Saturday, December 29, 2007
Appears to be the answer is 'yes.' From the AASHTO Practictioner's Handbook:
Extending the Comment Period
Requests to extend the comment period are frequently received, particularly for larger and
more complex projects. The decision about whether to extend the comment
period rests with the lead agency, which is typically FHWA for a highway project. The requirements of Section 6002 of SAFETEA-LU should be considered when deciding whether
to extend a comment period. Section 6002 establishes (with allowance for some exceptions) a 60-day maximum comment period for comments on a DEIS, and a 30-day maximum for other comment periods.
Friday, December 28, 2007
"The DEIS indicates that WISDOT's preferred alternative is the Safety and Design Improvements with Added Capacity. While DPW is supportive of freeway geometric improvements in the north-south corridor to improve safety, it is DPWs position that the DEIS is significantly deficient with respect to alternative analysis as required by the National Environmental Policy Act (NEPA) and does not adequately justify freeway expansion."
DEIS stands for Draft Environmental Impact Statement.
More at Michael Hornes' MilwaukeeWorld.
Scott informed us of FHWA's move today. WisDOT has not responded, at least in public -- the Dec. 31 cut-off date is still on its web site, but it would be hard to imagine Frank Busalacchi and co. blowing off the feds' request.
CASH, Ald. Bob Bauman and the city of Milwaukee sought extensions to the comment period.
Remember, though, that an extended comment period ain't a done deal. Its best to get comments in by Dec. 31 and add to them later than to bet the comment period will be extended and be wrong about it.
seeks extended comment period on I-94 project
Dec. 28 – The Wisconsin Department of Transportation’s improper withholding of requested records is blocking a full review of the agency’s plan for North-South I-94, Citizens Allied for Sane Highways said Friday.
CASH is asking WisDOT Secretary Frank Busalacchi to extend until Feb. 1 the time period during which members of the public may comment on the draft Environmental Impact Statement for the project. The comment period now is scheduled to expire Monday.
CASH is a coalition formed to oppose freeway expansion in Milwaukee.
The agency’s failure to provide the records likely is a violation of the state’s Open Records Law, CASH co-chair Gretchen Schuldt said.
“We asked WisDOT on Nov. 30 for certain electronic files so we could closely examine impacts of WisDOT’s proposal on affected properties,” Schuldt said. “WisDOT never provided any files, and then the official we were dealing with went on vacation until after the comment period closes. That’s not the way the law is supposed to work.”
WisDOT suggested that CASH should seek some of the requested information from county governments, but failed to release even records generated by WisDOT staff or contractors.
CASH, in a letter to Busalacchi, also raised concerns with the timing of the comment period – it begins and ends with the holiday season.
“WisDOT couldn’t have chosen a better time to minimize public participation than the holidays, when people are incredibly busy and incredibly pre-occupied,” Schuldt said. “All we are asking for is an extended comment period, which will give interested residents a chance to reengage in the process and will allow appropriate time to resolve the open records issue.”
Thursday, December 27, 2007
You can weigh in on the WisDOT plan to spend $1.9 billion plus hundreds of millions of dollars more in interest cost by
- calling the project hotline: (262) 548-8721
- e-mailing email@example.com
- faxing comments to (262) 548-5662
- or sending them to WisDOT: Attention Bob Gutierrez at P.O. Box 798 Waukesha, WI 53187-0798
Wednesday, December 26, 2007
And then there is the little matter of taking away the 27th Street ramp for people driving northbound through the Mitchell Interchange. WisDOT says that keeping the ramp open would mean the destruction of several houses. 27th Street business owners, fearful that closing the ramp will hurt them even more, are telling WisDOT to work harder to find a better plan.
Tom Graebner, ower of the Hospitality Inn at 4400 S. 27th St., says that "the closure of the westbound 27th Street exit will directly impact my business and its value to the community."
"I'm told an alternative would be to use the Layton Ave. exit," Graebner wrote in a letter. "In my opinion people will not choose to exit two miles from their destination, in the midst of a city they may not be familiar with, and navigate westbound through three stop-and-go lights before reaching 27th Street. I don't choose to do it, and I live here. Whatever problems are caused by congestion are limited to a small portion of the day, and are certainly no worse than on many other areas of the freeway. In addition, valuable taxpayer money has already been spent on improving and tweaking the area in the past. Why the sudden desire to rob 27th Street of a great asset?"
Letter after letter from business owner, telling Frank Busalacchi and the rest of the paveheads at WisDOT what a terrible idea they've come up with.
Stay tuned for more.
Thursday, December 20, 2007
Meanwhile, the Wisconsin Department of Transportation wants to spend $1.9 billion-plus-hundreds-of-millions-in interest to expand North-South I-94 even though it will add enormous amounts of construction- and vehicle-related pollution just when Milwaukee is likely to be declared a non-attainment area for particulate pollution under new EPA guidelines. WisDOT's very merry projections of declining pollution levels after the expansion project are based in part on huge increases in mass transit and guess what -- WisDOT isn't proposing funding for new mass transit projects.
WisDOT also says proposed interchange at Drexel Ave. in Oak Creek may (WisDOT quite often uses the word "may" when it means "will") hurt redevelopment efforts on the S. 27th St. corridor in Milwaukee and may mean businesses may be less likely to move to developed commercial strips when they can waltz into the new commercial area opened up by the interchange. "Induced development," they call it.
And here we are again: Milwaukee is hurt by the decision to cut the No. 9 bus route; Milwaukee is hurt by WisDOT's decision to push ahead with a pollution-generating freeway expansion project when Milwaukee is going to be a non-compliance area for pollution; and Milwaukee is hurt by WisDOT's decision to subsidize suburban sprawl in Oak Creek at the expense of commercial strips in the big city.
And I haven't even mentioned the reeky, rotten Pabst Farms interchange deal that will open up more of Waukesha County at the expense of -- you guessed it -- Milwaukee.
What gives here? These sprawl subsidies are bestowed by WisDOT, which answers directly to the road-building industry and Gov. Jim Doyle. I'm trying to figure out why Doyle is using the WisDOT budget to fillet and gut Milwaukee and Milwaukee redevelopment efforts.
A cynic might suggest that the state's transportation policies are designed to keep Milwaukee residents in Milwaukee and suburban residents flying through the city as fast as wider freeways can carry them.
Tuesday, December 18, 2007
Monday, December 17, 2007
Here's the summary, from WisDOT's own draft Environmental Impact Statement, on the effects of an interchange at Drexel Ave. in Oak Creek.
New interchange at Drexel Avenue
Induced growth very likely
• The pace and intensity of development along 27th Street may increase.
• The development pattern along Drexel Avenue could change from residential/open spaces to
• Potential to influence interregional land development patterns - redevelopment along 27th Street in Milwaukee may be discouraged as the ease of developing “greenfield” sites in Oak Creek and Franklin increases.
• May increase the competitiveness of new “greenfield” sites and discourage reinvestment in existing urban corridors. (Emphasis mine)
Hmm, wonder if the brains at WisDOT also figured out that reducing access to 27th St. from the freeway, as current plans call for, also will be a devastating blow to businesses along the strip.
Betcha they have.
Exposure to traffic pollution may increase respiratory problems and reduce lung volumes in children with asthma, according to researchers who studied the effects of road and traffic density on children's lung function and respiratory symptoms in the border town of Ciudad Juarez in Mexico.
"Our results show that close proximity to vehicular traffic-related emissions, either at home or at school, can lead to chronic effects in the respiratory health of children with asthma," said Fernando Holguin, M.D., M.P.H., assistant professor of pulmonary medicine at Emory University School of Medicine, and lead author of the study, which appeared in the second issue for December of the American Journal of Respiratory and Critical Care Medicine, published by the American Thoracic Society.
Traffic-related pollutants are known to be associated with asthma severity, but to what extent they affect airway inflammation and lung volume in both asthmatic and nonasthmatic children was unknown. "Major cities along the northern and southern US borders often have high levels of vehicular traffic flows, especially at the border crossing points. Vehicular traffic emissions from the high density of border crossing traffic may be negatively affecting the health of populations who live in nearby areas," said Dr. Holguin.
To investigate how specific traffic-related pollutants affected children's lung function and respiratory symptoms, the researchers recruited 200 age- and sex-matched asthmatic and non-asthmatic schoolchildren from ages six to 12. Over the course of a year, they measured road and traffic density and traffic-associated pollutants near the children's homes and schools, and evaluated each child's lung function and respiratory symptoms consecutively for four months.
The public comment period for the proposal doesn't end until Dec. 31.
Maybe Ald. Witkowski knows something the rest of us don't.
More on the latest North-South developments here.
Thursday, December 13, 2007
There's even a one-paragraph discussion of the topic on page 118 of the 367-page draft Environmental Impact Statement for the proposed, unfunded $1.9 billion I-94 expansion project:
The study area in Wisconsin is in attainment for PM2.5, as based on the present designation. The air quality monitoring network in southeastern Wisconsin indicates that it is likely that a portion of the study areas may be designated as being in non-attainment for the revised PM2.5 standard, which became effective on December 17, 2006. The DNR is presently preparing information for review by U.S. EPA. A final determination on the attainment designation is expected near the end of 2009.
Wait! 2009! Isn't that the year WisDOT Secretary Frank Busalacchi suddenly decided that he wants to begin rebuilding the Mitchell Interchange in Milwaukee, afterWisDOT repeatedly assured neighborhood residents that the Milwaukee phase of the project wouldn't begin until the next decade? Could it possibly be that Busalacchi wants those shovels in the ground, the state fully committed to the project, before the non-attainment designation is officially announced?
Cause once that announcement comes, people might wonder why we're not trying to get cars off the road, instead of putting more of them on the road.
The state, by the way, fully aware that there are too many particulates entering too many lungs, is in absolutely no rush to do anything about it.
In that same single EIS paragraph:
If the designation changes from attainment to non-attainment, SEWRPC and the DNR will develop measures to control PM2.5 emissions in accordance with U.S. EPA guidelines so that the region will be in attainment by 2015.
And, in case you're wondering, here's a few things the EPA says PM2.5 exposure is associated with:
* Premature death in people with heart and lung disease
* Non-fatal heart attacks
* Increased hospital admissions, emergency room visits and doctor’s visits for respiratory diseases
* Increased hospital admission and ER visits for cardiovascular diseases
* Increased respiratory symptoms such as coughing, wheezing and shortness of breath
* Lung function changes, especially in children and people with lung diseases such as asthma
* Changes in heart rate variability
* Arrhythmia (irregular heartbeat)
* Changes in subtle indicators of cardiovascular health, including levels of C-reactive protein and fibrinogen
Breathe on while you can.
Wednesday, December 12, 2007
There was a closed door with the word "Court Reporters" on a sign next to it. Since WisDOT said that court reporters would be on hand to take comments, I brilliantly deduced that somewhere behind that door, court r eporters would be on hand to take comments. I wanted to hear what was being said, so I opened the door. I saw a court reporter at a table or desk. Across from her was a man in a chair giving comments.
A WisDOT minion ran up to me and told me I could not go in the room
"You have to wait," she said.
I told her I wanted to go in. She said there was only one person allowed at a time. "No, you have to wait."
Bob Gutierrez, who gave the WisDOT sales job for freeway expansion that he passed off as an informational presentation, said later that the door could be left open if the individual testifying wanted others to listen what he/she said, and closed for anyone who wanted to give private testiomony at the public hearing.
Well, I said, does WisDOT have any way of knowing for individual testifiers whether the door should be opened or closed?
No, he said, but I could follow people as they prepared to speak and ask if I could come in and listen.
Two different responses from two different WisDOTters, neither whom seems to understand why the word "public" is in the phrase "public hearing."
Tuesday, December 11, 2007
(WisDOT conveniently set the public comment period from the Friday before Thanksgiving to New Year's Eve, exactly over the holiday season, when the people's lives are harried and they are pre-occupied with things other than government agencies run amok.)
The measure calls for the state to forego freeway expansion -- it does not urge it to forego reconstruction and safety improvements -- in favor of mass transit development. The vote was 10-4. The JS says the council voted to oppose expansion south of the city, but Bauman's resolution opposes expansion south of the Mitchell Interchange, which includes a good stretch of freeway within the city as well.
And a reminder about the WisDOT-sponsored public hearing Wednesday, Dec. 12, at the Best Western at 5105 S. Howell Ave. in Milwaukee. (It's not really a public hearing, but WisDOT thinks we're dumb enough to believe that this sham process is a public hearing.) First WisDOT gives a presentation on why its ideas for freeways are a good idea - people with different views are not scheduled to give presentations -- and then folks can submit written comments or recite them to a court reporter. Is that like any public hearing you've ever heard about?
If you're interested, the event is from 4 p.m. to 8 p.m. If you're not interested, please don't forget to submit your comments to WisDOT by Dec. 31. You can do so by:
* calling the project hotline: (262) 548-8721
* e-mailing firstname.lastname@example.org
* faxing letters to (262) 548-5662
* or writing to to WisDOT: Attention Bob Gutierrez at P.O. Box 798 Waukesha, WI 53187-0798
Sunday, December 9, 2007
From WISH-TV in Indianapolis:
INDIANAPOLIS - Improvements for Interstate 69 between I-465 and Exit 10 may be further down the road than expected. Local officials say the Indiana Department of Transportation has pushed major reconstruction back perhaps as long as 13 years...
The project would be funded from the $3 billion Major Moves deal that leased the Indiana Toll Road to a French and Australian consortium. Approximately $530 million of Major Moves money is earmarked for highway improvements in Hamilton County. Now INDOT officials say matching federal dollars are needed to get the job done.
"The Major Moves plan and program ends in 2015," said INDOT spokesman Will Wingfield. "The current projections call for the federal highway trust fund to dry up in 2011. It's really difficult to talk in definitive terms about things further than 2015."
Wingfield said INDOT will follow-up work north of I-69 and I-465 with additional projects as the budget picture becomes clearer. He added Congress will likely reauthorize highway funding during the next legislative session. Some projects could start sooner if funding becomes available, he added.
"That will give us a better picture, because obviously for an interstate, federal funding is a large part of what pays for those projects."The Wisconsin Department of Transportation, meanwhile, is charging ahead with plans for its unfunded $1.9 billion expansion project for North-South I-94 and and unfunded reconstruction Zoo Interchange project of unknown cost. Why should the Wisconsin Department of Transportation care if it puts huge financial burdens on state taxpayers? As long as the road-builders get paid, all is well.
Thursday, December 6, 2007
WisDOT isn't even going to begin to talk about how to come up with the money for its $1.9 billion freeway expansion plan until after it is approved by the feds, according to the JS.
Gutierrez said the financing details would be worked out after the project receives federal approval and an estimate on the federal dollars available. At that time, the DOT will ask the Legislature to allocate the money necessary to complete the work by 2016.
In other words, this could be another "find the money as you go" WisDOT project. What's the impact on driver taxes and fees? What's the impact on the state's debt load? What's the impact on the state's credit rating? We don't know, because WisDOT doesn't tell us. It is simply bad planning.
In that same story, by the way, the JournalSentinel reported that Citizens Allied for Sane Highways criticized the lack of an invoice plan for the project. That is incorrect. We criticized the lack of a financing plan, not an invoicing plan.
Wednesday, December 5, 2007
("Global warming" is a phrase not mentioned in the state's environmental impact statement for its proposed unfunded $1.9 billion North-South I-94 expansion project.)
Says the Transportation Group's recommendation:
A recent study in the Seattle metro area estimated that even if new car mileage were increased to 94.5 mpg and the carbon content of fuels reduced by 40%, it would still require an 18% reduction in VMT to meet the region’s goal of cutting GHG from transportation by 80%. The magnitude of needed VMT reduction may be different in Wisconsin, but the principle is the same...
To combat global warming, transportation policy must focus instead on accessibility – facilitating access to destinations via compact development and varied modes of travel, as well as auto mobility. This effort will require considering land use and transportation together and a variety of other actions...
Fix it first: Wisconsin shall strengthen its fix-it-first policy on roadways to place a priority on rehabilitation of existing infrastructure over adding new lane-miles....
This multifaceted policy faces a variety of barriers. In general, it will be necessary to work cooperatively with local governments so that they agree to new rules in a field – local land use planning – that is traditionally a local issue. To this end, this policy should not pre-empt any local decision-making that does not affect the statewide goal of GHG reduction, and it should emphasize incentives to local governments and private entities as well as new requirements. Another barrier is institutional resistance to altering the paradigm that maximizing mobility (rather than accessibility) is the ultimate goal. This institutional inertia should not be underestimated, and must be addressed with strong leadership in all affected agencies.
There are many more recommendations from the Task Force's Transportation Work Group, along with an email link for public comments, here (scroll down on the page). Comments are due Saturday, Dec. 8. Hurry, time is running out!
Monday, December 3, 2007
First, though, we wanted to bring you some good reasons to oppose the project.
• WisDOT’s $1.9 billion cost estimate for the project includes a 3% annual inflation adjustment. Based on recent history, this is unrealistically low. The American Road & Transportation Builders Association reported in October that the cost of highway and street construction materials was up 6% from September 2006 to September 2007. "Over the last three years, annual highway and street construction material prices have increased nearly 32 percent," the association said.
• The environmental justice analysis is inadequate at best. The study suggests that minorities would benefit from the project because “the study-area freeway system connects Chicago to Milwaukee, both of which are ‘minority majority’ communities.” The reader can only guess at the supposed relevance of that. The study does not discuss how many minorities actually travel between those cities using the freeway, nor does it mention the scores of majority-white communities connected by North-South I-94. The EIS does not include available documentation regarding work commuting patterns, which would shed substantial light on the issues of who benefits from the expansion proposal and who does not.
• There is no funding plan for the project. Busalacchi said in announcing the plan that work will continue “to identify the funds needed to complete the project." The source of funds needs to be identified before the state commits to such enormous expenditures. State residents have a right to know how this will affect their taxes and transportation fees and the state’s financial outlook. They also have a right to know how a project that will absorb so many resources will affect other needed road and highway projects in the state. While state officials have said publicly several times that the Federal Highway Trust Fund could provide a significant share of the money for the project, that fund is projected to have a negative balance by 2009. We reported on this in March http://www.storyhill.net/IssuesFreeway65.htm and in June http://www.storyhill.net/IssuesFreeway67.htm
• The project would drain money desperately needed for mass transit in the Milwaukee region. The EIS discusses the state’s past contributions to transit systems, but does not directly address how this massive project would affect future transit funding.
• The EIS does not include adequate protections for students and staff at schools near the Interstate. Numerous studies show that traffic-generated particulates and pollution have adverse affects on health, particularly among children. A recent study shows that students attending schools within 500 meters of a freeway can suffer permanent lung damage. In Milwaukee, schools within 500 meters of the North-South freeway within the project area include Cooper, Garland, Lowell and Whittier elementary schools; Ronald Wilson Reagan College Preparatory High School, IDEAL Charter School and Professional Learning Institute at the Sholes Educational Complex; St. Roman Parish; and Salam School. While WisDOT projects decreased pollution, the EIS does not consider the effects of any level of pollution on children’s health. WisDOT maintains only that it is not legally obligated to mitigate air pollution from the freeway.
• The project would have negative impacts on many threatened and endangered plant and animal species, including:
-- Butler’s garter snake
-- Eastern massasauga rattlesnake
-- Blanding’s turtle
-- Bluestem goldenrod
-- Seaside crowfoot
-- Reflexed trillium
-- Smooth black-haw
-- Alkali bulrush
• 53 to 56 acres of wetlands would be affected. Of the 128 wetlands that would be affected, 53 are in Milwaukee County, 28 are in Racine County, 39 are in Kenosha County and eight are in Lake County. The loss of an additional 26 acres is anticipated to accommodate reconstruction of I-94 interchanges in Racine and Kenosha counties. Mitigation plans are insufficiently addressed in the EIS.
• The EIS does not analyze or discuss potential light pollution from the project. This is a significant omission because homes and businesses – particularly those in Milwaukee -- would be nearer to the freeway.
• The EIS states that the preferred expansion alternative would increase impermeable surface associated with the freeway by 25% throughout the project area and about 50% in Milwaukee County. The EIS does not include plans to mitigate potential flooding and includes insufficient information about planned efforts to reduce polluted runoff from the freeway. The document suggests that WisDOT will rely on grass ditches in Milwaukee County to cleanse the runoff. (We do wonder how large a grassy ditch would have to be to cleanse the runoff from an expanded Mitchell interchange.)
• The EIS is silent on the impact of oil prices on construction costs, and is silent on the impact of oil prices on how much people drive.
You can read the EIS for yourself. It is at http://www.dot.wisconsin.gov/projects/d2/i94/eis.htm
You can send comments about the eis by calling the project hotline at (262) 548-8721; e-mailing WisDOT at email@example.com; faxing letters to 262-548-5662; or sending them to WisDOT: Attention Bob Gutierrez at PO Box 798 Waukesha,
Here is the schedule for all four hearings
* Oak Creek/Franklin
Dec. 3, 4 p.m. - 8 p.m.
West Middle School
8401 13th St.
Bus Routes: #15, #48
* Kenosha Area
Dec. 6, 5 p.m. -8 p.m.
Mahone Middle School
6900 60th St.
Bus Routes: #6, #3 North, #3 West, #5 South
* Racine Area
Dec. 11, 5 p.m. -8 p.m.
2320 Renaissance Blvd.
Bus Route: #27
Dec. 12, 4 p.m. - 8 p.m.
Best Western Airport
5105 S. Howell Ave.
Bus Routes: #80, #11