Public Comment File
Michael Grovak,  Project Manager
Bernardin, Lochmueller & Associates
6200 Vogel Road
Evansville, IN 47715

Re: The errors of the DEIS study:

I am for no build.  I could compromise US 41 / I-70, because  Some of these losses will be true to a lesser extent if the highway is built on existing four lane US 41 & I 70, but I believe the facts show “no build “ to be justified.

Loss of Farm Land:
Loss of productive farm land is in error of a factor of perhaps 2 times more loss than estimated because of the following:
 Frontage road losses not calculated by the study.  (60% of existing roads crossed will be closed.) Frontage and access roads not calculated will require the paving over of topsoil that blew from Kansas in the dust storm years.  We should be good stewards of the land that is a gift to Indiana.  With an ever growing population keeping the earth able to produce more and more food is of obvious importance.  The price paid for  food will rise as the demand increases and the available land decreases.

 “Point rows!”  A very large percentage of the farm land that is crossed by the new-terrain routes  is in a generally north/ east direction.   Current roads run North/South and East /West. This means that farmers who are now farming squares, are left with two triangles with what farmers call “point rows”.  It refers to the fact that you can not turn a tractor on rows that run out at different lengths as in triangles rather than squares.  Many farmers in Gibson and Daviess counties are left with field after field with this situation. This  renders their operation not viable given the loss of productivity and transportation times and costs to access remote fields that are currently continuous squares rather than isolated triangles.
 

Recognition of farming as the huge business of production of food is seemingly missed. Food production is one of the last USA manufacturing strong holds, yet  every environmental concern of the Draft EIS is addressed by taking more farm land.  Some routes will mitigate up to 1000 acres of lost forests with something.  Will this be farm land?  What ratio will the forests be replaced?  Has that been estimated into the loss in the amount of farm land, or is the 4000 acres lost on some routes before more land is taken to replace lost wetlands and lost forests?  The total loss of farm land needs to be accurately calculated.

Almost every consumer item is made in Taiwan or China now.  If you don't pay attention to this fact, then go to Walmart and look at every item.  You will see the fact that nothing is made almost anywhere accept China and Taiwan now.  The exception?  Food production and preparation is manufacturing in the USA now.  This needs to be protected and made more efficient.   Farm soil must not  convert to just any use that can prove more valuable in dollars for the short term.  By the time that food soil has reached the equilibrium with other land uses, only the rich will be able to afford food.  Joe Kernan has made this point.  If he does not come to the rescue of farms  soon, his legacy will be that of a liar politician who sold out the movement of his own making.  The protection of farm land, this is something that he should be proud of and stand up for.  If he does not, then he is worse than one who never made the point.

The fact of the Amish not using cars and being asked to give of their community for this limited access highway is of particular concern.  It is plain unfair.  Their lifestyle is based on a healthy community, undivided.  They require little in infrastructure costs from other taxpayers.  Their lands should not be invaded for a infrastructure item that has no possible use to them.
 

This Highway is not a good way of producing Jobs:

INDOT’S record for job creation is not even poor, it is a very strong negative.  According to DOT records, Indiana is #4 in interstate road density.  It was #1 in the country in Job losses in 2001 and #2 in the nation over the past 7 years.  Please see this Graph from http://www.assmotax.org/I69/InterstatevJobloss.php

One of the persistent themes surrounding the I-69 issue is that of economic stability that the highway will provide. Using data supplied by the Economic Policy Institute and the Federal Highway Administration we plotted the level of NAFTA-related job loss vs. existing rural interstate density per state. As you can see in the graph below, there is no correlation between a state's rural interstate infrastructure and its ability to create or retain jobs in the NAFTA era. In particular, Indiana is fourth in the nation in existing rural interstate density. It was second in the nation for job loss in the seven years 1993-2000.
 
 

*
 

This shows that despite being a leader in Interstate density, under our program of “Crossroads of America” we have become the leader in Job Losses.  To continue down this path would be a terrible waste of money.  There is no  evidence that building another highway in Indiana would improve this trend, in fact cutting smaller and smaller pieces of land will likely make the possibilities more and more limited for other uses.
The study lists as best case a growth in jobs of approximately 1/4 of one percent over the period of the
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study.  This return on investment is far below that of known jobs development programs.  It is hard to imagine a worse appropriation of money for economic development.  Prior studies for this highway showed $1.53 returned for every $1.00 invested, but this was over a 30 year time period and was later corrected to a loss benefit return of $.84 per dollar invested.   The original Donahue economic study of this project commissioned by Governor Bayh in 1990, found no benefit and recommended, no build.  Given the chart above and the errors in in the DEIS that are being discovered with public comment.  I believe that the “No Build option is still the only correct option.  The current study does not include a cost benefit analysis, because none can show a benefit.

Federal Gas Tax should maximize transportation interests and not be thought of as economic stimulus, since this is obviously not INDOT’s area of expertise.

The condition of Indiana’s roadway infrastructure is poor.  More than 1/3rd of our bridges fall below acceptable DOT standards.  The surface of roads are so poor as to be dangerous.  Many thousands of hours are wasted each week by Hoosiers stopped in metropolitan traffic jams.  These problems will only get worse if our budget is directed at yet another interstate highway. The most expensive variation of the proposed routes is 3B.  At an estimated cost of up to $1.8 billion dollars, that is three years of the entire INDOT budget that could otherwise be used to maintain and improve the existing roadways.  Since this road would take an estimated 9 years to build, INDOT would have to reduce repair and improvement of existing roads by 1/3rd, or raise the gas tax on every tank of fuel purchased forever in the future.  Given the request for a $.15 per gallon increase this year, which was granted a $.03 increase that we will begin paying in less than two months, I assume that INDOT has decided that we will pay more for this highway.  $.15 per gallon would be an additional $2.25 per 15 gallon tank full of gas per Hoosier for the rest of our lives.  This money would be removed from the Indiana economy for other areas of commerce.  Given family’s of 2 cars using 1-1/2  tanks of gas per car, this would remove $351 per family per year in buying power to fuel our economy.  It would greatly reduce the desirability of our fuel to cross country truck drivers if they were required to pay even a similar percentage for the road that would be of a greater percentage benefit to them.  That is they might only use our interstate 69, yet always purchase their fuel before crossing  our state if other states built their highway at a lower cost or at a time when it was able to be paid for in another way.

 In this time of economic down turn after the longest economic boom in history it would be most prudent to fix the existing infrastructure and look for economic benefit from general overall road infrastructure improvement and investment of funds that can be found poured into education.  Education will bring economic benefit. Raising the gas tax for a road that is not needed will not be a positive for the state.

Some persons make the mistake of thinking the building of the road is it’s self an economic benefit, or that the homes construction that will replace those that will be destroyed represents new jobs.  This is not true because the money that would would go to build this road, or even to the profit of home construction businesses or real estate offices, is highway money that will not go into transportation.  All of the money that would be spent on the highway, would be spent by INDOT anyway, given no tax increase.  Giving a portion of INDOT’s budget to a homeowner to relocate actually moves money from transportation into the homes and real estate market.  The Interstate highway builders make less money than if they were repairing existing roadways, because they do not have access to the acquisition funds for the land, buildings and protected natural resources that must be compensated by INDOT to build an New Terrain Highway.  Bottom Line, we get less transportation per dollar of our Gas Tax money, while we maximize environmental, damage, by placing our bets on a division of our government that has a proven lack of success in developing a strong economy.  If otherwise were true, wouldn’t it follow that a state with a capital city with the most interstate connections of any in the country and with the 4th highest interstate density in the country would have at least one of the top 5 or 6 economies in the nation.  The study needs to explain why a new highway will do what the old ones could not, and why fixing the existing interstates, state highways, county roads, and city roadway infrastructure across the state would not as greatly benefit
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the state.  The fact that Kokomo Indiana and Bloomington Indiana are among the top 5 cities in economic health in the state of Indiana points to the fact that Interstate Highways are not the silver bullet.  Ones who claim otherwise are missing something.  Most cities in Indiana on Interstate highways are not doing as well.  These facts need to be understood.

INDOT’s desire for another Interstate is like a person buying mag wheels for a car with a major oil leak and a rod knocking.  Fix the problems you have got and forget the trophy.

 Improved access of non interstate roads actually bring greater economic development than interstate highways!
Hoosiers see their state as a bicycle wheel with two spokes missing.  The US-31 spoke is hardly noticed, because that corridor that includes South Bend, Kokomo, Carmel and Indianapolis is perhaps the backbone of the Indiana economy because they are on a US highway, and not an Interstate.  Development along it is not hindered by limited access.  Kokomo has remained relatively successful because the automobile remains as one of the last remaining consumer products that is still manufactured in the USA.  Televisions, appliances, clothes, and now elevators are moving away from the USA.

Even NAFTA is not working.
For the past decade, NAFTA has created that “great sucking sound” that Ross Perot predicted as Jobs have left the USA to Mexico.  Lower transportation costs can only continue the trend toward globalization of manufacturing.  This is likely understood by everyone, but the highway is being sold to the public on a hint that manufacturing might somehow return because of transportation.  When this “NAFTA highway was planned a decade ago, perhaps persons actually thought trade would go both ways and that jobs would not go to the lowest wages, but that is a proven fact now.  But it is very important that this DEIS study wake up to the newest fact of NAFTA.  It is a totally failed treaty because now the jobs are leaving Mexico just as fast a rate.  Jobs that did pay $20 per hour in the USA went to $3.00 per hour Mexican workers and last week NPR reported that those same companies have moved their operations to $1.00 per hour factories in China.  They reported extensively from Juaraz, the boom town of three years ago,  that the job losses are so bad that even housekeeping jobs are hard to find.   The flow of goods show no trend of being from Mexico to Canada.  China and Taiwan made goods dominate the trade deficit at an ever increasing rate.  This trend needs to be disproven before investing Hoosier transportation dollars on a South North Interstate.  The flow of Chinese and Taiwan goods is from West to East, not South to North.  Wake up Indiana, before you make this ridiculous mistake.  Don’t buy us another I-64, a highway that is not needed at a price that will drain our economy for so far in the future that no end will be in site.  Create a good secondary road infrastructure like that found in Michigan.

This Highway is not needed.

That the study never points to the traffic count on the existing roads points to the fact that the roads that exist are actually some of the most pleasant to drive in the state.  One rarely is slowed below the speed limit and curves are gentle enough that you never feel any “g-force while going through corners.  Stopping is minimal and even slower traffic is rarely a problem because of low density and the availability of at least three highway options from Evansville to Bloomington.  The existing roads could be improved with a few well placed passing lanes and most travelers from Evansville agree that this is all that would be required to  fix any problems?  The inducement highway concept that calls for more trucks to pollute the area and destroy the natural unspoiled beauty is exactly what will ruin the reason why many people live in the area.

The “Core Value” System of this study is totally out of step with Hoosier values and is so rigged as to be obvious to anyone who stops to think at all.

That this study is a required “environmental study”, yet the study can conclude that the most damaging, most expensive route is the winner of the “environmental study”  while the least damaging and least expensive routes are the least desirable is outrageous.  That the study is “Core valued” into speed and money makes one wonder why the federal government called it an Environmental rather than an economic expressway study?  Stop and smell the roses is a phrase that residents understand more than the Interstate proponents who see only a underdeveloped wasted land that needs to be as quickly as possible traversed to get from one congested area to another with as little time between as is possible.  I am doubtful that the farm economies of Daviess and Hendricks County is visible to these city slickers as well.  This “core value” is not the core value of the residents of the area who will have their homes taken and their neighborhoods destroyed along with friendships and divorces and early death of persons aged.  The “core value” system of the study is The human destruction that will follow is captured in the speech that I gave at Bloomington High School North on August 20, 2002.  I called for a Center for Disease Control Study of the emotional and physical health results of forcing persons from their homes.  My “What will be the toll in deaths, illness and divorce to this destruction of citizens homes and neighborhoods is included as an attachment.  “Core values” must reflect those of residents of the state not a those of a small group of people in an Evansville or INDOT board room.

The Losses in home equity  need to be SUBTRACTED from the recognized benefits of the interstate.

My wife and I searched for three years for our home.  Homes like ours are always sold before they are listed publicly with realtors.  The lack of noise and light pollution are among the features that were a must, as well as a distance of 10 miles from Bloomington.  We can regularly see the Milky Way and often stand in our yard for 15 minutes in the day time and not hear a human sound.  Our house was listed in the newspaper 1 day in a classified ad and the owner got twenty offers to purchase and chose us.  We have gardens that are more like those found in France at the house of Claude Monet than any I have seen.  Eight Acres, Greene County, Two Bedrooms, does not describe what we own.  That which is now worth 1/2 what it was worth before being targeted by the I-69 project.  Our loss of $70,000 in year 2002 dollars equals two years of geriatric care for me in my declining years.  As one who invested very poorly in our stock market, and who is a self employed businessman, my home equity was my ability to die in honor.  The loss of this equity is a true monetary loss to the economy of the region.  If I do not sell, I will not be able to provide my care givers payment for as long before I become a burden on the taxpayers.  This is a real loss in equity for the state.  This negative number, the reduction of value to real estate within one mile of the road needs to be subtracted from the benefit.  This amount has been estimated as 1/2 of the equity up to 1 mile away by a Michigan study.  A similar number must be established for this study.

The travel time increases to local residents crossing the interstate are very real losses and they need to be SUBTRACTED from the savings in time for the interstate users.
The core value of “access” that views the interstate only in the one dimension along it’s continuous asphalt pathway is totally unfair to those Hoosiers who will pay for the highway.  Looking at the maps that pass within 1200 feet of my home, if I walk to my neighbors home now, it takes 5 minutes.  If our houses would both survive I-69, the walk would increase to two or 3 hours and the drive time will be on the order of 20 minutes.  Steve Howard who is a major supporter of the Interstate highway recognizes 800,000 persons in the corridor.  If we were to assume that 1 in 8 persons will be slowed in their travels because of crossing this interstate, or because of further traffic congestion nearby, then this would be 100,000 people.  If we suggest that on average these persons spend 5 minutes per day slowed because of the up to 60% of the roads that it crosses being closed, then we will lose 500,000 minutes per day.  This is 8333 hours per day, or 58,333 hours per week and 30.3 million hours per year lost to this highway by the  residents who have to negotiate under and over it’s limited access nature.

If one wants to challenge the numbers, the concept is still factual.  There is some real number in the loss of time to residents that needs to be subtracted from the gained “access/ core value” recorded in the study.  This is again one of these clear stacking of the deck tools that has so maddened Indiana citizens and make us look at our government, the consulting firm and the process as unfair.

That these highways stifle development between the intersections is undeniable as one travels the interstate system.
I often ask persons in small towns like Bloomfield, which city along I-64  that  they  would like to emulate.  They always say that I-64 was not justified by the study and it should not have been built.  I contend the same is true of this highway.

Person think that they see growth, because they overlook the diminishing or the death of businesses that lose traffic to the Interstate and the movement of job from the near to the far.  In the case of this proposed Interstate, if it is built elsewhere, the existing US 41 businesses will lose a majority of their traffic and be given no compensation.  As one who has moved my bicycle shop two times in the past when Landlords have decided to tear down my building for another, I can say with experience that moving a business is a positive.  Moving ones home is a totally different experience.  One that I had hoped would never happen.  I had planed to die here.  If I-69 is successful, then a portion of the traffic will be vehicles that would have traveled US 41 or US 65.  The business moved from those locations is not growth.  Persons traveling from small towns to bigger cities to work from longer distances has a negative effect on the qualities of life for everyone, while not adding to the employment base if the person were working in an Indiana town before getting the big city job.  Added travel distance uses more fuel.  When looked at in conjunction with the example that I gave above of walking time from my house to my neighbors changing from minutes to hours, it is clear that new Interstate highways do not move us any closer to the goals of the current Tea 21 laws that set as national goals the reduction in car trips of 10 percent.  The proposed I-69 would actually increase car trips and distance of car trips as well as the overall time of all car trips in opposition to the stated goals of our DOT.  There  would be no benefit to Evansville for it’s air quality problems and in fact the problems would be increased for the same reasons of increased sprawl travel that would result that would give Evansville the look of growth while stealing the economic vitality from the hearts of small towns like Washington, IN as has been seen over and over with every interstate highway project.  That the County Seat of Greene County does not get an exit closer than 8 miles shows that the proponents arguments of economic development of Greene county were shallow promises.  Currently two of the major routes from the south to the north in this region pass through Bloomfield.  No traveler will make the mistake of exiting the interstate and driving to Bloomfield by  accident.  The city will be stripped of all through traffic.  The residents will spend much more of their income in Evansville after driving 12 miles to the Scottdale (correction: Scotland) exit.  Bloomfield will die an ugly death, much like a Route 66 city.  Washington Indiana is perhaps Indiana’s most beautifully preserved city.  It stands alone in seeming unchanged by our big box store mentality.  It’s downtown is vibrant, yet stuck in time.  The Amish community provides many excellent restaurants that draw customers from far away.  The magic of Amish will disappear in a flash.  Some will call it progress, but what will be lost is small city charm, that is almost extinct.  If one wanted to make a sequel to American Graffiti, you would only need to change the decade of the cars.  The Church by the Mound South of  Scottsdale (correction: Scotland) is another magic place.  I watched a very old lady paint a picture of the church while the woman minister played her accordian with electric bass guitar accompaniment.  The the sound of the wind was evident as we enjoyed the view across the fields.  This will be lost to a noisy stinking interstate next to the geological wonder of the mound that I wouldn’t be surprised if INDOT decided to flatten just for the fun of it.

The most magic place on all of the routes is the twin antique bridge area of the Patoka Wildlife Sanctuary.  Why we would be willing to give this to a highway is beyond me.  Especially a highway that is unneeded and unjustified and fraught with the look of corruption regarding the placement of intersections and the flow of contracts and donations that appear a little too cozy.  The division of this wildlife area will create a break in this preserve that is criminal.  Someone in our federal government needs to get down there and say STOP!  These kinds of places will not and can not be replaced by INDOT even if they had any sense of understanding of National Wildlife Preserves.  One has to wonder who in our federal government is amiss in their “preservation” duties here.

The privately owned natural area of Green County between Scotland and Hobbieville is perhaps just as much in danger as the Patoka Wildlife Sanctuary and Washington Indiana, in fact getting back to our pioneer roots is easiest in this area of any that I have experienced in all of Indiana.  The Ashcroff church  and the Ashcroff log cabin make me think that there is federal recognition of this area possible that should not be allowed to be missed as this project would bulldoze over what can never be saved.

Further north is my own neighborhood of Maryland Ridge.  It’s national importance has been reported in the notification to this study by our community, so I will not duplicate efforts here.

The karst topography of this region, I believe, renders building the I-69 highway impossible.  While I am not an expert of geology.   I traveled up and down all the roads of routes 3 and most of 4 and 5.  I had the DEIS atlas on the seat beside me for hour after hour for the past 2 -1/2 months as I delivered maps to homes, businesses, farms and churches within 1000 feet.  I have seen the accuracy of the maps.  I have seen almost no missing homes,  Only one major church is missing It being being the Mount Zion Church on 142 and Heremont Road on Alt. 3 map 20 of 32, but it seemed every owner of ten acres of land in the Greene County and Monroe County area knew of one, two, three or more Karst features that were missed by the study.  I think an accurate study of the Karst features of the region will render building of this highway through this region impossible.  A truck driver pointed to the maps and said, “This doesn’t look like an interstate, look at all those curves, what is this all about.”  A GIS expert said laughingly, “I see their problem, they are trying to snake this thing past one karst feature after another”, one runs them into the next.

To chose any of the alternative routes 3 without first doing a more serious Tier I study of Karst would be stupid.  To eliminate other routes to learn that this one is impossible would be to further waste Indiana taxpayers money on Bernardin-Lochmueller & Associates study of this project.   Such obvious potential for impossibility to proceed on this area of karst, so incompletely documented, could likely bring question to the idea that perhaps building the highway was never the object of the study, but that the payment for the study with tax dollars and return of campaign contributions from persons enriched by INDOT study contracts to those granting those contracts might easily be questioned.  These ideas come very easily to large numbers of persons in our society in the post Emron (correction: Enron), post WorldCom era.  If it were me,  I would  step back and do a more complete geological and archeological tier I study, before proceeding on to a selection of “the route”.   In fact, I would recommend an independent contractor with no know association to any of the parties involved in the study to date do this study.   It would seem unwise to select route three to the exclusion of other possible routes and then invest more public funds  into a Tier II study, to ultimately fail to be able to build because of a shoddy tier 1 study.  I would consult council to see if perhaps giving  recommendation to proceed, might at some point actually  leave one open to a difficult to defend legal action.  Certainly care and prudence on the part of the consultants and politicians involved would be  recommended in a national climate of public skepticism and perceived corporate greed.

I do want to call into question the notification procedure. In this day and age posting a notice with a vague map saying go to the library perhaps 20 miles away or more is not a reasonable notification.  I have witnessed the ease of generating a mailing list to every person in Monroe and Owen Counties with GIS technology.  The time to create mailing labels for every person in Monroe County on all three of the routes who owned property within 1000 feet of the route was less than a minute.  The time to sort it by Zip code, also less than one minute.  The cost to mail the notification to 2000 persons less than $400.00  It makes no sense to have a law that says that notification must be made and then make that notification more difficult than necessary or perhaps as difficult as possible.  Persons late paying for something as insignificant as their cable TV bill are legally required a written notice before disconnection.  That one can pay your taxes in a timely fashion and do nothing else wrong, but not be granted written notice of intent to seize ones home and property is not at all like the United States of America that most residents would consider worth fighting for with pride.  As Richard Lugar put so well, you should notify the public to the best of your ability.  The labeling of the Atlas on your website was so poor that professional web designers took 2-1/2 hour to find appropriate maps.  Persons have agreed that the maps are buried under three layers of mislabeling.

The question of access to the Freedom of Information request for  GIS “Shape Files” is at least a public relations nightmare and again smacks of something that one would want to run passed a team of attorneys.  Perhaps it should be questioned if this is grounds for reopening the comment period after this data would be provided.  If it were the decision of Bernardin-Lochmueller & Associates to  deny access to INDOT the GIS background information I can not believe that the public would ever tolerate future contracts granted to the firm.  This is especially true considering the amount of money we have given your firm for various projects over the past decade.   Of course we have to suspect that it is not the consultants  at all who are denying the data to our INDOT, but perhaps more likely INDOT who is requesting not to be granted the underlying data so as to deny citizens the factual basis for the study.  We perhaps will never know for sure what the dynamics of this are, but again something here is not the United States of America that is taught in our schools.  The underlying principles of government by truth seem a lot more Soviet-like in this case.

As I wind up my comments, I want to be sure that you are aware that all of the bats that the study has reported as making 3A undesirable are also in the exact same relationship to 3B.  Those bats that reside behind my home, also do a terrific job of stopping the mosquito population of the region.  Dozens of the bats come out each evening in the warm months and feed for an hour or so along our woods, which is continuous woods from Buckner Cave, Small Dull and others to the I-69 proposals 3A and 3B.  I would direct you to the comments submitted by Gary Milhoan.  His include text from studies of the protected Indiana bats.  The study suggests that protecting the summer habitat is equally important to the preservation of the bat.  Among feature that I believe need particular care is a pond owned by Richard and Cheryl VanPelt.   Other wildlife depend on this pond for sure, and given the text of the Gary Milhoan provided article, I would surmise that this pond is important to the bats survival for drinking water.  The article also points out that the bats travel great distances to the summer nesting spots.  The situation is so delicate, that again this should be reason to think long and hard before choosing to move forward here.  Given the fact of West Nile Disease with no solution in the near future, the preservation and restoration of this bat population should likely be a very important goal.  The protection of bat habitat could be a best defense against this natural menace.

I suspect that others have informed you, but I have heard of two or three caves that the opening is exactly under the road. I have not confirmed these, but I could take your investigators to the locations described to me.  One is right behind the old Ivy tech location, and the other is on 3c between hobbieville and US 37.  Both of these are right in the center of the road I am told.   There is another one close to the mouth of the cave, but not directly over it.