-private route for I-49 South?
 http://theind.com/article-9431-Guest-editorial-Public-private-route-for-I-49-South.html

The Independent, January 18, 2012, Southern Strategy
 http://theind.com/article-9451-Southern-Strategy.html

The Independent, November 13, 2012, La. 1 a good example for I-49 South
 http://theind.com/article-11687-La-1-a-good-example-for-I-49-South.html

The Advocate, September 22, 2014, Tolls are possible to complete Interstate 49 South
  http://theadvocate.com/news/10339811-123/tolls-are-possible-to-complete

The Advocate, October 22, 2015, Finance expert: I-49 Connector through Lafayette would require tolls, taxes or both to fund construction
 http://theadvocate.com/news/13766344-123/finance-expert-i-49-connector-through

The Advertiser, October 23, 2015, Citigroup and the Lafayette Loop — what's next?
 http://www.theadvertiser.com/story/news/2015/10/22/citigroup-and-lafayette-loop/74359164/

Toll Road News, October 23, 2016, Tolling an Option for $750-800 Million Louisiana Project
 http://tollroadsnews.com/news/daily-news-brief-october-23-2015

The Advocate, May 31, 2016, Tolls a possibility to fund major road projects as state faces $12.7 billion backlog, DOTD leader says 
http://theadvocate.com/news/15959711-123/tolls-a-possibility-to-fund-major-road-projects-as-state-faces-127-billion-backlog-dotd-leader-says#comments

The Advertiser, June 4, 2016, Session's end: What's won, what's left
 http://www.theadvertiser.com/story/news/2016/06/03/sessions-end-whats-won-whats-left/85373342/

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Note: This is an updated and expanded version of a post first published on June 1, 2016.