Action Alert: Ask Council to Support Full Environmental Impact Statement (EIS) for Brent Spence Project
Message city council and encourage them to submit comments to the Ohio Department of Transportation (ODOT), advocating for a full Environmental Impact Statement (EIS) for the Brent Spence Project.
Considering the outdated assessment from 2012, unfulfilled traffic projections, updated environmental data, and concerns highlighted by the EPA regarding air quality and social disparities, it is imperative that a thorough EIS be conducted. This will allow for a reassessment of the widening of the Brent Spence Corridor impacts in light of these significant changes and concerns.
The form below will send your comments directly to city council – below the submission form we also have more information summarizing the deficiencies in ODOT’s process. (in short: 1. Inadequate Consideration of Environmental and Health Impacts 2. Failure to Consider or Mitigate Impacts on Minority Communities 3. Exclusion of Reasonable Alternatives Such as Transit 4. Neglect of Induced Travel Demand and Potential Mitigation Strategies 5. ODOT is operating on an environmental study that is 12 years old for a $3.6 billion project!).
Please submit the form above with your own comments to city council prior to March 8, 2024. Make sure to ask them to submit their public comment to ODOT requesting a full EIS followed by your own personal reasons why you want ODOT to thoroughly investigate all alternatives, be it related to air pollution, induced demand, climate change, lack of consideration for transit, or general skepticism of ODOT & KYTC.
Below is a summary of the SEA analysis with a link to the full analysis below.
The Federal Highway Administration determined back in August of 2012 that the then preferred alternative would have no significant impact on the human or natural environment. Almost a dozen years have passed since then, and much has changed over that time. The projected increases in traffic volume that were used then to justify the need for adding a new 10-lane bridge across the Ohio River have not occurred. The combination of the covid epidemic and the widespread adoption of video technology for working virtually has reduced commuting traffic volumes. Scientific knowledge and understanding of the impacts of greenhouse gas emissions has advanced, as has recognition of the need to reduce such emissions in order to limit the magnitude of the enormous risks and harms resulting from climate change. Federal policies to address racial and ethnic inequity and disparities, including environmental injustice, have been strengthened. Moreover, the currently preferred alternative has changed in numerous ways from what was evaluated in 2012.
About a year ago, the Environmental Protection Agency on February 15, 2023, raised a number of serious concerns over a preliminary draft of the Supplemental Environmental Assessment.
While the Supplemental Environmental Assessment addresses some of these issues, it totally misses the mark on some, and it is incomplete, insufficient or misleading as to others. It cannot support a Finding of No Significant Impacts (FONSI). Reasonable alternatives were not considered, a number of important impacts were not considered at all, others were inadequately considered, and some of the impacts of the project that were identified are not to be mitigated. As a result, an EIS must be prepared.
ODOT is obligated to take affirmative action to mitigate prior discriminatory harms
The SEA erroneously discounts the project’s harms to nearby minority residents
Census Data Documents the Racial Segregation
The EPA’s EJA Screening Tool Documents Already Existing Harms
Failure to include a reasonable alternative which included investments in and expansion of public transit as a means of reducing the amount of highway expansion
The SEA inadequately addresses air pollution impacts of the project.
EPA has issued more stringent air quality standards for particulate pollution, in order to protect public health.
Noise Impacts
The SEA Fails to Adequately Address Greenhouse Gas Emissions and Climate Change
Failure to reasonably assess induced travel demand.
The failure to consider tolling to reduce congestion and eliminate/reduce the need for adding lanes.
