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.
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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
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
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
●
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.
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
