Restoring and protecting the Cahaba River watershed and its rich diversity of life

CRS POSITION REGARDING NORTHERN BELTLINE

IN THE REGION’S TRANSPORTATION FUNDING PLAN

August 21, 2007

            The Cahaba River Society (CRS) submitted the following comments to the Metropolitan Planning Organization and ALDOT concerning proposed funding for the Northern Beltline within the proposed FY 2008-2011 Transportation Improvement Program (TIP). The Southern Environmental Law Center (SELC) also submitted more detailed comments on behalf of CRS, Alabama Rivers Alliance, Black Warrior Riverkeeper, Conservation Alabama Foundation, and Friends of the Locust Fork River, which follow.

CRS believes it is premature to fast-track those sections of the Northern Beltline east of I-65 and include them in the TIP for right of way acquisition and other projects within the next four years, because the Alabama Department of Transportation (ALDOT) has not completed essential work with the community to ensure that these segments of the project will conserve our water resources and are in the entire region’s best interest. We asked that these segments be removed from the TIP to give time for adequate and meaningful environmental review, incorporation of highway design to conserve water resources, and full evaluation of the best way to invest limited resources to promote growth that will equitably benefit the region. However, the TIP was approved by the MPO with the beltline funding included.

CRS has offered our assistance to ALDOT over the past several years to determine the best way to invest in transportation improvements for regional growth that will also conserve our water resources and drinking water supply, and we stand ready to continue that conversation with all parties.

CRS recognizes that the communities of our watershed and the larger metro area desire the benefits of growth. CRS supports economic growth in the region that is environmentally sound, equitable, and cost efficient.  For the past several years we have therefore tried to work with ALDOT with an aim to influence the Northern Beltline design and environmental review process, to ensure that the information is available that is needed to make wise decisions and to enhance the conservation of our watersheds to benefit the region as a whole.

For instance, we have met with ALDOT officials several times to recommend ways to design and manage the project that would greatly reduce the construction impacts and long term impacts of the interstate that would otherwise harm water quality and negatively impact our drinking water supply. We have also successfully urged ALDOT to undertake an updated and more thorough environmental review of the project as required by federal law.

However, ALDOT has not completed these essential environmental studies and has not addressed the need to incorporate low impact development design in the beltline, which, if taken seriously, have the potential to alter the right of way required for the project.

In addition, there is substantial public opposition in the communities of the Cahaba watershed segments of the proposed beltline, in large part due to the fact that these same issues are unresolved.  It is premature to proceed with right of way acquisition until these essential issues are addressed with full community participation.

Environmental Review Must Be Completed

If funding for the Beltline stays in the TIP, the proposed projects are inappropriately focused on fast-tracking the segments of the Northern Beltline in the most environmentally-sensitive areas of the planned route: the upper Cahaba watershed and biologically valuable streams of the Black Warrior watershed east of I-65. These river basins serve as valuable freshwater habitat of global significance, are sources of recreation and beauty that add great value to the quality of life of the region’s residents, and are the primary drinking water supply for the people of Birmingham and the metro area – about one fourth of the people of Alabama. 

Note that the Environmental Protection Agency stated during the initial environmental review process that the route chosen in these segments was the most environmentally-damaging of the potential routes. The initial environmental review documents are outdated and did not consider essential factors, such as impact to our drinking water source, or the cumulative or indirect (development-inducing) impacts of the Beltline. In addition, the Cahaba’s water quality and quantity conditions have worsened in that time in part due to growth that has occurred without special design methods to conserve water resources. Other deficiencies of the original EIS are outlined in the SELC letter.  ALDOT has not yet completed federally-required environmental studies for the Northern Beltline, yet the agency is making substantive decisions to move forward with road design and land acquisition as if the outcome of the studies will not matter. The federal environmental review process does not allow this.

Thus it is critically important to take the time to complete full environmental studies, which should provide new information, and allow public review and involvement in those studies, to determine the best way to proceed and also conserve the Cahaba River.

Improved Design of Beltline and Associated Development Essential to Protect Water Resources

CRS and others have provided the project design team and ALDOT officials many proposals for improving the construction best management practices and design of the roadway to reduce the potential short term and long term negative impacts to water quality and water supply. Thus far the agency’s proposed design for the first Cahaba segment has not incorporated any of these proposals.

Proper implementation of adequate construction and post-construction controls could affect the precise location and the width of the construction zone, and thus the right of way, of the beltline. Right of way purchase should not proceed until ALDOT adequately addresses these design issues that are crucial to the future health of our water resources.

The communities planning to grow around the Beltline also need to incorporate these same low impact design innovations and improved storm water control into their local planning, zoning and development review in order to maintain the river systems that we rely on for drinking water, recreation, and other uses. CRS promotes feasible, affordable methods to design growth to conserve our water resources.

CRS stands ready to work with ALDOT and with communities along the Beltline route to design the highway and associated development in ways to avoid damage to our water resources.  More information about potential ways to accomplish this is outlined in the SELC comment letter.

Economic Questions Concerning Wider Regional Benefit

Crucial questions also need to answered about the best uses of limited funds for the region’s transportation needs and for economic growth that would equitably benefit the region as a whole.  We ask the MPO and ALDOT to take a more holistic look at transportation alternatives, such as improved regional transit, that will support the revitalization of existing developed areas to meet more of our region’s growth needs. This could provide more cost-effective long-term benefits to the entire Birmingham metro area.

Conclusion