Tuesday, November 30, 2021

Secretary Pete: Put an immediate stop to the I-49 Lafayette Connector

Lafayette resident Ann Burruss sent the following letter to Secretary of Transportation Pete Buttigieg with copies to our Louisiana Governor, Lafayette Mayor, and Louisiana Transportation Secretary. The photos in this letter were taken by Ann earlier this month at the DOTD I-49 Open House poster presentation. 

If you feel strongly about the Lafayette I-49 Connector, you too can voice your opinion to the U.S. Secretary of Transportation by sending a letter to: The Honorable Pete Buttigieg, U.S. Department of Transportation, 1200 New Jersey Ave., SE, Washington, DC 20590. You may also email the secretary at  DOTExecSec@dot.gov.


____________________________________________________

Louisiana State Project No:  H.004273.5
Federal Aid Project No.:   H004273
Secretary Buttigieg, November 17, 2021

Congratulations to you and to the Biden administration for passing the infrastructure bill. In my volunteer work for Second Harvest Food Bank in Louisiana, I drive on substandard roads in rural parishes and I know what this bill can mean for struggling workers who commute on bad roads and bridges. Thank you for putting the needs of working people first.

I am writing today to ask that you put an immediate stop to the federal highway project called the I-49 Lafayette Connector in Louisiana. While promoting the infrastructure bill the administration talks about racial justice and equity as driving factors in projects.  Extending I-49 through the center of the city of Lafayette, Louisiana, is the exact opposite of that goal.  The planned route replaces a surface road with an elevated interstate. It’s like the 1960s and 70s all over again! As if we have learned nothing about the damage -- the permanent dismemberment -- that an interstate highway does to a city.  The I-49 Connector is racially unjust. It cements a redline through our city. It divides historically black communities from the prosperous downtown. We know better than we did in the 60s and 70s. We must do better.

The Louisiana Department of Transportation and their consultants held a series of sparsely attended open houses here recently.  They never ask the public ‘Do you want this interstate?  Do you need this interstate? If you need an interstate, where do you want it routed?’  It's always, ‘Do you like this lighting feature or that lighting feature? Do you want your children to be able to bike under this fabulous interstate, or do you want them to play basketball?’ I say “Neither.”

I and many informed citizens want this interstate to Not Be Built Here.  Instead, we want to see the LRX (Lafayette Regional Xpressway) built. The LRX will provide the first half of a loop highway around our city.  If this western loop portion proves useful and well-traveled, then an eastern portion could be built as an interstate through St. Martin Parish where they are willing and even eager to have a highway there.  The LDOT will say that an eastern highway ‘on the Teche Ridge’ can’t be built because of wetland impact - and they are correct that wetlands mustn't be harmed because of their flood storage capacity and natural value. However, the Teche Ridge isn’t the only possible eastern route. Wetlands can be avoided. Please investigate and authorize these routes in lieu of the I-49 connector.

US Census data shows that from 2010 to 2020, the population of the parishes that the I-49 Connector is supposed to serve has dropped by 15%.  The cost-benefit study for the I-49 Connector is very suspicious. How could it possibly have shown a positive cost for a highway to a rapidly depopulating area, an area that is losing its economic engine which is oil and gas production from which we must rapidly decarbonize? Accelerating coastal land loss will cause roads and highways south of Lafayette to face the open waters of the Gulf of Mexico. Additionally, the elevated route of this highway goes through a contaminated railyard and over our drinking water aquifer.

There is no reason to continue work on running I-49 through our city.  Please quickly authorize more affordable and supportable projects to the east or west of the beautiful city of Lafayette, Louisiana, my home. Thank you.

Sincerely,

Ann Burruss
110 Seville Blvd
Lafayette, LA 70503

cc:
Governor Edwards, by email
Secretary Wilson, by email
Mayor Guillory, by email


In addition to asking what kind of lights we like, the LDOT renderings add in new buildings along the route, as if prime real estate and good jobs appear right alongside interstates.  They don’t.  At best you get gas stations and storage unit facilities.  Please consider promulgating rules to prevent fanciful projections in renderings.  All transportation departments should show only exactly what they propose to build.



Do you want your children to walk, play or bike under an interstate highway?  I have never seen these activities happen under interstates anywhere in our country because parents know better.  Under an interstate is air pollution, soil pollution, noise pollution and danger from falling objects.  Diseases like asthma, chronic stress and depression from sleep disturbance will develop in nearby populations. Please don't visit these traumas on more of our people.



Photographs from posters presented by LDOT and consultants at the November 2021 open house series in Lafayette, Louisiana.









Monday, November 15, 2021

Comment: The Lafayette Connector project has failed to meet federal requirements for public involvement and environmental justice

 



From:
Mike Waldon 
Mon, Nov 15, 2021 at 3:56 PM
To: comment@lafayetteconnector.com
Cc: Josh Guillory, Charles Bolinger, Shawn Wilson, Monique Boulet, Tim Nickel, Col. Greg Ellison, Andy Naquin, Glenn Lazard, Liz Hebert, Nanette Cook, Patrick Lewis, Abraham Rubin Jr., Bryan Tabor, John J. Guilbeau, Joshua Carlson, Kevin Naquin

DOTD I-49 Open House

Subject: Comment for November 4, 2021 event transcript - Failure to address contamination and environmental justice

This is my public comment following the event that was called a "public meeting" held on November 4, 2021. I ask that my comment be included in its entirety in the public meeting transcript and the record of Lafayette I-49 Connector project comments.

It is misleading for the meeting transcript to call this a public meeting.  As with your previous meetings, the public was given no opportunity to openly provide comments or feedback. Simply providing an email address and comment cards is not adequate. This event would more accurately be called a poster session. 

This and other meetings held by the Lafayette Connector project fails to meet state open meeting law requirements (see my comment submitted October 19, 2017), and federal requirements for public involvement (https://www.fhwa.dot.gov/planning/public_involvement/orders/#a9).In the future, I urge the Lafayette Connector management team to follow not only the statutory and regulatory requirements for public involvement, but to also sincerely follow the spirit of open involvement on which these requirements were based.

This proposed state/federal urban interstate project completely ignores the issues of social justice, environmental justice, risk of severe health impacts on the predominantly disadvantaged community, and damage to property caused by spreading of toxic contaminants. This is in clear violation of federal requirements for public involvement. This project is in violation of Executive Order 12898, and the federal FHWA's published public involvement requirement to "assure that possible adverse economic, social, and environmental effects relating to any proposed project on any Federal-aid system have been fully considered."

Specifically, a large part of the proposed corridor of this project is heavily contaminated or likely to have contamination of soil and groundwater. This fact has been established in past court proceedings. However, the full spatial extent of contamination has never been publicly disclosed, and is likely unknown. Data and reports in possession of the Louisiana DOTD have been declared confidential by DOTD leaving the public ignorant of potential health risks that DOTD already knows about, or should know about after more than 30 years of floundering through design after design of this anachronistic project while avoiding knowledge of the risk and cost. 

Long ago when I was studying to be an environmental engineer, I recall learning that the first thing to do when considering working with a contaminated site is to determine the spatial extent of the contamination. After decades, the Connector project planners either have not made the determination of spatial toxic extent in the project corridor, or are not disclosing it to the at-risk public. In either case, this failure clearly violates federal policy including environmental justice requirements

We, the public, do have enough information about toxic contamination in the project corridor to know that it is an extremely serious risk. Indeed, neighbors of the railyard have sued seeking cleanup. We know that operating construction machinery over land contaminated with asbestos, arsenic, and lead risks spreading toxic dust through neighboring homes and businesses. If you want to give us poster sessions on your plans, show us how you will work in this toxic environment without further exposing us to toxic and carcinogenic chemicals through air, surface water, groundwater, and drinking water.

Likely, for over a century, contaminants have been eroded and followed drainage along Evangeline Throughway contaminating much of the surface soil in the corridor. Other contaminants have surely moved through the surficial aquifer under surrounding homes and businesses. It is known that the contaminants from the railyard migrated through groundwater off-site because Lafayette city/parish workers found and reported visible contamination off site near the railyard. 

We do not know the extent of migration of the contaminants from the contaminated railyard and other contaminated sites along the proposed route. However, we do know that in Houston a similar railyard has had significant off-property migration. Further, the State of Texas has confirmed that this contamination is coincident with cancer clusters in neighboring communities. 

The impact of the Lafayette Connector project on air and water toxic migration is vitally important to our community. The impact of toxic migration on design and construction of the Connector is vitally important to taxpayers who are paying for this project. A cleanup plan must be proposed for this project and must be disclosed to the at-risk public for public review and comment. This is not only a regulatory requirement, it is a moral and ethical requirement for those promoting this project. 

Finally, I address the engineers working on this project. How can you propose a project while remaining willfully ignorant of environmental consequences of your proposed actions on the surrounding community and construction workers? Every engineer  is ethically required to give protection of human life and property the highest priority. Doesn't the sequencing and planning of the I-49 Lafayette Connector project to-date breach your professional engineering ethical boundaries?

I am submitting these comments via email to comment@lafayetteconnector.com. I am also copying some interested members of the community, members of the I-49 Connector Executive Committee, and our City and Parish Council members. I will also send these comments in a separate message to US Secretary of Transportation Pete Buttigieg.

Thank you for considering my comments.

Michael G. Waldon, Ph.D.
110 Seville Blvd 
Lafayette, LA 70503 
337-852-3668, email: mike@mwaldon.com
November 15, 2021

Thursday, October 28, 2021

Restoring NEPA procedures to protect the public and taxpayers


The National Environmental Policy Act (NEPA) is the law that ensures that you can have a voice in federal decisions. During the previous administration, changes were made to the way NEPA is implemented. These changes were intended to streamline the process and allow federal projects to be approved more quickly. Although a goal of speeding up federal bureaucracy is laudable, the streamlining was at the expense of public scrutiny rather than streamlining the internal working of government agencies and contractors. Currently, there is a Phase I proposal that would begin to restore the right of the public to be involved. This proposed rulemaking is available for public comment until November 22, 2021. Yesterday, I submitted the following comments.


National Environmental Policy Act Implementing Regulations Revisions

Public Comment

Agency name: Council on Environmental Quality

Docket number, CEQ-2021-0002

Commenter: Michael G. Waldon, Lafayette, Louisiana

NEPA is not just an environmental law, it is a GOOD GOVERNMENT law. NEPA requires that federal agencies think before they act and allow the public to critically review proposed actions. I am submitting this comment to support CEQ’s proposed phase 1 rules. Furthermore, I ask that CEQ quickly initiate phase 2 rulemaking with robust public involvement so that NEPA is fully restored. 

Public review and comment are essential safeguards against wasteful, harmful, and ill-conceived large government projects. For years, NEPA protected public health and the environment. But, that is not all. By allowing the public to examine proposed plans and designs, citizens have exposed deficiencies and errors before they became costly mistakes. NEPA has saved government agencies from making huge costly blunders.

I am commenting as an individual, but I am a member of my local Sierra Club and the Y-49 group in Lafayette who oppose construction of a new urban section of I-49 through the heart of our city. Additionally, I participate in the Louisiana Four Corners Coalition which is seeking reform of Louisiana transportation decision-making through increased public scrutiny and input. Here, I illustrate the importance of NEPA with two examples from these citizen groups and my own experience. 

My first example shows how NEPA procedures can raise awareness of risks associated with proposed projects. As a retired environmental engineer, I first became alarmed about the public health and financial risks of the proposed Lafayette I-49 urban interstate project. This project has been opposed for decades by local citizens and citizen groups. As part of a developing supplemental environmental impact statement, the Louisiana DOTD contractors revised the design and proposed constructing an elevated interstate over a federally recognized and un-remediated hazardous chemical site that is just over a thousand feet from Lafayette municipal drinking water wells. The elevated roadway would be supported on pilings that extend deep into our city’s drinking water aquifer. This project not only endangers our drinking water source, but could also move financial liability from the potentially responsible party to the taxpayers. We continue to oppose this dangerous and ill-conceived plan through NEPA mandated public input.

My second example involves an apparent design error that came to light during NEPA mandated public review. While reviewing the I-49 proposed urban interstate plan I became alarmed by the roadway design which proposed constructing an elevated overpass interchange with University Avenue flying over I-49 at the edge of our Lafayette airport. This tall structure was going to be positioned just past the end of one of our city’s runways. The EIS wanted to fill an area of wetland and shift the runway a few hundred feet east in order to meet FAA safety requirements. This small shift just didn’t seem sufficiently safe to me, so I did my own calculation using FAA guidance to see how far the runway needed to move. My calculation showed that a much larger shift was needed to meet FAA regulations. I submitted my calculation as a comment for the developing SEIS, and also wrote a blog post (ConnectorComments.org) detailing my calculation. I never even received a confirmation from DOTD that they received my comment. However, I can only assume that DOTD and their contractors agreed with my analysis because after I submitted that comment the plan was changed to tunnel University Avenue under the interstate rather than flying over it.

What would the environmental and financial consequences have been for residents of Lafayette if the NEPA process had been abbreviated? How much has NEPA’s required public involvement reduced the risk to our city’s drinking water and public health? How much waste would have happened before correction of the intersection design at the end of our airport runway? 

In summary, NEPA safeguards both taxpayers and the general public. Circumventing full NEPA consideration of projects increases the likelihood of wasteful government spending, environmental damage, and damage to public health. I therefore support the CEQ proposed rules.

Thursday, September 9, 2021

Another letter to the US Secretary of Transportation opposing the I-49 Connector


9th September 2021

The Honorable Pete Buttigieg

U.S. Department of Transportation 

1200 New Jersey Ave., SE 

Washington, DC 20590


RE: Opposition to the proposed Lafayette Louisiana I-49 Connector (1)


Dear Mr. Secretary:

Thank you for publicly recognizing the disproportionate impact of urban interstates on minority populations.  I was thrilled when you made the statement (2) that “In the Biden-Harris administration, we will make righting these wrongs an imperative.” This is a welcome change.

I am writing to you concerning the proposed Lafayette Louisiana I-49 Connector which is planning to plow 5.5 miles of new interstate through the heart of my city. I could use many adjectives to describe the proposed Lafayette I-49 Connector. A few are: unjust, wasteful, ill-conceived, high risk, anachronistic, and racist. I am asking you to use all of the power and influence of your office to either stop and deauthorize the Lafayette Connector project, or relocate the project’s corridor to the planned Lafayette bypass, the LRX (3)

In Lafayette, there has been articulate bi-partisan and multi-racial opposition to routing I-49 through our city center. Opposition has delayed this project for more than two decades. However, the lure of authorized federal project funds with a low level of local match has led to the expenditure of many tens (maybe hundreds) of millions of federal tax dollars for continuing plan revision within the central city corridor. 

Some among us believe that this project is a long-dead “zombie” surviving only on free federal planning and design dollars. Others fear that one day the project may actually move to a construction phase.  In either case, the specter of the so-called Connector has caused neighborhood property value to fall and neighborhood business to flee. 

The injustice and environmental risk of building along this urban corridor has long been recognized. In their scoping comment on the 1998 DEIS, the USEPA Region 6 pointed out the requirement of Executive Order 12898-Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. They stated that Federal agencies are ordered to analyze (4)

 "the environmental effects, including human health, economic and social effects, of federal actions"

Despite many millions of tax dollars spent over more than two decades, these federal requirements identified by EPA in 1998 have never been seriously addressed. I believe that this is because there is no answer. The selected routing of the project corridor was unjust by design. 


Thank you for your consideration of my request.


Sincerely,

Michael G. Waldon


Footnotes:

  1. Louisiana State Project No. H.004273
  2. Twitter @PeteButtigieg Dec 20, 2020
  3. Lafayette Regional eXpressway,  http://www.lrxpressway.com/
  4. Final Environmental Impact Statement, I-49 Connector, Lafayette Louisiana, August 2002, Volume 2, Appendix C, Page C-29


This letter is also available in pdf format through this link.

Thursday, April 22, 2021

Notes from the Lafayette Connector Neighborhood Meeting April 21, 2021

 Rosa Parks Transportation Center, 4:30 pm, April 21, 2021


Meeting Notes 

In attendance there were 3 other citizens present in the meeting room (4 total including myself). Other citizens may have attended online but if they did they never commented or questioned. That makes me think that the online Zoom participants were all government employees  or others who were just observing.

Piling Alternatives

Alternative pilings*


As in prior meetings, the meeting was organized around a set of questions about the project design. We were offered 4 different piling designs (see figure
), one with art. We were asked which piling design we preferred. Then different girder designs were offered, and we were asked to choose from the pictures. I commented that I prefer as few pilings as possible, that pilings should not go deep enough to get past the clay layer, and I suggested earthen berms instead of piers under the bridge where there is contamination. I and another participant also noted that picking a selected pier or girder does not mean we approve of the project.


Another neighborhood concern is toxic construction dust and runoff. I commented that the preferred design should disturb the contaminated soil as little as possible. Much of the soil in the right-of-way is contaminated with arsenic, lead, asbestos, and other toxics. I believe that decades ago the railyard soil was perhaps covered with a thin layer of cleaner soil as remediation. Any digging or use of heavy machinery may therefore require workers to wear protective masks and clothing (moon suits), and the site will need to have a dust and runoff control plan. It may also need continuous dust monitoring at the fence line testing for the known toxic contaminants released from the disturbed soil. 


One question was whether we prefer a roadway elevation that allows 17 feet of clearance, or 22 feet of clearance. This led to questions about how this decision affects the noise level and area of noise impact. Noise was a big concern. We asked “What is the impact of roadway height on noise? We were told that we will not know how much noise to expect or how the design impacts noise until after the design is selected. Then they will model the noise levels from the selected design. We pointed out that the height of the elevated roadway may impact the noise level. 


I also commented on train noise. With the planned elevated roadway next to the railway, the project is likely to focus noise from trains and train whistle blasts into the surrounding community. With only my intuition to guide me, I am guessing the train whistle could actually cause hearing damage if it blasts next to people standing under the highway. I am also guessing the project would mean that the train whistle will be a lot louder in people’s homes if the Connector is ever constructed.


It seems clear that for those who will be living in the vicinity of the highway, noise and contamination, and health risks are very high priority concerns. However, as I understand from this meeting, DOTD will only publicly consider and evaluate these priority issues after the final design is selected and approved. 


Concerning noise barriers, we learned tonight that a new policy concerning storm evacuation routes allows sound walls on the roadway structure to be 14 feet high rather than the previous maximum of 10 feet. That is good news, but it does not mean DOTD will necessarily approve building sound walls or how high they will build them.


On the topic of connectivity, we learned that there is a Complete Streets policy. I had not heard of that before. It sounds like a very good thing. However, it also sounds like the policy is more of a vision statement and not strictly a requirement.


We were asked about alternative designs for gateway markers at one or both ends of the project. We were shown alternative pictures of lighted ornamental metal structures that would communicate some abstract message about our city. 


There seemed to be little interest in gateway ornaments, but this question did lead us into talking about the loss of our Lafayette visitor center. It seems reasonable that the new visitor information center should be located at one of the gateways. I commented that my understanding is that replacement of the visitor center is a local expense that must somehow come from local sources rather than federal or state highway funds.


The final question was what use do we prefer for the space under the elevated roadway. We were shown pictures of parks and playgrounds. Another participant immediately pointed out that this question amounts to pure propaganda for the project because none of these uses would be funded by DOTD. We were then told that indeed, DOTD will not build a park or even a single basketball goal. I believe they said that this question is simply aspirational. 


It was also pointed out by another citizen that much of the land under the bridge is classed by DEQ as being only for industrial use. I pointed out that DOTD could choose to clean up the site to residential standards, and that railyards in other places have been cleaned up to that level. However, DOTD plans to do only the minimal clean up required to complete the project. 


We were also told that DOTD does not intend to buy or take the entire railyard site, and any part outside the right-of-way will receive no remediation by DOTD. 


The meeting ended at about 6:00 pm. This meeting was for neighborhood input. I attended because my church is in the neighborhood, and I tried to limit comments to neighborhood issues. We were assured that there are upcoming meetings that will include the entire community and provide more details on the new design proposals.


Michael Waldon, PhD


*The figure is copied from the LCAG meeting Sept. 9, 2020. It is similar to the one shown during this meeting.


This post was updated to correct the date of the meeting. Sorry!. --mike



Wednesday, August 19, 2020

Letters: So many reasons to forsake I-49 project, so why would we risk this?

 The following Letter to the Editor appeared in the The Advocate on August 11, 2020.


So many reasons to forsake I-49 project, so why would we risk this?

Once again, the Department of Transportation and Development is attempting to move forward with the Lafayette Interstate 49 Connector project. The Connector is unlikely to ever become a reality for the following reasons:

The project lacks public support and has been opposed for over 30 years by hundreds of citizens and the victims who will lose their homes, jobs, businesses, churches and other community assets. This opposition has been well-voiced in public hearings, meetings and lawsuits.

It has an overabundance of prohibitively expensive problems due to its proximity to the railroad, downtown Lafayette and the airport. These issues bring the price to at least $300 million to 400 million per mile, which far exceeds the normal funding for interstate highways.

The path of this highway takes it through the abandoned, highly contaminated Union Pacific rail yard. It has been declared so by the Environmental Protection Agency, Department of Environmental Quality and federal courts. Litigation seeks to hold Union Pacific accountable for the cleanup. This suit and the clean-up must be completed before the connector can be built.

Its cost could be as much as $2 billion and could take decades to complete. Louisiana DOTD attorneys declared in the federal citizens’ suit against the project that the proposed pathway for the connector is the only feasible route, which was upheld by the court’s ruling. This creates a Catch-22 whereby more cost-effective routes are not considered.

The footprint of the proposed connector lies above the Chicot aquifer, Lafayette’s water source. Contamination has already been observed in our aquifer. Driving elevated roadway pilings through the rail yard and into our aquifer without a thorough cleanup would endanger our precious water supply.

The 20-year-old Environmental Impact Study required by federal law is significantly outdated, far exceeding the three-year life of an EIS. The attempt to supplement this outdated EIS is a waste of time and money. A new EIS is required because of passage of time, new significant environmental information and major changes in the Record of Decision, all of which apply to this project.

We are outraged that the DOTD continues to spend millions in taxpayer money on a project that is too expensive, destroys community, jobs, homes and businesses, reduces property tax revenue, increases traffic on city streets, and endangers drinking water, air quality and Bayou Vermilion. The public has been wise in opposing this project for the past 30 years.

When confronted with public opposition, engineering obstacles and high cost, other states have revised planned interstate corridors and created urban bypasses. Why not in Lafayette?

HAROLD SCHOEFFLER

chairman, Acadian Group, Sierra Club

Lafayette







Saturday, July 25, 2020

Meetings Announced by DOTD Will Again Suggest Design Revisions

For over two decades LaDOTD has been revising designs for their "I-49 Connector" in Lafayette. Each new design that has been presented has fallen to design flaws, impracticality, legal challenge, and/or extreme public opposition.  Once again, the LaDOTD Lafayette I-49 Connector is returning to make renewed plans for building their urban interstate through the heart of Lafayette. Two online meetings of the LCAG (I believe this is the Lafayette Connector Advisory Group) are planned:
  • Tuesday, July 28, 2020, 4:00 pm - 6:00 pm: An Introduction to Bridge Design and Construction. Focus will be on the Mainline Structural Viaduct Type Alternatives, the Evaluation Criteria and Evaluation Process conducted to date, and other opportunities to improve structural components with the CSS (Context Sensitive Solutions) process
  • Thursday, July 30, 2020, 4:00 pm - 6:00 pm: Working Session utilizing breakout Focus Groups and a summary round table to further discuss structural concepts and alternatives introduced in the Tuesday LCAG Meeting. The breakout Focus Groups will discuss the Mainline Structural Viaduct Types and their detailed characteristics including such things as scale, constructibility, cost, and long-term operations and maintenance; and other CSS Structural Considerations such as abutment walls, piers, retaining walls, and railings.These focus groups will report back the results of their discussion, evaluation,and preferences.  Consensus will be developed on LCAG conclusions/preferences for report out to the Partner Agency and Executive Committee, at future meetings.
The Louisiana Open Meeting Law requires that the public be given a reasonable opportunity to speak at advisory committee meetings. However, as with past LaDOTD sponsored I-49 Connector committee meetings, no public input will be allowed. The I-49 Connector website states:
This is a committee working meeting, but if members of the public would like to attend in a listen-only manner, please email info@lafayetteconnector.com to request the Online Meeting access information.
Although I will have no opportunity to comment, I do plan to view the meeting. As described above, I have emailed my request for this meeting information, and I urge all interested citizens to also make this request and observe the meeting.
CSS Project Map
CSS Map I-49 Lafayette Connector

 

Monday, June 22, 2020

Ozone and the I-49 Connector: Why should we care?

DOTD I-49 Urban Route.
Recent local news articles on KATC and in The Acadiana Advocate  reported an LDEQ warning that on June 19 Lafayette would have high levels of ozone. LDEQ declared an Ozone Action Day for Lafayette. Why should we care about ozone?

First, high ozone levels are a risk to health, particularly among our most vulnerable citizens. Those who work or exercise outdoors are also at risk.  

Second, Lafayette has in the past been close to non-attainment for ozone, while Baton Rouge has been out of compliance. Currently all of Louisiana is considered to be in compliance with the federal standard of 70 parts-per-billion for ozone. Lafayette air pollution has improved, but there are continuing calls to make the ozone standard more protective. Non-attainment matters to Lafayette's future economic growth which could be impacted by restrictions and new requirements placed on any industry wanting to locate here. Beyond that, the most sought after companies looking for a new location are far less likely to choose a city with recognized poor air quality. Bottom line: our current good air quality is a plus for Lafayette to recruit new economic development. 

Finally, what has ozone got to do with the I-49 Connector? If you listen to Louisiana DOTD and their consultants who are writing the I-49 Environmental Impact Statement you might think ozone and air pollution have nothing to do with their plan. But, our biggest source of ozone in Lafayette is from cars. Common sense tells us that the proposed elevated interstate through the heart of our city is going to concentrate heavy traffic on city streets that lead to and from the interstate. Further, much local traffic will avoid using the elevated highway because of its limited points of access and exit. Those cars and trucks will be forced to sit in traffic on city streets. And, if the Connector has tolls, expect even more traffic forced down to city streets. Expect troubling increases in ground level ozone.

LRX Bypass Corridor Options (DOTD)
This doesn't have to happen! The proposed Lafayette Metro eXpressway (LRX) would allow through traffic and hazardous cargo to bypass the central city. For almost two decades we the taxpayers have funded planning for the LRX bypass. It is time to act and choose this alternative. The LRX would draw traffic away from easily congested urban streets and save local tax monies as city street expansions are no longer needed. The LRX would improve rather than worsen ozone pollution in Lafayette. If the I-49 Connector is built, we will be stuck with its induced traffic congestion and resulting bad air in our city for decades. Let's just not go there! 


Friday, March 15, 2019

February 2019 LRX Public Meeting Comments

The comments below were submitted on March 15, 2019. The February public meeting that solicited these comments presented the Tier 1 Environmental Impact Study for the Lafayette western bypass termed the Lafayette Regional Xpressway or simply the LRX. Learn more about the meeting and the LRX by reading the recent Connector Comments meeting announcement. It is available by clicking HERE.

The period for public comments closes on March 18, so you may still have time to submit your statement of support, concerns, or questions. Although the attached comment is quite detailed, short comments simply stating support and/or concerns are of great value and provide evidence of public interest.

The meeting slide show included this information on how to provide written comments after the meeting:
  • Send comments to: HNTB Corporation,10000 Perkins Rowe, Suite 604, Baton Rouge LA 70810,
  • or, Email comments to kbprejean@hntb.com
  • Comments received or postmarked by March 18, 2019 will become a part of the record.

If you have submitted or do submit comments through one of these methods, please consider sharing your comments with us by pasting then in the comments section at the end of this article. However, do be aware that comments on this Connector Comments site are not official, so be sure to submit official comments as described in the bullets above.


__________________________________________________________

Comments of Michael G. Waldon, PhD
Following LRX Public Meeting February 28, 2019


The following comments are my comments submitted in response to the request for public comments at the Public Hearing held in Lafayette on February 28, 2019.
I have divided my comments into the following topic-related sections.

Statement of appreciation
Relationship to other projects and needed model scenarios
Where is the Eastern Corridor?
Arkansas example - phased funding and completion
Flooding
Preferred corridor selection
Public information and participation
Public support
2005 Study Corridor Map


Statement of appreciation

I first sincerely thank the LMEC for holding this hearing and giving the public an opportunity to share our support and concerns. Thanks is also due to the visionary citizens of Lafayette who saw almost two decades ago that the only viable path forward for a north-south interstate connecting I-49 segments was a bypass. At that time, the so-called I-49 Connector, the “Con,” was seen to be effectively dead; killed by fierce public opposition, environmental infeasibility, and legal challenges. And rightfully so.


Relationship to other projects and needed model scenarios

If we cannot call the LRX an alternative to the I-49 Con, then at least allow us to call it a substitute.

Although our Louisiana DOTD continues to waste many tens of millions of federal tax dollars on planning the I-49 Con, it is even less viable today than in the early 2000s when it was effectively abandoned. Today’s advancements in geochemical science provide an even better understanding of the environmental risk of further contamination of the Chicot aquifer, and there is a renewed concern for flooding since the 2016 regional flood disaster. Additionally, the massive negative impact of urban interstates, particularly on poor and minority communities has become even more apparent than it was  decades ago. The Con is today quite simply inviable (i.e. dead). For years the LRX plans were stalled in order to not “distract” the public with the promise of a substitute for the locally opposed Con. Let us delay no longer. The LRX is our most advanced proposed substitute for the failed Con, and I urge our professional, political, and civic leaders to now give its development their enthusiastic support. Lafayette does urgently need the LRX project. Although completion of the LRX may be far in the future, every distraction coming from the Con, and every other delay simply moves LRX completion further into that future.

If ever built, the I-49 Con is almost certain to be partially toll funded (https://connectorcomments.blogspot.com/2016/06/the-specter-of-tolls-on-i-49-connector.html). Former Secretary of Transportation Dr. 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 our Chamber of Commerce affiliate 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."

The infeasibility of building the I-49 Con project is highly relevant in planning for the LRX, as is the prospect of the Con also having tolls. Additional model scenarios need to be considered for LRX planning. First, the scenario that the I-49 Con will never be constructed needs to be considered as a scenario because this is in fact most likely. Second, the scenario that the I-49 Con is built but has tolls must be considered. Adding tolls to the I-49 Con in modeling will increase traffic flow and toll revenue of the LRX. Failure to include these added scenarios related to the future I-49 Con seriously impairs planning for LRX traffic and toll revenue. Failure to consider these scenarios could negatively impact Louisiana's financial negotiations in dealing with the private PPP project partner for the LRX. 

It seems relevant to mention here that despite the tens of millions of dollars already spent on I-49 Con planning, to-date the DOTD has refused to include an I-49  toll scenario, or to incorporate the LRX in any I-49 Con traffic models. To members of the public this appears to be a blatant attempt to inflate traffic projection to thus justify the Con project. This concern is relevant here because I hope that such manipulation of planning results is not a part of the LRX project. A refusal to run the added scenarios listed here would lead to a similar but opposite appearance. It would lead the public to think that the LMEC and DOTD are purposefully failing to consider scenarios in order to “put their finger on the scale” giving preference to the Con relative to the LRX substitute.

In summary of my concerns stated in this section, I am asking that two LRX planning scenarios (model runs) be added for projection of traffic and toll revenue. First, projections are needed for the most likely future in which the I-49 Con project is abandoned and never built. Second, The scenario that the I-49 Con is constructed as a toll funded project is additionally required. Planning for the LRX that does not consider these possible futures would have little credibility in the eyes of the public. 

Where is the Eastern Corridor?

Earlier LMEC documents map an eastern corridor extending from I-49 north of Carencro to I-10 west of Breaux Bridge. Documents include “TECHNICAL MEMORANDUM 4: ENVIRONMENTAL RECONNAISSANCE” dated February 2005, “LAFAYETTE METROPOLITAN EXPRESSWAY FEASIBILITY STUDY EXECUTIVE SUMMARY IMPLEMENTATION PLAN”  dated June 2005. Figure 4-1, “Study Corridor Map,” from the 2005 Technical Memorandum 4 is appended to the end of these comments for the reader’s convenience. I have seen no published planning or engineering study, or any rationale for dropping the eastern segment. Was a decision made to drop this option? Does any documentation of the decision exist and was the public invited to comment on the decision?

For many years local citizens have supported an eastern route bypassing Lafayette following the high ground of the Teche Ridge. Here are a few of the links demonstrating this long-term support information on this proposed roadway:
     Kelly Roberts Caldwell spokesperson comments for Lafayette citizen groups in the I-49 Connector FEIS, Volume II, page 299  dated April 30, 2001 https://connectorcomments.blogspot.com/2017/04/public-comment-from-16-years-ago.html
     Connector Comments blog, May 27, 2016, “The I-49 Lafayette Bypass Option: Teche Ridge” https://connectorcomments.blogspot.com/2016/05/the-i-49-lafayette-bypass-option-teche.html
     I-49 Teche Ridge Bypass Facebook page https://www.facebook.com/I-49-Teche-Ridge-Bypass-191859984503529/
     Harold Schoeffler’s presentation to the St. Martin Parish Council on February 16, 2016 https://soundcloud.com/mike-waldon-906517104/hschoeffler-stmartinparish-2016-02-16

Some have suggested that such a roadway might begin as a two lane expressway and expand where needed to four lanes. Combined tith the LRX, the Teche Ridge eastern bypass would provide Lafayette with a full loop. This would improve traffic, efficiency of travel, and attract desirable economic development to communities in both Lafayette and St. Martin Parishes.

This comment is directly relevant to the LRX plan because it appears that the proposed eastern corridor was aligned to connect with the eastern Teche Ridge bypass which has been so long supported by citizens here. While I understand that the LMEC desires, as far as possible, to keep roadway development within Lafayette Parish, it seems arbitrary and wasteful to drop the eastern corridor from all consideration. I ask that future planning include this eastern corridor as a potential future extension. 

Arkansas example - phased funding and completion

The Bella Vista Bypass (Arkansas Hwy 549) is being constructed in Arkansas as a part of their I-49 completion. I believe this is a good example of a state (Arkansas) listening to public concerns and developing a bypass rather than running the interstate through the heart of a community. The Bella Vista bypass has been designed and is being and constructed by ARDOT. It is being constructed one segment at a time as funding becomes available. While in Lafayette we are mired in I-49 planning that will likely never lead construction, Arkansas is building a highway. The Bella Vista Bypass is initially being constructed as a two-lane expressway which will be expanded to four lanes as funding permits. Arkansas has been able to design a viable project which will likely be completed long before we even begin construction. I urge the LMEC and Louisiana DOTD to consider using a similar incremental approach for the LRX. You can learn more about the Bella Vista Bypass from the Wikipedia article titled “Arkansas Highway 549,” by Googling news articles, and by downloading ARDOT project documents.

Flooding

In an urban setting such as the I-49 Con, finding hundreds of acres outside the flood zone for runoff retention is at-best expensive and at-worst impossible. However, in the rural setting of the LRX this is less of a problem and may actually be viewed as a project benefit. I urge the LMEC to make flood impacts from the LRX project an integrated part of planning. In other projects the Louisiana DOTD has been accused of failing to adequately consider flood impacts of their projects. My understanding is that, as a state agency, DOTD is not required to follow local ordinances requiring runoff retention or other flood impact analyses or mitigations. In spite of this I ask that the LMEC pledge to integrate runoff management planning into every level of LRX design including the plan development for roadway routing. In the rural setting of much of the LRX, retention ponds can actually be an aesthetic feature while possibly providing needed fill for roadway elevation. Landowners may also welcome retention ponds as neighboring features which improve property values and provide alternative drainage for development.  

Preferred corridor selection

I agree with the selection of the preferred corridor identified in the meeting handout. Not only does this selection best meet the criteria in the selection matrix, It is the alternative which may most quickly be constructed.

Public information and participation

At the public hearing I voiced my concern that the LRX web site (www.lrxpressway.com), was not being maintained, and information on the site appeared to be years out-of-date. I also noted that information from the 2017 public hearing had not been posted to the site as had been promised to me at that meeting. Following the 2017 meeting, I did try on multiple occasions to contact anyone from the LMEC about this, but was unable to do so using the outdated information then available on the web site. If I had expended more effort I could have likely made contact, but such a level of effort should not be required for a member of the public to simply get information.

I have additionally tried to find the schedule for the quarterly LMEC meetings, meeting agendas, and meeting minutes. As a public body in Louisiana, there are requirements that these be available on the web site. However, such information was not on the LRX web site. Following the February public meeting, I was told that some of this information is actually on the LEDA web site. However, I have not found this information on either the LEDA web site or the LRX site. The LRX website has an LMEC meeting page which is reached from a link on the “about LMEC” page:  www.lrxpressway.com/lmec-meetings/
However this page refers to the schedule of the 2011 meetings, and even that information is incomplete.

Please post on the LRX website all documents required by law and publish timely announcements of the quarterly LMEC meetings. At a minimum LMEC must meet the requirements of the Louisiana open meeting law, but I hope LMEC will exceed these requirements by actively seeking public involvement.

Since the February 2019 meeting, I do see that LRX public meeting materials have been added to the LRX web site for 2019, and prior public meetings including the 2017 public meeting. These posted documents have been useful and I thank the LMEC for providing them. However, I am unable to locate agendas, calendars, or minutes for the legally required quarterly meetings of the LMEC. I request that these either be provided on the LRX site, or that a link be placed on the LRX web site to wherever these documents are archived. I also ask that LMEC meeting announcements be prominently posted on the LRX website along with the agendas for upcoming meetings so that the public and media may attend.

Public support

There was a clear demonstration of the public’s interest in the LRX project shown by the standing-room only crowd at the February public hearing. Although I did hear mild concern from a few potentially impacted property owners, I did not hear a single person comment that they were opposed to this project. This stands in stark contrast to the near unanimous public opposition concerning the I-49 Con voiced at every public meeting held over more than two decades by DOTD and others. The public is not timid in voicing opposition, and I felt that the lack of any expression of opposition toward the LRX, as well as the many positive voices of strong support, together give an indication that the LRX project can be successful. The LRX can be a valuable addition to our region’s transportation infrastructure. I support its development. Thank you again for this opportunity to comment. 


2005 Study Corridor Map



February 2005 “Study Corridor Map” from Figure 4-1 in the report “Lafayette Metropolitan Expressway, Technical Memorandum 4, Environmental Reconnaissance.” The black circle was added to the figure to indicate the segment termed the eastern corridor in these comments.




Michael G. Waldon, PhD
Resident of Lafayette Parish, Louisiana

March 15, 2019