Cal Markert, P.E.

Baldwin County Engineer

P.O. Box 220

Silverhill, AL 36576

 

RE: Baldwin Beach Express From I-10 to I-65

 

Dear Mr. Markert,

 

We are Mobile Baykeeper, a twelve year old nonprofit organization with the mission of providing citizens a means to protect the beauty, health and heritage of the Mobile Bay watershed. We are writing on behalf our Board, Officers and more than 3,500 members to address the Baldwin County Highway Department’s corridor study to select a route for an I-65/I-10 Connector. This is a major undertaking that requires very close scrutiny from both your department and the community at large. 

 

A significant issue that should be considered in the construction of such a road is a major investment by the State of Alabama's Forever Wild Program, The Nature Conservancy and other conservation groups in 19,000 acres of native Alabama forest habitat along the Perdido River. This investment was made to preserve and restore one of the last areas in Baldwin County with potential to support a fully functioning longleaf forest ecosystem. Conservation groups deliberately focused their moneys and efforts in a section of the county relatively free of development and roadway impacts. More purchases have been planned to expand this conservation area into a 30,000 to 50,000 preserve that would be adequate to preserve all of the longleaf ecosystem components into the 21st century.

This investment could be threatened in multiple ways. Even small alterations to runoff as a result of road construction can severely impact the area's complex small-stream and sheet flow hydrology, which feeds the rare bog ecosystems on properties immediately adjacent to the easternmost route. Collection of multiple small streams and sheetflow in culverts can severely impact the health of acres of downstream wetlands.

In Alternative 2, the easternmost Baldwin County corridor, at least 24 stream crossings are evident, with an estimated 150 acres of wetlands requiring fill to construct the road. Alternative 1, proposes eight stream crossings on the dry ridge that underlies the westernmost corridor, with 99 acres of wetlands to be filled.
 

Prescribed fire management is essential to the restoration and maintenance of all aspects of the longleaf pine ecosystem, and numerous studies have shown that such forest systems do not survive without frequent fires, with a typical return interval of three times each decade. Because of the complexity of smoke-management issues and other fire-management concerns, the placement of a high-speed, high-traffic corridor next to the Forever Wild preserves is very likely to eliminate the ability to maintain the health of the ecosystem that millions of dollars have been spent to preserve.

We encourage the Baldwin County Highway Department to conduct comprehensive studies of the collective environmental impacts of the proposed road project. A thorough analysis of direct, indirect, and cumulative impacts of projects like the I-65/I-10 Connector is required pursuant to the National Environmental Policy Act. Eastern Baldwin County is currently relatively rural, and a project of this scope is going to have significant impacts, both as a direct result of the new roadway and indirectly through the acceleration of growth. Economic and physical growth are not inherently negative things, but unplanned development can have lasting and often unforeseen negative impacts on the region’s culture and environment.

We attended the public meeting held last week to view the corridor maps as well as the summary presentation on display. We respectfully request more information on this project including continued notice of public meeting, potential intersections, and the Highway Department’s timeline for this project. Additionally, we are aware of similar study being conducted by the Alabama Department of Transportation to construct a similar I-65/I-10 Corridor. What differentiates the Baldwin County plan from the ALDOT plan? We would appreciate a rationale explaining specifically why and how these two preliminary routes were chosen. 

This project must be viewed as one large undertaking. We assert that any permit request that may take place for this project be submitted as one single plan, with an accompanying Environmental Impact Statement.  We also affirm that any wetlands taking possibly associated with such a project should not be reviewed and permitted for fill in a piece-mail fashion as that is a direct violation of the Clean Water Act. 

Thank you in advance for consideration of these comments and our requests for further information. Mobile Baykeeper considers all roadway proposals for Eastern Baldwin County to be of high environmental concern, and such projects will be a program focus for the organization in 2010 and beyond. Please feel free to contact us with any questions you might have or to discuss these comments.

Sincerely,

Casi Callaway, Executive Director & Mobile Baykeeper

Donna Jordan, Program Director