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Enviro-Mich message from WMEACJENNY@aol.com


For Immediate Release
April 7, 1999

Contact: Tom Leonard   Tom Cary
  616-451-3051   616-451-3051


Citing a review of the comments on the Draft Environmental Impact Statement ( 
DEIS ) for alternatives for rebuilding US - 31,  West Michigan Environmental 
Action Council called for Alternative F, the rural bypass alternative, to be 
dropped from consideration because of the environmental damage that would 

In addition to conducting its own internal review of the US-31 project 
proposals, WMEAC reviewed the responses to the DEIS submitted by Federal and 
State agencies with responsibility for commenting on environmental impacts of 
transportation projects.  Several of the agencies, especially those with 
charges to protect natural resources, identify concerns that are 
environmentally critical.  Some of the agencies also voice concerns with the 
lack of sufficient detail within the DEIS to support appropriate 

The following agencies' comments were reviewed:
x Advisory Council of Historic Preservation
x Department of the Army
x U.S. Department of Agriculture
x U.S. Department of Interior
x U.S. Department of Human Services
x U.S. Environmental Protection Agency
x Michigan Department of Environmental Quality

Environmental concerns cited in the comments include but are not limited to, 
the following factors:

x Destruction of  farmland, including prime and unique farmland, and wetland 
acreage is greater under Alternative F than any of the other alternatives.  
At least 90 acres of wetland and 1900-2100 acres of farmland would be 
directly eliminated under Alternatives F or F/J1.
x Secondary effects on farm and wetland acreages  in the area of the 120th 
avenue corridor were not much explored in the DEIS but are anticipated to be 

Deleterious impacts on the Pigeon River, a state-designated trout stream, are 
anticipated to be great and unacceptable.  Alternative F calls for a crossing 
of the Pigeon at its wetland sources, where the Pigeon is most sensitive to 
damage from soil erosion and polluted runoff.    
Said Thomas Leonard, WMEAC Executive Director:  " Expressway construction 
accelerates development and does not eliminate congestion.  It artificially 
encourages urban sprawl by selecting undeveloped lands for new development, 
while drawing traffic away from  previously-developed areas.
 "In contrast, demand management strategies that focus on reducing current 
and projected demand can be used successfully to regulate growth, protect the 
environment, and reduce costs.  Alternative solutions can include local road 
and bridge improvements and repairs, comprehensive bicycle planning, 
pedestrianization, and public transit.
 " The general thrust of these comments is to confirm that the US 31 rural 
bypass alternative will have significant and unacceptable impacts on our 
landscape, waters, and quality of life.  Because there are feasible and 
prudent alternatives to these outcomes, the rural bypass alternative should 
be discarded."

Review of Federal and State Agency Responses to the US 31 Draft Environmental 
Impact Statement (DEIS)

The responses from the following agencies were reviewed:

 * Advisory Council of Historic Preservation
 * Department of the Army
 * U.S. Department of Agriculture
 * U.S. Department of the Interior
 * U.S. Department of Human Services
 * U.S. Environmental Protection Agency
 * Michigan Department of Environmental Quality

EPA  ( January 21, 1999 )

The EPA letter did not concur that more detailed analysis of the remaining 
alternatives presented in the DEIS should go forward at all. They felt that 
there has not been a sufficient statement of need. The EPA points to the fact 
that the purpose and needs statement identifies that 1) the existing 
alignment needs to be "rebuilt" and improved, 2) that "capacity must be 
increased" or 3) "demand must be decreased." While 1) is specific for the 
existing alignment, 2) and 3) provide little guidance for selecting the best 
alternative, or judging whether the present slate of alternatives is 
sufficient.  Thus, the need and purpose are unclear.

EPA feels that it does not meet the substantive requirements to protect 
wetlands and other special aquatic sites. They feel that demand management 
and creative transit/intermodal alternatives have not been sufficiently 
developed and strongly suggest these be further explored. The EPA deems the 
impacts of the non-TSM alternatives on the wetlands significant and 
unacceptable unless more compelling LEDPA arguments are presented. The EPA 
feels intelligent transportation systems, intermodal/ multimodal 
transportation and combinations of transit and build alternatives are 
underrepresented in the DEIS. The EPA feels that without sufficient detailed 
analysis of less impacting alternatives and the cumulative impacts (past, 
present, and future regional impacts from human activities), there is not 
sufficient information for a sound selection of the alternatives.
In fact, without further detailed explanations and attempts to justify 
non-TSM approaches, EPA would rule out all alternatives aside from TSM or 
highway (existing route) build in combination with intermodal transportation 
and intelligent transportation systems, on the basis that that there are 
practicable alternatives that satisfy the need (acceptable Level of Service) 
of the project while having minimal impact on the aquatic environment.

Department of the Interior  ( January 15, 1999 )

The DOI feels the proposed freeway and alignment alternatives addressed in 
the DEIS would have considerable, unacceptable environmental impacts on 
wetlands, uplands, and other fish and wildlife habitats. The DOI remains 
unconvinced that the alternatives presented in their current form, avoid or 
minimize environmental impacts to the extent practicable, as is required. The 
DEIS lacks a thorough analysis of low impact, low capital improvement 
possibilities that would address level of service, traffic congestion and 
accident rates. Therefore the DOI is unable to concur that the alternatives 
as presented should be advanced for more detailed analysis. In addition the 
DEIS lacks sufficient wetlands mitigation plan that is comprehensive and 
includes commitments as was requested by FWS in Lansing in 1994. The DEIS 
lacks a comparison of wetland functions and values among built alternatives 
and as such inhibits the ability to adequately compare these impacts based on 
quality of wetland destroyed. 

Department of Health and Human Services  ( January 8, 1999 )

The DHHS felt that the lack of a preferred alternative made them unable to 
determine the current thinking and thus how to respond to the project..

The US Department of Agriculture ( November 12, 1998 )

The USDA is opposed to any alternatives east of the present alignment of US 
31 due to immediate and secondary development impacts on prime and unique 
farmlands. The USDA supports alternative A.

The Advisory Council on Historic Preservation ( January 21, 1999 )

The ACHP identifies a public participation failure in the DEIS in that it 
does not clearly state that the FHWA should afford persons an opportunity to 
participate in the consultation on ways to avoid, minimize or mitigate 
adverse affects.  The ACHP feels that there is a lack of information with 
regards to the area of effect assigned to the project, such that it can be 
judged for adequacy. For instance, the Boer Farm which is eligible for 
listing on the National Register of Historic Places was not scrutinized by 
"visual, audible or atmospheric elements that are out of character with the 
property or alter its setting" but was found to be unaffected by US 31 
alternatives in the DEIS.

Department of the Army  ( February 1, 1999 )

The DOA has also not announced concurrence with the request to advance the 
alternatives forward. The DOA is most concerned with the wetland impacts, 
their mitigation and the future of mitigated sites, but also about how 
alternatives emerge and are being selected. The DOA does not feel that 
cumulative impacts  have been thoroughly investigated and analyzed. The DOA 
feels that the wetlands loss seems very high for the length under study.

The DOA feels that consideration of a freeway boulevard hybrid is needed. The 
DOA suggests this noting that the net benefit of the bypass at Grand Haven is 
only a 17,400 car per day reduction, while the costs are $22 million per mile 
and extensive disturbance to wetlands, state game areas, and riparian zones. 
The DOA also questions how the elimination of the eight lane boulevard took 
place, noting only the comment in the DEIS  "eight lane boulevards are not 

The DOA indicates a feeling of less wetland of higher quality will be at risk 
along the existing alignment than by alternatives due to the secondary 
impacts (such as along the 120th corridor) that could result in cumulative 
impacts to wetlands and farmland. The DOA also feels that wetland impacts for 
the bypass options will likely be greater than those stated due to bridge and 
pier development and access. The DOA supports the elimination of alternative 
F due to the impacts it would have on the high quality wetland complex of the 
Pigeon River watershed and minimal benefit.   

With regards to wetland mitigation the DOA feels the DEIS is insufficient in 
locating likely potential mitigation sites in the Grand River watershed, and 
in fact feels that if dredging and filling of the Grand River is performed,  
enough sites may not be available to meet mitigation requirements. The DOA 
feels that the DEIS lacks a wetlands mitigation plan that includes clearly 
stated objectives, criteria for judging success, and provisions for failure 
correction as well as how areas will be preserved in perpetuity.  

The Michigan Department of Environmental Quality  ( January 11, 1999 )

The DEQ concurs with the recommendation of the DEIS to advance the selected 
alternatives forward for more detailed analysis. However, the DEQ opposes 
those alternatives which would impact the Pigeon River area due to the 
criticality of the natural resource and the availability of feasible and 
prudent alternatives. The DEQ feels the DEIS provides insufficient detail 
about the number and impacts of stream crossings, noting that details only 
exist for the Grand River, the Pigeon River and Macatawa River, excluding 
needed information on smaller but valuable watersheds. The DEQ feels that 
without this information on the cumulative impacts on these smaller streams, 
it is not possible to determine the environmental consequences the proposed 
alternatives may have on aquatic resources. 

The DEQ also feels the DEIS lacks a thorough analysis and therefore 
mitigation proposals for the long term impacts of hydraulic loading, dredging 
and bridge construction. The DEQ also feels that the focus of wetland 
mitigation is improper and needs to be shifted from downstream portions of 
the Pigeon and Macatawa watersheds (below 120th) to upstream in their 
headwaters. The DEQ feels that an insufficient number of wetland mitigation 
sites on the Grand River have been identified.

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