- Send comments to: HNTB Corporation,10000 Perkins Rowe, Suite 604, Baton Rouge LA 70810,
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- Comments received or postmarked by March 18, 2019 will become a part of the record.
Friday, March 15, 2019
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:
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
Preferred corridor selection
Public information and participation
2005 Study Corridor Map
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.
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.
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
● Daily Iberian, February 17, 2016, “Teche Ridge I-49 proposal gets traction in St. Martin” https://www.iberianet.com/news/teche-ridge-i--proposal-gets-traction-in-st-martin/article_8568414e-d593-11e5-8443-1b20b9abbe76.html?utm_medium=social&utm_source=facebook&utm_campaign=user-share
● 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.
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.
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.
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.
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.
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.
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