20020672 Ver 3_Sierra Club Comment_20150205

Central Piedmont Group, NC
Amy Chapman, DENR-DWR, February 5, 2015
Water Quality Permitting Branch,
1617 Mail Service Center,
Raleigh, N.C., 27699-1617

Dear Ms Chapman,
The Central Piedmont Group of the Sierra Club opposes issuance of a 401 permit for construction of the
Monroe Connector/Bypass because we do not believe there are benefits that would justify the
environmental harm it would cause. The analyses by NCDOT that make that claim are seriously flawed.
Our major disagreement with the conclusions of the Record of Decision is that it starts with the wrong
needs for our region, i.e. “to improve mobility and capacity . . . by allowing for high-speed travel . . .
while maintaining access . . .” To maintain access is appropriate, but high-speed mobility is not a need.
We believe that environmental protection should be given much more weight in decisions regarding
transportation improvements. Transportation is responsible for 38% of the CO emissions in NC and
2
second only to utilities for its share of the total. (USEPA data)
The environmental analyses never mentions the impact of energy extraction and the climate impacts of
burning fossil fuels, which is the greatest threat to the planet ever identified and will provide another
pathway to water quality degradation. Spending such a large amount should be seen as an opportunity
to take a step toward a redesign of our transportation system such that it would yield a reduced
environmental impact. Instead, the 75 additional lane miles of the preferred alternative will generate
more vehicle miles, storm water runoff, fuel consumption and Green House Gas (GHG) emissions.
We have no confidence in the traffic analysis because it appears to be based on outdated trends and
assumptions. The Final Environmental Impact Statement (FEIS) speaks of using “historic travel trends”
but has no discussion of recent changes in those trends such as a decrease in per-capita Vehicle Miles
Traveled (VMT) over the last 10 years (FHWA statistics), the increase in transit ridership, the aging of the
population and increasing use of telecommunication. NCDOT asserts that Union County is and will
continue to have high growth rates, but the rate of growth has already slowed (CRTPO projections).
Another recent trend is an increased preference of people to live and work in downtown areas, close to
transit and walkable communities. The Rt. 74 study area is hardly walkable (e.g. Monroe has a
Walkscore of 25).
NEPA requires that environmental impacts be mitigated as a part of the project. The FEIS identifies the
loss of wetlands and streams, forests and farmland by the Bypass. Under the discussion of mitigation it
mentions coordinating, study and testing but little action or dedication of resources. It did note that

many of the necessary followup actions would be covered by existing regulations. But there is no
assurance that the regulations would be enforced, or that they are sufficient in the first place.
The alternatives analysis rejected several “unreasonable” choices, either without a reason, or based on a
failure to meet the prescribed Level-of-Service, a seriously flawed metric. Measures such as lowered
VMT per capita, per employee, or per trip are superior. If the goal were revised to “Improve accessibility
while minimizing environmental impacts”, this would likely lead to more effort toward developing
creative approaches to the problem, especially with strategies to offer alternatives to the automobile.
The FEIS includes a mass transit alternative, but it is a simple listing of existing transit, including the
recent elimination of a stop, so as to suggest an apparent failure. An honest consideration would have
looked at what sort of service could be provided with at least $838 million dollars (more would
recognize the environmental benefit). For example, NCDOT might have considered an extended Silver
Line to Monroe, or dedicated lanes for a Bus Rapid Transit system. The TDM alternative is pathetically
weak, failing to look at many tested methods such as transit subsidies, alternate work schedules and
parking management. Where is the consideration of adjusted land use policies directed at
concentrating future growth? Where is the consideration of commuter rail on the parallel CSX line?
Individual alternatives were narrowly defined, then evaluated in isolation which made it easier to
declare them “unreasonable”. There should have been an evaluation of a super hybrid of
Transportation Demand Management (TDM) / Transportation System Management (TSM) / Mass
Transit/Multi-Modal / Improving Existing US 74 Alternative or various subsets thereof. For example, if
dedicated bus lanes along the most congested stretches, or even on parallel routes were constructed
(US 74 upgrade) and low-headway buses with pre-pay stations (Mass Transit) with traffic signal override
(TSM) and upgraded stops accessible by a network of bike lanes (TDM) you would move a lot of people,
provide access and avoid a lot of water quality and other impacts. Would it cost less than $838 million?
If NCDOT had done an honest job, we would know.
It comes down to how a problem is approached and what values are engaged in the process. If going
fast on the way to the beach is your highest goal, you may decide to spend a $billion on pouring
concrete. But if you value community, clean water, open space, and a stable climate, you will spend
some time analyzing the old paradigm. DENR-DWR should insist on corrections to the indicated
problems and omissions before considering a 401 permit.

Sincerely,
David Robinson, Chair
Central Piedmont Group, Sierra Club
16713 Cabarrus Rd
Charlotte, NC, 28227-6463

Roger Diedrich, Transportation Chair
Central Piedmont Group, Sierra Club
10128 Vanguard Parkway
Huntersville, NC 28078-5357
[e-mail]