When is Phase I Study Necessary?

We were troubled by some of the reaction we received following other meetings, too. For example, Ms. Lamie’s reply which deferred answers to a future Phase I study.

According to the Department’s BDE Manual, a Feasibility study is typically initiated only when the facility will be a four lane highway, not when lesser solutions might apply. A Corridor Protection study is needed only “for a major highway project on a new location...” From her comment, we gathered that she still supported the GC project.

There are several kinds of Phase I studies. BDE Manual, Chapter 11 states that “Phase I work can vary from a very minor type study to an in-depth investigation…” Only if the project is to move forward would a full NEPA EIS be necessary. No EIS is needed if the required work is classed as an (non-major) improvement. It should be clear from the material presented in this paper that improvements to existing roads will forever be adequate to handle future traffic, without leading to unacceptable congestion.

Secondly, from our reading of the Department’s BDE Manual, Chapter 25, it appears that an Environmental Impact Statement (EIS) is valid for only 3 years. After that time, supplemental information is needed to confirm nothing has changed. If that’s true, we wonder why the Department would consider a Corridor Protection study that is more than 10 years old to be valid, or for the Secretary to use the studies to tell us the project is still “viable?” It’s not as if the studies don’t address the same topics as an EIS would address. It seems to us that the Department should want a preliminary evaluation (following the 10-year hearing, perhaps?) to update the existing studies before launching a $23.7 million EIS, as was put into the Capital Budget a couple of years ago.

Finally, much of the data we cited came from the Department’s own sources. One would expect that such data is not collected simply to be filed away, but has some purpose. One would also expect that it’s periodically assessed by staff, summarized, and briefed to management. The district ought to know the things that are in this paper, already. They should be familiar with studies from other agencies and states about the new trends in transportation planning and construction; about demographics; and about the state’s financial future. One would expect those things to be part of every engineer’s continuing professional education.

In short, they should agree with our assessment. To sit on the Feasibility and Corridor Protection studies, until 3 years before they want construction to begin, seems senseless. As we have suggested before, it sounds like the Department just wants to complete the right steps along the path to building a GC. They are not interested in periodically evaluating whether to end the project or its corridor protection.

There’s a second issue related to the no-build decision. First of all, the District 8 Engineer, then James Easterly, in effect, turned the county concept into a proposed facility. No study, no consultation. Now, the District now claims a no-build option must come from an EIS! Not only do we think that’s mere rhetoric, but we found no cases where an EIS actually concluded the no build option was the preffered one.

The Galena Bypass study, among others, dismissed the no-build option out of hand—there was no impact analysis or benefit-cost analysis for that option. While other alternatives get discussed in detail, the no-build option does not. The Record of Decision for the Galena study used exactly 42 words to say essentially “not building the road doesn’t meet the need.” (to build the road?)

In all of our meetings with her, Ms. Lamie recalled only one no build decision in District 8, but admitted it did not come pursuant to an EIS: it was cancelled essentially because the Department recognized the futility of the project without a study. We were pleased to learn that actually is an option!

The editor of the Belleville News Democrat wrote in his September 22, 2014 editorial that there’s “No need to study what’s obvious.” We agree! According to the editorial, common sense can be enough. He was referring to spending $29,150 to study the need for a traffic light in front of Lindenwood University in Belleville, but the notion has many applications, including a $500 million highway.
What Regional Vision is the Department Supporting?

There is no stated, or unstated, vision for this region which would call for a new highway. In fact, there is no regional vision, period.

As mentioned in Chapter 3,two SIUE professors reported that what they found in the MetroEast was a disjointed aggregation of taxing entities, competing with each other instead of cooperating to achieve a regional goal of economic progress. As a group, the entities did not have or share a regional view; each one took the parochial view, instead. The authors were generous by saying that changing the condition was “a significant challenge.” If there is any entity that should break through the challenge to impart, and then support, a regional view, it should be the regional transportation expert, that is, the Area 5 Engineer!

Rather than continuing to respond to individual requests from each locality, the Engineer ought to have a broad plan to meet a broad vision. Right now, that vision seems to be to plow ahead with existing plans, regardless of their origin, purpose, or cost. We suggest that’s “followership,” and not leadership, and a waste of the full talents of the office.

The facts and circumstances surrounding the GC strongly suggest that to pursue the project as written would be wasteful and destructive, and provide little benefit to the community at large. It shouldn’t take a study to realize congestion is not a serious problem.

Even closing US40/I-64 for 2 years turned out not to be a problem for St Louis; and adding the Stan Musial-Veterans Bridge did not end the delays in crossing the Mississippi River for Illinois commuters.

Further, the MetroEast is not a boom town, driving is down and is expected to stay down, and there is no call from the public to add more roads to a system that already has more lane-miles per capita than most cities.

The 10-Year Review

Pursuant to 605 ILCS 5/4-510, District 8 must hold one or more public hearings to discuss the viability and feasibility of the GC’s protected corridor. After the discussion, the Department is to give “due consideration” to the information obtained at the hearing(s). What is not clear is what due consideration means. If the actions of departed Area5 Engineer’s are any indication, then it means little. If the remarks of the current Area 5 Engineer to our comments are taken at face value, it means nothing.