Today I spoke with TDOT Environmental Division Director Suzanne Herron regarding our concerns about the project and the level of public involvement, our request for a full EIS, and our request for the original corridor improvement proposal to be included as an option for public comment on a preferred build alternative.
We discussed the decision to require only an Environmental Assessment (EA) instead of a full Environmental Impact Statement (EIS), and what oversight the FHWA had in that process. Ms. Herron said that TDOT makes an initial assessment regarding the level of environmental documentation needed based on NEPA and FHWA guidelines, the type and scope of the project, the anticipated level of environmental impact, and their past experience with similar projects. She said their recommendation is then submitted to the FHWA, who either approves the decision or not. She also mentioned that TDOT has a good working relationship and open lines of communication with FHWA on such matters. In this case, FHWA approved the preparation of an EA.
I asked if there were any records of the decision making process behind TDOT's recommendation to the FHWA and the justification for only preparing an EA. Ms. Herron said there probably were but she would have to look for them. I said we would submit an open records request.
I asked if there was any way that TDOT or FHWA would consider requiring an EIS for the project. Her response suggested it wasn't likely at this point in the process.
I also asked why the original existing corridor improvement was not included as a build alternative in the 2004 EA. Ms. Herron said she did not know and that the 2004 EA only mentioned it as a "previously studied" alternative. She said she would have to research it further.
Ms. Herron did agree to discuss with her manager the possibility of including the original existing corridor improvement as a build alternative in the final EA document. I asked if it was her professional opinion that it should be included, and she said in effect that she would have to study the history, the rationale and the local politics involved.
Regarding the current status of the project and the environmental documentation, Ms. Herron dropped a bombshell. She said it was her understanding that TDOT was finalizing the environmental documentation (the EA) for submission to the FHWA, and that typically at this point there would be no further public meetings required because they had already been held on the EA as proposed.
I pointed out that some things had changed since the last public meeting in November.
First, TDOT officials said at that meeting that noise impact and abatement studies had not yet been performed, but they would be as part of the final design and there would be public hearings on the findings. (I'm not exactly clear if that would be during the environment phase or the final design/build phase.)
Second, I noted out that Alcoa Inc. Tennessee Operations had recently expressed concerns about the bypass as currently proposed, saying that "much about the physical and economic landscape of the area has changed" since the original 2004 proposal and that "these changes mandate alterations to the plan." I also noted that the Alcoa City Manager was recently quoted in the local paper as saying they would be making some adjustments "to help Alcoa" (the company) and would submit them to TDOT.
So we'll see what happens next. Stay tuned.
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- TDOT PROJECT WEBSITE
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- TDOT transcript of Nov. 9 2010 public meeting
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