CAPPE’s Revised Summary Analysis of Draft Environmental Impact Statement on Pellissippi Parkway Extension


TDOT held the required public hearing on the DEIS on Tuesday, July 20, from 5-8pm at Heritage High School. Now we urge you to write a letter to TDOT—written comments count! More details about what you can do appear on page 8 of this memo. We encourage you to use this memo to prepare your letter to TDOT.


TDOT and advocates of the PPE want to spend up to $100 million of taxpayers dollars to build a high- way that will not improve regional mobility, will not reduce crash incidence, will not address traffic con- gestion, will not improve levels of service on most of our roads, will likely accelerate residential devel- opment that increases costs to the County for providing services like education, will displace families and take active farmland out of production, will substantially increase noise levels in residential neigh- borhoods, and will threaten our waterways and wildlife habitat.


In brief, the DEIS and supporting materials provide the following information:

There is much, much more information in the DEIS and additional technical reports from TDOT. This summary analysis covers:

Part I: Background, including stated Purpose and Need

Part II: The DEIS demonstrates that the “build” alternatives will not fulfill the stated Purpose and Need

Part III: Deficiencies in the DEIS Part IV: Other Concerns

Part V: Conclusion


PART I: BACKGROUND

The Tennessee Department of Transportation (TDOT) and the US Federal Highway Administration (FHWA) issued the Draft Environmental Impact Statement (DEIS) on the proposed Pellissippi Parkway Extension on April 16, 2010. Technical Memoranda that contain data and analyses underlying the descriptions of impacts that ap- pear in the DEIS were not posted on the website, nor were comments from participating agencies.

The National Environmental Policy Act (NEPA) requires preparation of an EIS for any project using federal dollars that is determined to be a major action significantly affecting the quality of the human environment. In the Draft EIS, all reasonable alternatives--including "no action" or "no build"--must be discussed at a comparable level of detail. Purpose, need, and all areas of potential impacts (traffic, environment--air, water, land, wildlife, botanical and aquatic species, geology, economy, historical and archeological resources, community institu- tions) must be addressed through in-depth study. The impact, or lack of impact, must be substantiated by da- ta. The Draft EIS must also address mitigation of all potential impacts.

The EIS also must address indirect and cumulative impacts. These are effects that are expected to be "caused" by the proposed action but are later in time and removed in distance, but are still reasonably fore- seeable. Cumulative impacts are those which result from the incremental consequences of an action when added to other past and reasonably foreseeable actions--such as the Alcoa Parkway and the Southern Loop, both of which are factored into traffic analysis in the DEIS. TDOT initially prepared an Environmental Assessment, which is a much less comprehensive analysis. CAPPE sued TDOT and FHWA in 2002 to ensure that the required EIS would be done.


Official description

The official description of the proposed new highway follows:

The Tennessee Department of Transportation (TDOT), in cooperation with the Federal Highway Adminis- tration (FHWA), is proposing to extend and construct Pellissippi Parkway (State Route (SR) 162) from the current terminus of Pellissippi Parkway/Interstate 140 at SR 33 (Old Knoxville Highway) to US 321/SR 73 (Lamar Alexander Parkway) in Blount County. (DEIS D-1)

Purpose and needs

The DEIS outlines the purpose of the new highway and the needs the new highway is supposed to address: The purpose of the proposed action is to develop and implement a transportation solution in the northern por- tion of Blount County, east of Alcoa and Maryville, that would:

  1. Enhance regional transportation system linkages;

  2. Improve circumferential mobility by providing travel options to the existing radial roadway network in Blount County, Maryville, and Alcoa;

  3. Enhance roadway safety on the roadway network, including the Maryville core; and

  4. Assist in achieving acceptable traffic flows (LOS) on the transportation network or not adversely affect traffic flows on existing transportation network.

    In addition, the proposed transportation solution should support community goals and plans and minimize adverse impacts to neighborhoods and businesses, to farmlands, and to the natural and cultural environ- ment.

    The proposed action is intended to address identified transportation needs in the study area. These needs have been identified during the public and agency coordination activities conducted for the project be- tween April 2006 and February 2008, as well as through prior planning efforts and review of current transpor- tation and community plans. The transportation needs are:

  5. Limited mobility options in Blount County and Maryville due to the primarily radial roadway network that now exists;

  6. Poor local road network with substandard cross sections;

  7. Lack of a northwest/east connection east of Alcoa and Maryville to help serve:

    Expanding residential development occurring in eastern Alcoa and Maryville and northern Blount County; and

    Demand for trips between Maryville and Alcoa and the Knoxville area to the north as shown by high traffic volumes between the areas on US 129 (approximately 50,000 vehicles-per-day) and SR 33 (ap- proximately 6,000 vehicles-per-day).

  8. Safety issues on roadways in the area, including roads in the Maryville core that through travelers be- tween north and western portions of the county and the eastern portions of the county must pass. Numerous rear-end crashes and angle crashes have been reported due to high volumes of traffic and lack of access management along the roadways; and

9. Traffic congestion and poor levels of service on the major arterial roads in the study area (US 129/Alcoa Highway, SR 33, US 411/SR 35 and US 321/SR 73). (DEIS pages S-2 and S-3)


PART II: THE DEIS DEMONSTRATES THAT THE NEW HIGHWAY WILL NOT FULFILL THE STATED PURPOSE AND NEED

In this section, we look at each of the objectives and needs from the official description. The DEIS is supposed to evaluate how well the alternatives under review will fulfill the stated purpose and need. The DEIS states re- peatedly that the “build” alternatives will not improve traffic congestion or levels of service on most of our road network. $60-$100 million is too much to spend for no improvement to traffic congestion and levels of service.

  1. Enhance regional transportation system linkages.

    This is the first and most frequently cited purpose/need.

    (DEIS S-2 to 4, 1-6 to 8, 2-4, 2-6 to 7, 2-10, 2-16 to 17). Despite priority of this purpose/need, the DEIS offers no fur- ther measures to gauge regional linkage by any alternative.

    Throughout the DEIS and the supporting Technical Memoranda, the Alcoa Parkway and the Southern Loop are factored into the traffic analysis. (Traffic Forecast Study, 13) Assuming these two major projects and the PPE were all built, regional transportation linkages may be improved. However, the Alcoa Parkway is not scheduled for construction until 2014 (Traffic Operations Report, 1). The Southern Loop is not scheduled for con- struction until 2025-2034 (DEIS 2-3; Traffic Forecast Study, 13). The DEIS and the Traffic Operations Technical Re- port show failing levels of service beginning in 2029 and increasing through 2035 for much of these new ‘re- gional transportation linkages.’ (DEIS, 3-3)

    The Traffic Operations Technical Report states that by 2035, in the Build (A/C) scenarios, “the existing section [of Pellissippi Parkway] just west of US 129 (Alcoa Highway) and the section between the proposed Re-


    located Alcoa Highway and SR 33 would operate poorly. In addition, the proposed section between SR 33 and US 411 would operate poorly in the future year of 2035.” (Traffic Operations Technical Report, 31.)

    Moreover the DEIS shows that 8 of 12 studied intersections are failing by 2035 whether the PPE is built or not (Fig 3-2, DEIS 3-9). According to the DEIS, only two intersections in the entire study area are improved by Alternative A or C (DEIS 2-10, 3-4; Traffic Operations Report 43), despite improvement being a major project purpose (DEIS S-2, 1-7).

    NEW: TDOT’s presentation at the public hearing included a new map (not published in the DEIS) showing ‘intersection time delays.’ This map was introduced as showing that delay times would improve for only short periods. Percentages of improvement, not minutes or seconds, appeared on the map. We have asked for the data and analysis underlying this new assertion.

    Why would we invest up to $100 million in “enhanced transportation system linkages” if these linkages are going to be failing by the time they are completed?


  2. Improve circumferential mobility by providing travel options to the existing radial roadway network in

    Blount County, Maryville, and Alcoa.

    Circumferential mobility will not be improved if the new “travel

    options” have failing Levels of Service. Adequate circumferential mobility is not defined in the DEIS. The DEIS dismisses Alternative D as an improvement because This route may not be immediately obvious to motorists who are unfamiliar with the area and are trying to travel between SR 33 and US 321/SR 73 east of Maryville and Alcoa.” (DEIS 2-10).

    We think people traveling through Blount County can read maps and follow road signs.


  3. Enhance roadway safety on the roadway network, including the Maryville core.

    The DEIS asserts that

    Alternatives A and C would “address safety concerns along the existing roadway network” by shifting travel from existing roads to the new Pellissippi Parkway Extension (2-10). But neither the DEIS nor the separate Crash Analysis Report Update offers any interpretation of safety data beyond the 2007– 2008 year and comparison to Statewide Critical Crash Rates.

    In fact, the Traffic Operations Report (Table 9) shows that the five most deficient five road seg- ments (out of 24) as identified in the DEIS (1-20, Table 1-3) and in the Crash Analysis Report Update (3, Table 1) would see increased aggregate traffic volume under Alternatives A/C. The DEIS states that for a given segment of roadway, crash exposure is proportionally related to traffic volume (1-18), which means Alternatives A/C would INCREASE (not decrease) the number of crashes on the study area’s five most hazardous road segments.

    Moreover, none of the build alternatives will improve traffic congestion, which contributes to un- safe conditions. According to the Traffic Operations Technical Report, “US 411 has poor traffic opera- tions regardless of scenario. SR 33 has little difference in level of service regardless of scenario, with poor levels of service, particularly for the year 2035.” (Traffic Operations Technical Report, 31.) And eight of twelve studied intersections are failing in no build or build scenarios by 2035 (Fig 3-2, DEIS page 3-9). On- ly two intersections in the entire study area are improved by Alternative A or C (DEIS 2-10; 3-4; TOR 43).

    There are no findings regarding improvement in safety, if any, to the road segments reported as defi- cient. Indeed, Alternatives A/C would INCREASE (not decrease) the number of crashes on the study area’s five most hazardous road segments. This is a classic example of using a symptom to justify an action rather than addressing the cause. TDOT should address factors that cause high crash incidents, not seek a way to by-pass them.


  4. Assist in achieving acceptable traffic flows (LOS) on the transportation network or not adversely af-

    fect traffic flows on existing transportation network.

    The DEIS repeats TDOT’s analysis presented in 2008:

    “Little change is predicted in the level of service of existing roadways between the No-Build and Build Alternatives since the traffic volumes do not change substantially for most roadways among the alter- natives.” (DEIS, 3-3) “Overall, this analysis does not demonstrate that any of the Build Alternatives would substantially improve the level of service for the existing highway network.” (DEIS, 3-4) “Sections of SR 33 and US 411/Sevierville Road would operate at a poor level of service (LOS E or F) regardless of alterna- tive due to existing and projected high traffic volumes on these roadways that exceed the given ca- pacity.” (DEIS, 3-4).

    Improvement of traffic operations at just two intersections does not “substantially meet the purpose and need of the proposed project” (DEIS 2-10) to “assist in achieving acceptable traffic flows on existing transportation network” (DEIS S-2 and 1-7).


    Also on the list of objectives we find: Support community goals and plans, minimize adverse impacts to neighborhoods and businesses, to farmlands, and to the natural and cultural environment. The First Guiding Principle of the Blount County Policies Plan is: “The rural, small town and natural character of the county should be preserved.” The impacts anticipated from the proposed PPE and impacts from the Southern Loop are not consistent with this Principle. Neither is the PPE consistent with the Fourth Guiding Principle: “County roads should be improved and maintained to a level consistent with present development and expected future development.” Other pressing road needs, already identified by our County Road Superintendent and TDOT, should take priority for limited road funds.


    The transportation needs stated in the DEIS are:

  5. Limited mobility options in Blount County and Maryville due to the primarily radial roadway network that now exists

    But if three proposed new road projects (PPE, Alcoa Parkway and Southern Loop) in combination do not divert sufficient traffic to improve congestion on the primary radial network, then mobility options are not improved. What we get is a costly new highway with no change in traffic congestion, because most traffic is not going where the highway goes, with accompanying undesirable impacts on our county budget, farmland, water ways and wildlife.


  6. Poor local road network with substandard cross sections

    The DEIS confirms that Alternatives A and C do not improve the poor local road network or its substandard cross sections. Unimproved and unsafe routes will continue to carry substantial and increasing traffic. As stated in the Traffic Operations Report, “There are numerous roadways in the region that were not designed to accommodate the type and amount of suburban development that is occurring, which leads to unsafe oper- ating conditions.” (3)


  7. Lack of a northwest/east connection east of Alcoa and Maryville to help serve:

    Expanding residential development occurring in eastern Alcoa and Maryville and northern Blount Coun- ty; and

    Demand for trips between Maryville and Alcoa and the Knoxville area to the north as shown by high traffic volumes between the areas on US 129 (approximately 50,000 vehicles-per-day) and SR 33 (ap- proximately 6,000 vehicles-per-day).

    The data in the DEIS show minimal demand for trips from the area that would be served by the PPE.

    License plate analysis reported in the DEIS showed a very small number of vehicles on US 129 and SR 33 may be coming from east Blount County: “Based on the license plate survey, it could be expected that six percent (3,000) of the 50,000 vehicles on US 129 could come from east of Blount County as could two percent (120) of the 6,000 vehicles on SR 33.” (DEIS, 1-10) Moreover, the DEIS states “Traffic operations on US 129 shows minimal difference between the No-Build and Build scenarios, with some improvements in level of service for certain sections and worse levels of service for other sections.” (Traffic Operations Technical Report, 31)


  8. Safety issues on roadways in the area, including roads in the Maryville core that through travelers be- tween north and western portions of the county and the eastern portions of the county must pass.

    image

    Numerous rear-end crashes and angle crashes have been reported due to high volumes of traffic and lack of access management along the roadways

    As noted above, the DEIS does not offer any data showing how Alternatives A, C or D will address safety and crash incidence. What the DEIS does contain are numerous statements that unsafe traffic conditions and congestion will not improve even with the PPE.


  9. Traffic congestion and poor levels of service on the major arterial roads in the study area (US 129/Alcoa Highway, SR 33, US 411/SR 35 and US 321/SR 73)

    As noted above, the DEIS states that traffic congestion and levels of service will not be improved if the PPE and Southern Loop are built.


    PART III: DEFICIENCIES IN THE DEIS

    In addition to demonstrating that the “build” alternatives do not fulfill the stated needs, the DEIS has significant deficiencies with regard to evaluation of impacts.


    Ecology Report


    The methods used in the DEIS and Ecology Report to select species to be evaluated underestimate species to be considered and potential project impacts to threatened and endangered (T&E) species and their habitats. The TDEC, DNA-NHP database website ://state.tn.us/environmental/na/pdf states that re- liance on published databases is inadequate: “The lists provided are intended for use as planning tools. Because many areas of the state have not been searched for rare species, the lists should not be used to determine absence of rare species.” Dr. Lee Barclay, USFWS made the same point to Leigh Ann Trib- ble of FHWA: “we note that DNH records may not be all-inclusive. … this information is seldom based on comprehensive surveys of all potential habitat and does not necessarily provide conclusive evi- dence that protected species are present or absent at a specific locality.” (E-22) Barclay’s reference to aquatic species applies also to terrestrial T&E species.

  10. The Ecology Report describes as ‘wet weather conveyances’ several waterways that are in fact streams containing fish and other aquatic species. Streams are protected under the Clean Water Act, requiring state permits and benefitting from a higher level of monitoring to protect against negative impacts.

  11. The field study of waterways occurred in late September 2008, which is ordinarily a very dry time of year and in 2008 followed a drought. To ensure our waterways are protected from silt, sedimentation, cross- ings, fill and other destructive impacts, a thorough field study with corrected field locations must be done at the appropriate time of year to document waterways and secure required protections. Addi- tional water resources may be identified by thorough environmental impact evaluation.

  12. The Ecology Report states impacts on water will be controlled through “best management practices” (BMPs), which may not be adequate or appropriate for this project due to size, scope, and existing pol- lution. The first storm event during construction often proves BMPs to be inadequate.

  13. Missing from review of impacts on water is analysis of loss of local water resources in exchange for off- site mitigation, such as loss of local wetlands that provide flood storage & protection in the immediate neighborhood, in exchange for mitigation wetlands in another watershed that provides little or no bene- fit to the community or landowners experiencing direct impacts.

  14. Secondary and cumulative impacts on water have not been fully described or considered. Cumulative impacts cause great harm to downstream waters, local environment, and residents.

  15. The Ecology Report misses species (blotchside logperch, tangerine darter, hellbender), new taxonomic status for the duskytail darter and the recent extreme decline of the Little River ashy darter population. A wider review of impacts from sediments from directly impacted tributaries will be necessary.

  16. Agricultural, Forested Communities, Old Fields are listed as land use categories within the alternative corridors. There is no data from Avian Point Counts or Call Count Surveys conducted during appropriate times of the year to obtain qualitative information on resident avian communities and listed species.

  17. The area studied for possible habitat and presence of threatened and endangered (T&E) species was a corridor of 1-4 miles and did not include actual field study. Searching a 1-4 mile radius for T&E species instead of 5, 10 and 15 miles skews downward the number of T&E species to be considered.

  18. Sinkholes are challenges to construction as well as important components of ecosystems and merit more thorough analysis for their role in water and wildlife impacts.

    Indirect and Cumulative Impacts

  19. TDOT committed in its Project Data Summary to complete an EIS that will “consider the indirect impacts resulting from the project that would occur later in time or further removed in distance,” and “those im- pacts may include growth-inducing effects or other effects related to changes in the pattern of land use, population density, or growth rate and related effects on air, water and ecosystems,” and “cumu- lative impacts on the study area’s resources that would result from this project in combination with other past, present and reasonably future actions by public and private entities.”

  20. The DEIS affirms “therefore, the geographic limits for the analysis of indirect and cumulative effects reach beyond the defined project study area” (3-101), but the DEIS doesn’t provide the necessary analysis of the indirect and cumulative impacts of the Southern Loop and the Alcoa Parkway, both of which are factored in the traffic modeling used throughout the DEIS.

    Farmland

    In the evaluation of public works projects involving Federal funding, analysis of impacts on farmland should comply with FPPA and also evaluate the broader implications of the project for conversion of farmland in the area and the future of farming as a land use and economic contributor to the region. The ecosystem values of farmland in addition to agricultural values should be evaluated, such as groundwater recharge, flood retention and wildlife habitat, all of which are lost or severely compromised by development land.

  21. The DEIS acknowledges the potential for indirect impacts on farmland: “Cumulative impacts on farm- land could be substantial, particularly if the local growth policies are not enforced. The proposed future


    transportation projects, coupled with completion of the Pellissippi Place Research and Technology Park, could spur a greater increase in growth than currently anticipated, resulting in increased demand for developable land. This could accelerate the rate of decline in the amount of farmland within and out- side the UGBs.” (3-115ff) There is no quantification of the potential loss of the region’s farmland as a re- sult of the project’s impact on future growth and growth trends. Past practice shows “local growth poli- cies” are unlikely to minimize influence of the highway on the cumulative loss of farmland in the area.

  22. Agriculture in Blount County is a $17.4 million dollar industry as measured by the market value of prod- ucts sold by county farms. This figure does not include secondary economic benefits of local agriculture such as processing, farm supply and equipment sales and on-farm employment.

  23. Recent trends across the country suggest that farming in and around metro areas like Maryville and Al- coa is becoming more viable and has a role to play in food security. The 2007 US Census of Agriculture reports that while Blount County ranks only among all the counties in the state of Tennessee in the Total

    Market Value of Agricultural Products Sold, it ranks

    in the “value of agricultural products sold directly to

    individuals for human consumption.” A May 2010 report issued by the USDA Economic Research Ser- vice, “Local Food Systems: Concepts, Impacts and Issues”, reports that “Production of locally marketed food is more likely to occur on small farms located in or near metropolitan counties” and that specifical- ly farms with less than $50,000 in annual sales are more likely to produce food sold direct to consumers. Ninety-five percent of the farms in Blount County in 2007 were small farms with less than $50,000 in an- nual sales.

  24. The DEIS states “On April 27, 2009, TDOT was advised by NRCS that FPPA of 1981 does not apply to projects within urban growth boundaries.” (Table 4-1, p 4-5). Review of both the FPPA statute (Public Law 97-98, Subtitle I of Title XV, Section 1539-1549) and the FPPA Rule (7 CFR 658) did not uncover any such categorical exception or exemption for projects within designated urban growth boundaries.

  25. The DEIS reports “Total Acres Statewide and Local Important Farmland” for each alternative as 0 (DEIS, A-22), but elsewhere “Alternative A would affect approximately 128 acres of farmlands; most of the land (about 74 percent) within the proposed right-of-way of this alternative is classified as farmland.” DEIS, 3-40). Any acreage recorded for “Statewide and Local Important Farmland” would increase the Land Evaluation Information score on the Rating Form for each alternative.

    Economy

    The Economic and Fiscal Impacts Analysis (EFIA) contains assumptions that render its conclusions suspect:

  26. The DEIS assumes that “when combined with appropriate land use regulations, the recommended transportation improvements need not contribute to urban sprawl.” (DEIS 3-17 and 3-18) But the EFIA acknowledges a different outcome from recent history: “a review of historical building permit trends between 2005 and 2007 suggests that despite the smart growth policies of the County, new residential growth outside municipal boundaries is occurring at a far more rapid pace than within those city limits. .

    . . on average about 75% of new development over the past three years has occurred in the unincorpo- rated portions of Blount County as compared to Alcoa and Maryville.” (EFIA 18)

  27. The EFIA projects induced development to 2020 and assumes that construction would be complete be- tween 2015 and 2017. The full impact of induced development will take longer than 3 years after con- struction to occur. Continued population growth around earlier phases of the Parkway–in some cases, over ten years later–calls into question the projection to 2020. Analysis of the impact of the PPE beyond 2020 would also require consideration of the impacts of the Southern Loop.

  28. Prior phases of Parkway development in Knox County show that new highway construction has an im- pact on residential growth in areas most proximate to the new highway. Knox County Census Tracts at the first two phases of the Parkway experienced a combined growth rate of 79.7% between 1990 and 2010, more than double the growth rate of Blount County Census Tract 109 and more than 1½ times the growth rate over the same period for Blount County Census Tract 110.

  29. The EFIA projects savings in the cost of delivering services, but this assertion is based on an analysis of smart growth savings by the Victoria Transport Policy Institute in Canada. The cited source refers to a 1995 study estimating potential savings from smart growth policies in Greater Toronto. Are potential sav- ings from centralized development in Toronto, Canada applicable to suburbanized development of Blount County, Tennessee? Under the central development option in Toronto, population density is pro- jected at 152 residents per hectare or 61.5 residents per acre. In Blount County, that level of density would translate into a countywide population of 3.6 million people.

  30. Population growth in Blount County over the last decade has not improved County government finan- cial stability based on several different measures: Population growth is outpacing commercial and in- dustrial growth. This is also reflected in changes in land use and assessed property value in the County


    between 2000 and 2008: total assessed value in the County increased by 85.2%, but commercial and industrial assessed value increased by only 66.6%: the commercial/industrial share of total assessed val- ue declined from 21.9% to 19%.

  31. Between FY2000 and FY2009, County employment grew at twice the rate of population growth. County FTEs grew by 29.1% from 1690 in FY2000 to 2181.5 in FY2009. Per capita County expenditures (excluding capital) are up by 43.6% -- more than 1½ times the regional rate of inflation. In FY2000, County spending totaled $93.2 million or $880.68 per resident (based on 2000 population data). In FY2009, County spend- ing totaled $153.6 million or $1,264.18 per resident (based on 2008 Census estimate). By comparison, dur- ing this same period, the regional inflation rate for the South (for urban areas) was 24.3%. Reported County debt has increased from $66.1 million in FY2000 to $219.9 million in FY2009.

  32. All of these measures point to increasing fiscal pressure on the County, as its tax base becomes increa- singly dependent on residential property owners. Growing school enrollment has meant growing cost that has not been matched by growing tax revenues. Overall growth in Blount County employees be- tween FY2000 and FY2009 was in large part the result of a 31.4% increase in employees of the Blount County school system: the increase in County school workers accounted for 76.5% of the net increase in County workers. Part of the increase in the County’s debt is also attributable to enrollment growth: be- tween 1999 and 2009, Blount County schools increased from 16 to 20. Increased residential develop- ment will likely yield growing school enrollment, the need for new capacity and growing cost.

  33. EFIA addresses the issue of declining revenues: “In both development scenarios, property taxes represent the smallest category of net revenues likely to accrue to the County, with the largest contribu- tor being sales tax revenues from the expenditures of new residents and employees. “(3) But sales tax revenues have been unreliable for recurring County expenses, and the commercial development antic- ipated at the new PPE interchanges has been or will be annexed by the cities of Maryville and Alcoa, meaning new sales tax revenues that will not go to the County while education costs due to population growth will continue to be borne by the County.


  1. OTHER CONCERNS

    Noise

    The DEIS documents multiple noise impacts from all three ‘build’ alternatives that will exceed NAC (Noise Ab- atement Criteria) and increase noise levels 10 decibels or more. “The NAC are noise impact thresholds for con- sidering abatement measures.” (3-62). Increases of 10 decibels or more are considered substantial, yet there is no mitigation planned to reduce this disruptive noise impact for residents. (3-66, 3-67) Noise has proven and documented negative impacts on human health, but these impacts receive no mention in the DEIS. Apparent- ly the convenience of tourists and commuters is worth $100 million of taxpayer dollars, but protecting the peace and quiet of local residents’ health and homes doesn’t measure up in TDOT’s cost-benefit analysis.

    Air Quality

    The DEIS says the PPE will not have a negative impact on air quality because EPA's national control programs will reduce emissions, even though the PPE is predicted to increase regional vehicle miles traveled (3-59).

    Other planned road projects

    NEW: TDOT’s comment form describes the ‘no-build’ alternative as no improvements at all, but numerous road projects scheduled are for the area over the next few years that have nothing to do with the PPE. See p. 9 of this memo, which shows planned improvements to Sam Houston Schoolhouse Rd, Peppermint Rd, SR 33 between Hunt Rd and Sam Houston Schoolhouse Rd, and turn lanes at intersections on US411 (from Washington Road to Peppermint Road). (DEIS 2-2)


  2. CONCLUSION

    What do we get for $100 million? An estimated 10 minute reduction in drive time. At $10 million per minute, this is an irresponsible expenditure of public dollars when other urgent road projects in Blount County are not even in the Long Range Plan for improvement. These dollars can be used for other roads in the study area. Let’s apply them where we need them.

    TDOT recently cancelled another proposed new highway, I-475, because it didn’t satisfy stated purpose and need. Neither does the PPE.



    WHAT YOU CAN DO

    We encourage you to write a letter to TDOT. To be part of the public record, comments must be postmarked by Monday, August 30, 2010. You are welcome to use the summary analysis to prepare your letter.

    It is critically important to make your views known to TDOT and to our state representatives.

    Tell them we expect transportation projects to meet community needs, and this one clearly doesn’t. There are other urgent road projects in our community that are not being addressed.

    Comments to TDOT must be postmarked by August 30, 2010.

    Send your letter via US mail to:

    Tennessee Department of Transportation -- Project Comments Suite 700, James K. Polk Building

    505 Deaderick Street

    Nashville, TN 37243-0332

    Send a copy of your letter to TDOT to the Governor and to Blount County’s state legislators. Their names and addresses appear below.

    Don’t use TDOT’s comment form – it misrepresents the No Build Alternative and omits Economic Impacts.

    Send a copy of your letter to TDOT to CAPPE at PO Box 494, Alcoa, TN 37701 or

    Send a letter to the Editor of the Daily Times (address below)

    What else can I do?

     


Governor Phil Bredesen Governor's Office Tennessee State Capitol Nashville, TN 37243-0001


State Representative Robert Ramsey Suite 207 War Memorial Bldg

2120 Middlewood Drive Nashville TN 37243

Maryville, TN 37803 Phone: (615) 741-3560 Fax: (615) 253-0376

.bob.ramsey@capitol.tn.gov


State Representative Joe McCord 214 War Memorial Building

4504 Montvale Road Nashville, TN 37243-0108

Maryville, TN 37803 Phone (615) 741-5481 Fax (615) 253-0212

(865) 984-5881 800 449 8366, ext. 15481

.joe.mccord@legislature.state.tn.us


Senator Doug Overbey Suite 4 Legislative Plaza

1105 N. Heritage Drive Nashville, TN 37243

Maryville, TN 37803 Phone: (615) 741-0981

(865) 681-8236 sen.doug.overbey@capitol.tn.gov


Editor, The Daily Times OR Editor, The Daily Times

307 E. Harper Ave. P. O. Box 9740

Maryville, TN 37804 Maryville TN 37802-9740

Planned road improvements (DEIS p 2-2; source: Knoxville Regional Mobility Plan 2009–2034)


200 (47) Cusick Rd.

Alcoa Hwy. to Pellissippi Pkwy.

Add center turn lane

2009-2014

204 (612) Pellissippi Place Access Rd.

Connects SR 33 to Wild- wood Rd. thru Pellissippi Place

Construct new 2-or 4-lane road with center turn lane


2009-2014

209 (97) Ellejoy Rd.

River Rd. to Jefferson Hol- low Rd.

Reconstruct 2-lane section

2009-2014

212 (66) Old Knoxville Hwy. (SR

33)

Wildwood Rd. to McArthur Rd.

Reconstruct 2-lane section

2009-2014

203 (NA) Old Knoxville Hwy. (SR 33)

Hunt Rd. (SR 335) to Pellis- sippi Parkway

Widen 2-lane to 4-lane with center turn lane

2009-2014

214 (NA) US 411 (Sevierville Rd.)

Washington St. (SR 35) to Everett High Rd.

Construct 2-lane road with center turn lane along ex- isting and new alignment

2009-2014

217 (41) Alcoa Hwy. (SR 115)

Singleton Station Rd. to Hunt Rd. (upon completion of Alcoa Highway Bypass)

Improve intersections in- cluding turn lanes & traffic signals

2015-2024

237 (74) SR 33 – Broadway Ave.

Intersection at Brown School Rd.

Realign & install traffic signal

2009-2014

231 (149) Old Knoxville Hwy.

(SR 33)

Pellissippi Pkwy. to Knox County line

Reconstruct 2-lane section

2015-2024

234 (160) Wildwood Rd.

Maryville city limits to US 411 (Sevierville Rd.)

Reconstruct 2-lane section

2015-2024

236 (NA) Brown School Rd.

E Broadway Ave (SR 33) to US 411 (Sevierville Rd.)

Reconstruct 2-lane section

2015-2024

242 (162) W Broadway Ave. (SR

33)

Old Niles Ferry Rd. to US 312 (SR 73)

Add center turn lane

2015-2024

244 (152) Peppermint Rd.

Wildwood Rd. to (Sevier- ville Rd.)

Reconstruct 2-lane section

2015-2024

245 (NA) US 411 (Sevierville Rd.)

Dogwood Rd. to Pepper- mint Rd.

Add center turn lane

2015-2024

247 (153) Sam Houston School Rd.

Old Knoxville Hwy. to Wildwood Rd.

Add center turn lane

2025-2034

250 (123a) US 411 (Sevierville Rd.)

Peppermint Rd. to Chapman Hwy. (US 441/SR 71)

Reconstruct 2-lane section

2025-2034

254 (609) Corridor #7 – Southern Loop Connector

US 321/SR 73 @ proposed Pellissippi Pkwy. (SR 162) extension to Old Niles Ferry Rd. @ proposed Wm Blount Dr. (SR 335) extension

Construct 2 lane road along existing and new alignment

2025-2034

257 (84) Alcoa Hwy. Bypass (Re- located Alcoa Hwy.)

From Proposed Interchange at McGhee Tyson Airport to Pellissippi Pkwy.

Construct new 8-lane freeway (6 thru lanes plus 2 auxiliary lanes)

2015-2024

258 (84) Alcoa Hwy. Bypass (Re- located Alcoa Hwy.)

From Pellissippi Pkwy. to Near Singleton Station Road

Construct new 8-lane freeway (6 thru lanes plus 2 auxiliary lanes)

2015-2024


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Source: DEIS p 3-15