CITY to WISDOT: IMPACT STATEMENT "SIGNIFICANTLY DEFICIENT"

DPW Commissioner, City Engineer Call for Independent Peer Review

Special to the Readers of Milwaukeeworld

By Michael Horne

[Updated Saturday, December 29th, 2007 -- The Federal Highway Administration has extended the comment period until January, according to posts in The Milwaukee Journal Sentinel and Citizens Allied for Sane Highways. -- Ed.]

The Wisconsin Department of Transportation's Draft Environmental Impact Statement [DEIS] for the proposed I-94 North-South Freeway Reconstruction Project offers a "perfunctory treatment of transit alternatives" that is "not only contrary to National Environmental Policy Act [NEPA] requirements but also contrary to accepted regional transportation planning principles."
These statements were made in a letter sent today, Friday, December 28th, 2007, by City Engineer Jeffrey Polenske and Department of Public Works Commissioner Jeffrey J. Mantes to Robert Gutierrez, the project manager at WisDOT.
The pair call for an "independent peer review" of the DEIS and "that the public comment period be extended until the results can be made available."
"While DPW is supportive of freeway geometric improvements in the north-south corridor to improve safety, it is DPW's position that the DEIS is significantly deficient with respect to alternative analysis as required by NEPA and does not adequately justify freeway expansion.
"The Council on Envirenmental Quality in its regulations for implementing NEPA, requires that all reasonable alternatives be rigorously evaluated at a comparable level of detail as the proposed action so that the public may assess the comparative merits. ... The DEIS for the I-94 North-South corridor, therefore, would be expected to incorporate an alternative analysis that allows the puiblic to assess the relative merits, costs, and impacts of freeway expansion alternatives, rapid transit alternatives, as well as freeway expansion in combination with rapid transit improvements."
They go on to say, "The DEIS as written, however, dismisses rapid transit improvements as an alternative to freeway expansion in accommodated travel demand without analysis of potential rapid transit improvements.... The DEIS simply indicates that rapid transit service was eliminated from consideration as transit improvements alone will not address future traffic demand as determined by previous analysis performed in conjunction with the 2035 Regional Transportation Plan. ...
"Given the significant and lasting financial, socioeconomic, and environmental ramifications of the selected approach to infrastructure improvements in the north-south corridor, it is essential that all necessary information be made available to allow decision makers to select an alternative that best meets the current and future needs of citizens in the region and the state."
Ald. Bob Bauman, a transit activist who has been critical of the Department of Transportation's handling of the I-94 project, said he thought the letter was a good one and brought out "some points I wasn't aware of, like the Council of Environmental Quality regulations. Somebody in DPW is thinking. They did a good job on this."

See the full text of the letter below.

071228.cityletter.pdf