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.
Today I spoke with FWHA Tennessee Division Administrator Pamela M. Kordenbrock regarding our request for FHWA to require an Environmental Impact Statement for the Alcoa Parkway/bypass project and to clarify a couple of points in her previous response re. same. (See here.)
Ms. Kordenbrock said in her letter that "FHWA approved an Environmental Assessment" for the project in 2004. I asked if she could clarify that, and she said that no decision or "Finding of No Significant Impact" (FONSI) has been issued by FHWA, and that it was her understanding that TDOT has not submitted the final EA. She said that her letter was referring to FHWA's approval for TDOT to prepare an Environmental Assessment as opposed to a more thorough environmental study (i.e. Environmental Impact Statement).
I asked how FHWA arrived at a determination regarding the required level of environmental documentation (an EA v. an EIS) for a project of this scope, which involves acquisition of all new right of way as opposed to the original proposal to improve the existing corridor. She said she didn't know because that decision was made before she got there, and she referred me to TDOT.
I asked Ms. Kordenbrock if there were any FHWA records of the decision, such as meeting minutes, notes, memos, etc. She referred me to TDOT.
I asked if there were FHWA policies or procedures for approving the required level of environmental documentation. Ms. Kordenbrock said yes and that it was covered by NEPA, but that the FHWA initially lets TDOT make that determination acting on behalf of FWHA, and then FHWA either approves it or not. She again referred me to TDOT regarding their decision to prepare an EA v. an EIS.
I then asked if FHWA was not the regulator in charge of overseeing TDOT highway project environmental documentation and complance with NEPA. She conceded that yes, they were, and referred me to TDOT for more information.
Several times during our conversation, Ms. Kordenbrock said that I still had time to submit comments to TDOT regarding the project because no decision had been made regarding the EA. I explained that we had submitted comments to TDOT but that we were also asking FHWA, as part of FHWA's regulatory oversight authority, to require TDOT to prepare a full EIS and to include the original existing corridor improvement proposal as an option for the public to comment on a preferred build alternative. Ms. Kordenbrock suggested that I express my concerns to TDOT.
This is an unsatisfactory response from the FHWA. The FHWA is the regulator, but they are deferring to the regulated (TDOT) regarding FHWA oversight.
I concluded by asking Ms. Kordenbrock to at least file our letter away and read it again when TDOT submits their final EA for FHWA approval, and to consider requiring an EIS and public hearings on a preferred build alternative that included both the bypass and the existing corridor improvement options.
FixAlcoaHighway.com wrote to the Federal Highway Administration Office of Project Development and Environmental Review requesting four things with regard to the Alcoa Parkway/Bypass project:
1. Reject a "finding of no significant impact" and require a full Environmental Impact Statement for the 2004/2010 proposed bypass alternative.
2. Require the original 2000 "fix in place" improvement EA to be included in the final 2004/2010 bypass proposal EIS as an alternative build option for public comment.
3. Require a new public hearing on the combined 2000 EA and 2004/2010 proposal EIS.
4. Carefully review the EA/EIS reports and give full and equal consideration to public comments of all stakeholders, including the general public and residents of the affected communities, before making any final decision on a preferred build option.
After filtering down to the Tennessee Division office, FWHA Tennessee Division Administrator Pamela M. Kordenbrock responded by saying that they appreciate our comments and FWHA will pass them along to TDOT for consideration.
Further, Ms. Kordenbrock says that "the FHWA approved an Environmental Assessment, which was developed by the Tennessee Department of Transportation (TDOT), on March 24, 2004. The Department is currently preparing a final environmental document in accordance with the National Environmental Policy Act (NEPA)."
We are not exactly clear whether the statement "FHWA approved an Environmental Assessment" means FWHA approved preparing an EA or approved the plan based on a "finding of no significant impact" for the EA. We are also not clear on what a NEPA "final environmental document" is.
It is also our understanding that the Federal Highway Administration is the final decision maker on whether to approve a project's Environmental Assessment or Environmental Impact Statement, so we are not clear on why the FHWA forwarded our request to TDOT.
In fact, Gerald Solomon, Director, FHWA Office of Project Development and Environmental Review in Washington said in his response that "our Division Administrator in Tennessee, Ms. Pamela M. Kordenbrock, is responsible for decisions on review of projects under the National Environmental Policy Act."
We will be following up with Ms. Kordenbrock for clarification on these points.
In the mean time, if anyone else has similar concerns about the lack of public involvement in this project or FWHA oversight, please contact the FHWA officials mentioned below, and feel free to copy and paste from our letter.
Mr. Gerald L. Solomon, Director
Office of Project Development and Environmental Review
Federal Highway Administration
1200 New Jersey Ave., SE
Washington, DC 20590
Ms. Pamela M. Kordenbrock, Administrator
Federal Highway Administration Tennessee Division
404 BNA Drive
Nashville, Tennessee 37217
Copies of the letters (click image to view):
We asked Alcoa, Inc. about the project. Here is their reply:
In response to a recent inquiry, Christy R. Newman, Community Relations Manager at Alcoa Inc., Tennessee Operations said: "Currently Alcoa Inc. has not agreed to sell any property to the City of Alcoa or the State of Tennessee for the proposed Parkway project.
Secondly, while we are sensitive to the safety concerns surrounding Alcoa Highway in its current state, we are not in full support of the proposed route of the Bypass project as presented at the most recent public meeting. The proposed roadway plan hasn't been altered since public hearings were held in 2004. However, much about the physical and economic landscape of the area has changed. We believe that these changes mandate alterations to the plan."
Local officials said initially they thought the Alcoa Parkway/bypass could be built at a lower cost than improving the existing Alcoa Highway corridor, which at that time in 1998 was estimated at $50 million.
The estimated cost of the proposed Alcoa Parkway/bypass has been quoted as anywhere from $64 million to over $100 million.
Any way you look at it, it's a lot of money at a time when the economy is still struggling and local, state, and federal governments are slashing budgets and cutting spending wherever they can.
And just how reliable are these cost estimates, anyway?
An alert reader estimates that the asphalt alone could cost nearly $60 million at today's prices. And that doesn't include all the engineering, right of way acquisition, concrete, steel, excavating, construction, landscaping, labor, etc. etc.
And asphalt prices fluctuate with oil prices, and we all know where those are headed. If the asphalt had been purchased in September of 2008, the cost of the asphalt alone would have been $94 million.
And keep in mind that the highway would have to be resurfaced about every 12 years or so, at approx. 1/3 the original asphalt cost. That would be in addition to maintaining the existing Alcoa Highway corridor.
So nobody can really say what a highway project will cost until the bids are let and the contracts are signed. It's almost like writing a faith-based blank check.
SEE ALSO: Here's a reader submitted timeline of asphalt costs, along with traffic counts and some other interesting data. Note that traffic counts have declined, and appear loosely tied to unemployment rates and/or gas prices. And here's a chart of asphalt and gas prices.
In response to the Daily Times report on our meeting with Alcoa city officials, I sent a letter to the editor to clarify a few things and add a little more information about the proposed bypass.
- TDOT meeting participants have favored fixing the exisiting highway and not building a new bypass.
- Traffic counts have never been 75,000, currently around 52,000.
- Noise abatement is an issue.
- What happened at what meeting to change the project from a fix to a new road?
Today's Daily Times has a front page report on our meeting with Alcoa City officials, noting our recent decision to "switch tactics."
As reported in the article, we are suggesting that the original TDOT proposal to improve the existing Alcoa Highway corridor should be given another look and a fair hearing among all the stakeholders, including affected residents along the right of way of the proposed bypass alternative.
More after the jump...Continued...
We have changed the name of this site from stopalcoaparkway.com to fixalcoahighway.com. We decided to advocate for something instead of against. The old domain name/url will still work but it will be redirected here.
In response to a public invitation by City of Alcoa officials for citizens to come talk with them about the Alcoa Parkway/bypass project (as reported in the Maryville Daily Times on Nov. 11, 2010), the publishers of FixAlcoaHighway.com (formerly StopAlcoaParkway.com) met yesterday with City of Alcoa officials to discuss the project.
We met with Alcoa City Manager Mark Johnson and Assistant City Manager Bill Hammon to gather information about the history of the bypass proposal, the decision making process, and the public involvement in the decision to substitute the bypass alternative for the original TDOT improvement proposal.
We had a frank and open discussion about where the project is today and how it got there. We expressed our concerns and those of other citizens we have heard from.Continued...
The site includes a general description of the project as it is now proposed, a bypass. It does have a brief history regarding previous proposals. In addition there are links to the previous environmental assessments (1998 and 2004).
Rikki Hall at Metro Pulse has a good article recapping the history of this project. The article concludes: "We need a comprehensive EA that lays out all the options so the community can find the best choice and the state avoid a decision that will haunt us ever after."
The article: Let's Consider Our Options to Fix Alcoa Highway
In response to an open records request, TDOT has provided us with copies of the original 1998 Environmental Assessment for proposed Alcoa Highway improvements with public comments and the revised 2004 Environmental Assessment with public comments. We have included links to these documents in the "Resources" section on the right.
The original 1998 TDOT proposal was to improve the existing Alcoa Highway between Pellissippi Parkway and Hunt Road. It involved widening, limited access frontage roads, and a bridge to connect them.
The 2004 TDOT proposal scrapped that plan and replaced it with the currently proposed bypass. The report includes a discussion of the original proposal and how it came to be shelved in favor of the current proposal as a result of requests by local government officials and the chamber of commerce:
The proposed alignment of the build alternative considered in the 1998 EA began approximately 196 feet north of the existing Airport Road Bridge with two 12-foot traffic lanes in each direction, separated in the center by a 14-foot median with a center concrete median barrier. The proposed outside shoulders were 10-foot and the inside shoulders were 6-foot in width. That cross section began to transition near Cusick Road into three 12-foot traffic lanes in each direction separated in the center by a 22-foot median with a center concrete median barrier, with inside and outside shoulders of 10-foot. That cross section continued through the end of the project at Pellissippi Parkway.
Frontage roads consisting of two 12-foot traffic lanes and separated form the main line by a concrete median barrier were also proposed. Airbase Road on the west and Northpark Boulevard on the east would have been relocated to provide an interchange with the frontage roads. An interchange was also proposed at Wrights Ferry Road that would have required additional relocation on the east side. A bridge over the main line at Cusick Road was proposed to be constructed to provide access between the two frontage roads. Several slip ramps through the concrete barriers were proposed to provide connection between the main line and frontage roads. The overall design was to provide access control on the main line and allow the frontage roads to handle local traffic.
Comments received from agencies, organizations, and the general public were taken into consideration during development of the 1998 build alternative. Subsequently, the City of Alcoa and the Blount County Chamber of Commerce held workshops to deal with perceived deficiencies in the design.
Business owners had three primary concerns: (1) diminished access and visibility of their property after the completion of the project; (2) disruption to commerce that would occur during construction; and (3) ROW impact to their property. Likewise, the City of Alcoa was concerned with the potential loss of tax revenue during construction and substantial cost associated with relocation and adjustment of municipally owned utilities. Other non-municipally owned utilities would be faced with major relocation projects and associated costs. The City of Alcoa predicted the possibility of losing car dealerships to another location should the dealerships encounter a long-term loss of business.
Following the workshops, representatives of the Chamber of Commerce, business owners, and government officials began to seek alternative solutions to the needs of increased safety and capacity on State Route 115. Several ideas and plans were presented and the relative merits and weaknesses of each were considered. The concept of an alternate corridor was deemed to have the most potential for success.
At the 2004 public meeting, citizens in attendance raised two specific concerns regarding this process.
First, the 2004 Environmental Assessment included only a "no-build" and "build" option, with the "build" option being the bypass. The originally proposed "in place" improvements were not included for consideration as an alternative or for public comment.
Second, a question was raised as to why a full and comprehensive Environmental Impact Statement was not required for the new plan, which is a significant departure from the original plan and involves significantly more right of way acquisition and environmental impact, not to mention more than double the cost.
The currently proposed plan and Environmental Assessment presented at the Nov. 9th 2010 public meeting is essentially the same as the 2004 proposal and assessment. TDOT is preparing to submit it to the Federal Highway Administration for a "finding of no significant impact" (FONSI), which would allow the project to proceed with acquisition of right of way.
We are concerned that state and federal officials who will make the final decision and fund the project are not being given all the alternatives from which to choose, nor is the public being given an opportunity to voice a preference. Further, while local officials make some good arguments for the bypass, the current proposal represents the interests of local business, some of which are no longer in existence, with little consideration for the general public's concerns.
We also question how a project of this size and scope can be allowed to proceed without an Environmental Impact Statement. The National Environmental Policy Act (NEPA) gives federal agencies wide latitude and discretion in making this decision, but too often such decisions are a result of a flawed process and incomplete information.
Please take some time to review these documents, including the correspondence and public comments, to decide for yourself if the process that has gotten us to this point is a responsible and appropriate way to conduct the public's business.
TDOT has made available the transcript of the public hearing held on Tuesday, Nov. 9, 2010.
Don't forget to submit your comments to TDOT regarding the proposed Alcoa Parkway/Bypass before November 30, 2010.
Comments must be postmarked by Nov. 30, 2010.
Here is the comment form provided by TDOT.
You can include additional sheets with the form if there is not enough room or you want to type your notes instead of hand write them. If you do this, don't forget to write "see attached" on the TDOT comment form and include your name, address, etc. on the additional sheets along with the project name, "Project Comments-SR-115 (Alcoa Hwy) Bypass"
Written statements and other exhibits can be submitted by mail to:
Project Comments-SR-115 (Alcoa Hwy) Bypass
Tennessee Department of Transportation
Suite 700, James K. Polk Building
505 Deaderick Street
Nashville, TN 37243-0332
Or by email to TDOT.email@example.com
If you send an email, we suggest putting "Project Comments-SR-115 (Alcoa Hwy) Bypass" in the subject line.
According to TDOT at the Nov. 9th meeting, several communities will be impacted by noise pollution from the Alcoa Parkway/bypass as proposed.
When asked about plans to address it, TDOT basically said that specifics wouldn't be known until a design is finalized and that there wold be a more detailed noise abatement study and public hearings.
If history is any guide, don't expect much. The Pellissippi Parkway Extension Environmental Impact Statement has a lengthy section on noise pollution. Detailed studies were done showing exactly who would be impacted and by how much in terms of increased decibel levels.
The study then looked at mitigation using realignment, traffic control measures, and concrete sound barriers. Realignment was rejected because the route is already planned for minimum possible environmental and community impact. Traffic control measures were rejected because they would be "contrary to the purpose of the road."
Regarding concrete sound barriers, the report concludes (pg. 3-66):
Eight locations were considered for an in-depth barrier analysis. All noise barriers were evaluated at heights ranging from six to 24 feet. [..] All eight barriers were determined to be too costly based on cost criteria defined in the TDOT noise policy and procedure guidelines, as demonstrated in Table 3-22. The cost per benefitted residence in all eight cases was higher than the allowable $38,000. This was due in part to the low density of homes in areas likely to have noise impacts, and because of the height of the noise barrier that would be required to achieve adequate mitigation.
The Alcoa Parkway/bypass will border neighborhoods with much higher population density, though, so a detailed noise study, if one is ever conducted, might come to a different conclusion for this project.
A reader corresponded with TDOT regarding the need to at least plan for future passenger rail service between the airport and Knoxville, noting that there are tracks across the highway that go all the way to the Worlds Fair site in downtown Knoxville.
The problem is that the proposed improvements do not allow for the tracks to be extended to the airport side of the highway, so the suggestion is to at least include a tunnel or underpass for future use if a new Hunt Rd. interchange is built.
TDOT responds to the query:
As you may already know, there are others in the greater Knoxville area who are also interested in the potential use of the track between Alcoa and Knoxville. From what I understand, there is still some freight rail traffic on this track, but not enough to preclude consideration of its future use for commuters.
TDOT recently provided funds to the Knoxville Area Transportation Planning Organization (TPO) to undertake a review of various regional corridors and then recommend those with near-term transit potential, so that more focused design efforts can begin. This corridor will very likely be evaluated. I am therefore copying Jeff Welch, the TPO's director, to make him aware of your interest.
I am also sharing your suggestion about incorporating an underpass with the TDOT project manager for the Alcoa Highway project, Mike Russell. [..] He will be better informed as to the project development schedule and our ability to consider the proposal at this stage.
The reader also notes that the $500 million Kinsey-Probasco plan for the new Downtown Alcoa development includes "future light rail service access between downtown Knoxville and the airport."
Approx. 100 people including residents, local government, and TDOT officials attended the Nov. 9 TDOT public meeting on the proposed Alcoa Bypass/parkway project. Following is our report with a summary of the public comments.Continued...
At Tuesday's TDOT meeting someone asked where the traffic on Alcoa Highway is originating and where it's going. TDOT did not have that information available.
Poking around the Knoxville Regional Transportation Planning Organization (TPO) website, we found some clues in the 2008 East Tennessee Household Travel Survey.
Cross-county travel statistics do not include routes, but it's a safe bet that most travel between Blount Co. and Knox Co. involves Alcoa Highway.
Here's what we found interesting...Continued...
We have added the raw, unedited audio recording of the Nov. 9 TDOT meeting in the 'resources' section. Right click and save as to download the 17MB file.
Or listen to it here:
Don't forget to submit your comments to TDOT regarding the proposed Alcoa Parkway/Bypass before November 30, 2010.
Contact TDOT with “Written statements and other exhibits.” Must be submitted within twenty-one (21) days after the meeting date to:
Project Comments-SR-115 (Alcoa Hwy) Bypass
Tennessee Department of Transportation
Suite 700, James K. Polk Building
505 Deaderick Street
Nashville, TN 37243-0332
If you send an email, I recommend you put "Project Comments-SR-115 (Alcoa Hwy) Bypass" in the message header.
About this site
- TDOT public meeting on Alcoa Highway Bypass project (1 reply)
- Alternatives (9 replies)
- Request for FHWA to require an Environmental Impact Statement (2 replies)
- KNS Guest editorial: Alcoa Highway bypass: Bad process leads to bad project (1 reply)
- FHWA EIS request update: TDOT response (1 reply)
- Maryville Daily Times report on our meeting with Alcoa city officials (1 reply)
- New documents added to the Resources section: 1998 v. 2004 (3 replies)
- WATE report (4 replies)
- Maryvile Daily Times; Parkway a done deal? (1 reply)
- Stop Alcoa Parkway (10 replies)
- Comments Deadline - Tuesday, Nov. 30, 2010 (1 reply)
- Noise abatement (2 replies)
- TDOT PROJECT WEBSITE
- FHWA/TDOT Finding of No Significant Impact
- 1998 TDOT proposal EA with public comments
- 2004 TDOT proposal EA with public comments
- TDOT transcript of Nov. 9 2010 public meeting
- TDOT public comments received after Nov. 9 2010 meeting
- Raw audio recording of Nov. 9 2010 TDOT meeting
- Map of proposed route
- Knox TPO Feb. 2010 Agenda w/attachments
- Map of local area TDOT projects
- Knox TPO Long Range Transportation Plan Update
- Knox TPO Transportation Infrastructure Program FY11-14
- Knox TPO Executive Board minutes Aug. 2006
- TDOT Nov. 9 2010 public meeting notice
- Printable opposition flyer for public meeting
- Maryville Daily Times ad
- U.S. Department of Transportation
- Tennessee Department of Transportation
- Knoxville Region Transportation Planning Office