BLOGExclusive: EPA Concerns Over US DRIC Draft Environmental Impact Statement

Let me be direct about it. Who is going to be the sacrificial lamb? Who is going to take the hit for the team? Who is going to have to stand up and be slammed by furious Michigan legislators for hours upon hours at the hearings about how MDOT handled, or perhaps mishandled, the DRIC study.

Who will tell Senator Cropsey and his colleagues that DRIC did not dot all the I's and did not cross all the T's!

$34 million spent already, teams of experts retained and there are EPA "concerns" to the work that was done. Senator Cropsey and his colleagues will be apoplectic if his Press Release is anything to go by. If the Senator has concerns now about MDOT and the way it performed its function, then just wait!

Talk about "abysmal track record," if the Senator wants to see a "public sector boondoggle," then all he needs to do is read on in this BLOG. Never mind having faith in their ability to plan and design another international border crossing, what about their ability to complete the Environmental Impact Statement properly in the first place.

If DRIC's actions forced Michigan to keep on spending money so as not to have to pay back cash to the Federal Government if the DRIC project was completely killed before completion, how much more money will DRIC force Michigan to pay to correct their mistakes?

Let me tell you exactly what I'm talking about. Here is what the US Environmental Protection Agency wrote to the US Federal Highway Administration about the DRIC Draft Environmental Impact Statement. They gave an EC-2 rating, something DRIC probably did not want or need at this time when the hearings in Michigan are going to take place soon:

The SUMMARY OF EPA RATING DEFINITIONS states:

• "EC" (Environmental Concerns)
  
  The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact. EPA would like to work with the lead agency to reduce these impacts.

The ADEQUACY OF THE IMPACT STATEMENT states:

• "Category 2" (Insufficient Information)
  
  The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action. The identified additional information, data, analyses, or discussion should be included in the final EIS.

I expect that the EPA concerns and inadequacies will probably be corrected by DRIC in due course or the project is completely dead. But at what cost and during which time period. How much more will the DRIC people need to come back to the taxpayers to pay in Michigan? I am certain that Senator Cropsey will not be thrilled with the fact that MDOT had previously underestimated costs. For example, he identified that the second Blue Water Bridge span project was 60% over budget.

The EPA is obviously concerned since the DRIC project has the potential to adversely impact air quality in Detroit. The problem that they have with the report is that no preferred location has been chosen yet under the Draft Statement. There are a number of tests and analyses that have to be taken for particulate matter but have not yet been completed.

I wonder as well if EPA understood that, unlike the Enhancement Project which is a replacement of the existing bridge, the DRIC bridge to be financially successful must bring new traffic from other border crossing locations including from Sarnia/Port Huron to the Detroit area. In other words, it has to add a substantial amount of traffic so that there will be enough in tolls to pay for the cost of construction and operation.

While tests were undertaken, there needed to be

• "a more focused discussion about how the project will actually affect traffic levels in specific locations."
• The ozone standards are being revised.
• "the Michigan Department of Environmental Quality will have to include air emissions related to the DRIC projects in the associated state implementation plans."
• EPA "believes that more could be done to quantify local air impacts, especially where higher concentrations of diesel emissions are expected."
• While the DEIS provided toxicity information, the emphasis was on cancer concerns not respiratory concerns. Accordingly EPA "recommends including health endpoints other than cancer be included in the description of toxicological endpoints."
• The EPA pointed out that the DRIC project is close to Detroit Public Schools and an early childhood Center. Accordingly there is a need for greater prominence for studies in the Final Statement on population studies of people who are exposed to traffic air pollution.
  
  "These studies establish a presumptive public health problem with populations near major transportation infrastructure, and as such, the Environmental Impact Statement should include an analysis of a broader range of mitigation options."

There was a concern with respect to mitigation for air quality impacts

• "Construction emissions may represent a substantial source of PM 2.5 tmissions... We recommend that FHWA and MDOT undertake an analysis of construction mitigation options and commit to them to the extent possible."
• "General mitigation approaches for anti-idling during operations are only briefly touched upon."
• "We recommend that FHWA and MDOT undertake an analysis of mitigation options for both construction and operations."

The point of all of this is that DRIC has not done its job properly. It will force delays in time and extra costs to be incurred. How much of each I have no idea, but Senator Cropsey needs to find that out at his hearings.

In fact, the Senator has a lot of matters that he needs to look into in his hearings. It will be fascinating to learn what he and his colleagues uncover.

And who is left standing at MDOT.