Monday, November 15, 2021

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


Mike Waldon 
Mon, Nov 15, 2021 at 3:56 PM
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 ( 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 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:
November 15, 2021

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