November 4, 2002

Mike Grovak, Project Manager
Bernardin, Lochmueller, Associates, Inc.
6200 Vogel Road
Evansville, IN 47715

RE:  Comment on the Draft Environmental Impact Statement for the Proposed Interstate 69

Mr. Grovak:

This letter is forwarded as comment on the Draft Environmental Impact Statement prepared for the proposed Interstate 69 which includes proposed routes that traverse portions of Monroe County.  The Monroe County Plan Commission through Indiana Code Title 36 Article 7, as amended, is charged with developing policies and objectives for the future development of Monroe County, for land use development within Monroe County, and for the development of public ways, public places, public lands, public structures, and public utilities.  It is within the scope of this charge that the DEIS has been reviewed and the corresponding comments have been made.

The Commissions fundamental concerns with the DEIS are the lack of comprehensiveness with the DEIS, how fundamental impacts are not addressed, and that the proposed routes through Monroe County have significant impacts that are not in the best interest of the community. 

Specific concerns regarding the lack of comprehensiveness of the DEIS include the following:

Failure to adequately discuss and analyze the potential impact upon the adopted land use and development policies of local communities.  All three jurisdictions potentially impacted by a route through Monroe County (Monroe County, City of Bloomington, and the Town of Ellettsville) have adopted land use plans.  These land use plans serve as the foundation for the communities decisions on project approvals, investments in infrastructure, and actions taken to protect environmentally sensitive features. 

These plans have been developed and adopted without consideration of nor demand for an interstate facility.  Introduction of such a facility could dramatically alter the future location of land uses, public investments in infrastructure, etc.  Further, such a facility could dramatically alter the stated preferred development pattern for the County, that is one where development is focused within the City of Bloomington, the Town of Ellettsville and several small rural communities dispersed throughout the County.  It may prove difficult if not impossible, to continue to pursue such a development pattern should an interstate cross rural portions of the County.

On a more pragmatic note, each of the adopted plans would likely need to undergo significant revision and update.  The costs associated with such an endeavor, likely to be in the hundreds of thousands of dollars, would be borne solely by the local communities.  The DEIS simply fails to adequately consider local land use policies and to analyze what the impact of a new interstate on these policies would be.

 Failure to adequately evaluate impacts upon local facilities and services.  The DEIS fails to identify the potential impact an interstate facility in Monroe County would have on the local road network, the vehicular movement of residents, emergency vehicles, and farm machinery.  Without a comprehensive understanding of what local roads would be bisected or re-routed as a result of the interstate, decision makers cannot be fully aware of the impact the interstate would have on the same.  Likewise, the DEIS provides no discussion regarding the funding source for construction of needed frontage roads, re-routing of local roads, etc.  Again, without such information, decision makers cannot fully understand the actual impact of the interstate.

It is quite possible that currently available routes that area residents use to move about the county will no longer be available, in some cases adding considerable time to local travel.  Likewise, the same impact may be felt by emergency services such as fire, ambulance, and law enforcement.  In some cases, this may force the construction of additional facilities in areas not otherwise planned nor funded.  Similar impacts will likely occur to truck traffic arising from area quarry operations and with farm machinery moving from field to field.  Finally, local movements of non-vehicular traffic such as bicycles would in effect be limited to a very few locations, many of which are quite heavily used by vehicular traffic.  Essentially no discussion of these topics is contained within the DEIS, again failing to provide decision makers with needed data upon which to base their decision.

Specific concerns regarding the extent of impacts identified in the DEIS include the following:

 Significant impact on the quality of life present in Monroe åCounty and on local environmentally sensitive features.  A very high quality of life exists in Monroe County, one that includes a strong and diversified economic base, strong housing market, outstanding cultural offerings, and a unique and beautiful physical environment.  Each of these face significant impact from the placement of an interstate facility within Monroe County.  

The DEIS identifies substantial impacts to the areas unique environmental features including karst features, caves, woodlands, wetlands, and farms.  It is our belief that due to the limited research conducted regarding the presence and significance of environmental features, the impact will likely be far greater than identified in the DEIS.  Relying solely on the data provided in the DEIS, we believe the environmental impacts associated with an interstate in Monroe County outweigh the perceived benefits to the residents and businesses located in Monroe County.

The DEIS identifies limited economic benefit for Monroe County residents from a new interstate traversing Monroe County.  Indeed, it is our belief that most of any new jobs created as a result of a new interstate will be in the low paying service industry, often in the form of ìbig-boxî retail and fast-food restaurants.  Further, the DEIS identifies the potential for the removal of a number of existing local businesses, some that uniquely contribute to the Monroe County economy and the local quality of life, such as Oliver Winery and Worm's Way Garden Center.

The introduction of an interstate facility in Monroe County has the potential to significantly alter the current quality of life enjoyed by the residents of Monroe County.  Impacts include the further bisecting of the community into east and west, reduction of non-vehicular movements from east to west, difficulty in local vehicular movements for residents, emergency vehicles, and farm machinery, loss of environmental features as discussed earlier, loss of unique businesses, additional air, noise, light, and water pollution, etc.  Based on the data contained in the DEIS, it is our belief that the impacts on the quality of life for county residents are greater than any perceived benefits for the same.

In conclusion, we believe that the DEIS needs to be expanded to include further consideration of the items identified above, including evaluation of impacts upon locally adopted land use plans, transportation plans, and existing and future public facilities and services.  Further we believe that the impacts associated with an interstate through Monroe County are greater than any perceived benefit to the residents of Monroe County.  

We therefore, encourage BLA, Inc., INDOT, and FHWA to delay any decision until all of the necessary data has been collected and adequately analyzed and to focus on a facility that capitalizes on the use of existing roads outside of Monroe County, rather than the establishment of a new terrain facility.

Sincerely,
 
 
 
 
 

Brian O'Neill  John Irvine    President   Plan Commissioner	Carol Wise Plan Commissioner	Scott Wells Plan Commissioner
Charles Newman Plan Commissioner

 

cc:  Bryan Nicol, INDOT Highway Commissioner

(original document on file.)