Reviewing and Commenting on the DEIS

Prepared by the University of Pittsburgh Environmental Law Clinic on behalf of its client, Citizens for Alternatives to New Toll Roads (CANTR)

YOUR CONCERNS SHOULD BE VOICED

The Federal Highway Administration has now released its draft environmental impact statement (DEIS) for the segment of the proposed Mon/Fayette Turnpike from Route 51 to Pittsburgh and Monroeville. It is a very long and slightly intimidating document, but reviewing and commenting on it is CRUCIAL if you have concerns about this very expensive proposed turnpike.

The law that required the Federal Highway Administration to prepare this DEIS, the National Environmental Protection Act (NEPA), also requires them to consider, report, and respond to the public’s comments. THIS IS YOUR CHANCE TO BE HEARD.

The Federal Highway Administration is only giving the public until September 9, 2002 to respond to the DEIS. This is not enough time for the average person to review this very long document and any supporting materials. The first thing you should do is contact the Federal Highway Administration and ask for more time to comment. You can write to them at this address:
James A. Cheatham
Division Administrator
U.S. Department of Transportation
Federal Highway Administration, Pennsylvania Division
228 Walnut St., Rm. 508
Harrisburg, PA 17101-1720

After you do that you can start reviewing the DEIS. Here are some guidelines regarding what you should be looking for when you read the DEIS.

THE DEIS IS NOT COMPLETE

The first thing you should be aware of when reading the DEIS is that it is not, in fact, the whole story. Be sure to read the first two pages of the section entitled “preface” which tells you that the DEIS is, in many respects, a summary of eleven other documents that are not part of the DEIS’s five volumes. The preface says you can review these documents at the Pennsylvania Turnpike Commission’s office in New Stanton, but you, as an interested member of the public, are in fact entitled to receive copies of these documents. Call the number set forth in the preface (724-755-5123) and ask for your copies and ask that the comment period be extended until the public has received the complete DEIS.

GENERAL ISSUES

The most important thing to use when reading the DEIS is your COMMON SENSE. It is often the most valuable tool you have to evaluate the numerous claims and assertions that you will be reading. If something does not make sense to you, seems to defy logic, or seems to be based on an incorrect assumption, that is a valid basis for a comment or criticism of the DEIS. This is especially true when you review a part of the DEIS concerning the effects in your neighborhood or another area with which you are very familiar. You know a lot more about your neighborhood than the folks who prepared the DEIS. Let them know that.

The law requires the Federal Highway Administration to support and document their statements, assertions and conclusions about the impacts of this proposed turnpike. The fact that DEIS says something does not, in itself, make that statement true. Look at what the DEIS cites, if it cites anything, in support of its assertions, especially when it is claiming no or minimal impacts. All too often you will find that the DEIS cites nothing or cites to something which is not readily available to you. Include these omissions in your comment.

IMPACTS OF THE PROPOSAL

The DEIS should identify and discuss all reasonably foreseeable environmental impacts from the proposed turnpike. “Environmental Impacts” means more than just impacts to trees or streams. It also means impacts on the communities, neighborhoods and your quality of life. Impacts include both direct and indirect effects of the proposed turnpike. For example, if a proposed interchange could cause additional traffic on nearby streets, that traffic is an indirect impact that should be addressed. The DEIS also must address cumulative impacts. Cumulative impacts are the total effects of this proposal and other past, present or future projects in the area. For example, with regard to Homestead, the DEIS should address the cumulative impacts of the proposed turnpike and the ongoing Waterfront development on that neighborhood.

ALTERNATIVES

The Federal Highway Administration is required to consider a reasonable range of alternatives to its proposal. The DEIS only considers in detail two alternatives for the turnpike and a “no-action” alternative. Ask yourself if this is a “reasonable range” of alternatives when the government is considering spending hundreds of millions of dollars. Ask whether building a turnpike is really the ONLY reasonable alternative. Supposedly the Federal Highway Administration considered other alternatives about six years ago. Those alternatives are discussed in one of the documents that is not part of this DEIS. Were you aware of this? Does the DEIS make the case for why this six-year old analysis is valid? Why aren’t these alternatives and others addressed in the DEIS itself?

ENVIRONMENTAL JUSTICE

The Federal Highway Administration is required to address whether and how the proposed turnpike will impact low income and minority communities. The DEIS favors building the turnpike on the North Shore of the Mon River, which will impact more low income and minority neighborhoods than would the South Shore alternative. It cites the cost of the South Shore alternative as a significant reason for favoring the North Shore alternative. The DEIS finds that the South Shore businesses have considerable value. But does the DEIS put any value on the green spaces and neighborhood communities on the North Shore? Examine this analysis in the DEIS closely. Do you agree with its conclusions? Are these conclusions supported?

PREPARING YOUR COMMENTS

Be sure to put your comments in writing and make them as specific as possible. If there is a relevant published article or unpublished study that was not included in the DEIS cite to it specifically and, if possible, attach a copy to your comments. As of today, you must submit your comments by September 9, 2002 to:
Pennsylvania Turnpike Commission
PO Box 67676
Harrisburg, PA 17106-7676
Attn: David P. Willis, Environmental Manager

**If you have any questions about how to review and comment on the DEIS, contact the University of Pittsburgh Environmental Law Clinic: 412-648-1300.**

If you would like to join CANTR or receive more information about why they oppose this proposal contact:
Citizens for Alternatives to New Toll Roads (CANTR)
PO Box 8171
Pittsburgh, PA 15217
412-384-0378

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