Also on this page: 27th St. group slams I-94 North-South statement. EPA says WisDOT analysis falls short.

I-94 North-South project would add tons of global warming gases
WisDOT omitted impact from report

March 3, 2008 - Expanding North-South I-94 will add seven million tons of greenhouse gases to the atmosphere during the life of the proposed freeway, according to the land use group 1000 Friends of Wisconsin.

"This study should be a wake-up call for all Wisconsinites," 1000 Friends Executive Director Steve Hiniker said Sunday. "We are driving ourselves into a global warming nightmare if we don't free ourselves from the addiction of driving. More lanes means more problems for all of us."

The Wisconsin Department of Transportation is recommending that I-94 from the Illinois-Wisconsin state line to about Holt Ave. be expanded from six lanes to eight. That would increase carbon dioxide emissions by seven million tons over 50 years, according to 1000 Friends.

"For comparison purposes, each Wisconsin resident is responsible for about 20 tons of

C02 emissions a year," the group said.

The Transportation Working Group of the Governor's Global Warming Task Force was unanimous in endorsing strategies to reduce dependence on the automobile, Hiniker said.

"The Wisconsin DOT is going against all of our recommendations by recommending widening I-94," he said.

WisDOT did not consider global warming impacts in its draft environmental impact statement for the proposed, unfunded $1.9 billion reconstruction and expansion project.

Source: Sightline Institute

Hiniker said the 1000 Friends' analysis takes into account improved automobile technology that could significantly boost fuel efficiency.

"These findings show that even with more efficient cars, we will still be increasing greenhouse gas emissions from automotive source -- unless we drive less," he said.

The analysis was based on work done by the non-partisan Sightline Institute in Washington state.

Clark Williams-Derry, who oversees research for Sightline, discounted claims made by WisDOT and other freeway expansion supporters that adding lanes to freeways

actually reduces pollution.

"Our analysis shows this claim is bunk," he wrote. "Sure, congestion relief may help in the short term -- say, 5 to 10 years. (Even then, it's pretty slim stuff.) But over the long term, traffic in crowded urban areas tends to fill all available road space. And when roads fill up, we'll just have an extra highway lane filled with idling traffic -- and the extra emissions from new traffic positively dwarf any temporary decline in emissions from congestion relief."

Said Hiniker: "Instead of spending $2 billion to worsen our global warming problem and hurt neighborhoods in Milwaukee, we should take half of that money and invest in the beginnings of a world class transit system. That would help the economy of Milwaukee, the health of our neighborhoods and the health of the planet."

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27th Street group slams I-94 North-South statement

Feb. 4, 2008 -- The State Department of Transportation did not adequately explain its proposals for the 27th St./I-894 interchange in a draft Environental Impact Statememt, according to a business group.

WisDOT's presentation of alternative scenarios for the interchange were "unclear and difficult for the public to decipher throughout the EIS process," attorneys Douglas B. Clark and Brian H. Potts wrote on behalf of the 27th Street Business District Association.

Clark and Potts are with the Foley & Lardner law firm.

WisDOT's work on the DEIS for the proposed unfunded $1.9 billion North-South I-94 expansion project was so bad, they said, that the agency should revise the draft and circulate it again for public comment.

In maps attached the impact statement, they said,"there is no mention of closing ramps to/from I-94—even though this would clearly be a primary issue of concern for the affected public."

WisDOT has proposed closing the 27th Street ramp serving drivers driving northbound through the Mitchell Interchange.
Businesses and institutions along the the business corridor believe the state's plan will damage the business corridor.

The business association agrees with the city's contention that WisDOT should have better analyzed transit options, according to the letter.

In addition, wrote Clark and Potts in their response to the draft EIS, "a rigorous analysis will demonstrate that reducing and eliminating interstate access from/to 27th Street will have a substantial negative economic impact on local businesses. But the DEIS does not determine or discuss in any detail the social, economic or environmental impacts associated with the proposed options at the 27th Street/I-894 interchange."

The two, like others, criticized WisDOT's air pollution and environmental justice analyses as inadequate.

"The 27th Street/I-894 interchange proposal disproportionately burdens minority and low-income persons, yet this was not addressed in the DEIS," the lawyers said. "Moreover, these groups were not adequately informed of the proposed changes to the interchange, as the DEIS maps posted on WisDOT’s website do not indicate the full extent of these proposed changes."

To read more about concerns about the 27th St. interchange plan, click here and here and here and here.

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WisDOT analysis of air pollution, wetlands impacts inadequate: EPA
I-94 study reviewed

Feb. 1, 2008 - The Wisconsin Department of Transportation failed to adequately consider the impacts of air pollution and the loss of wetlands its draft Environmental Impact Statement for the North-South I-94 reconstruction project, according to the U.S. Environmental Protection Agency.

"We have rated the DEIS as Environmental Concerns -- Insufficient Information," wrote EPA official Kenneth A. Westlake.

"Our concerns center on how wetland impacts and air quality concerns are characterized and how mitigation strategies will be evaluated. Additional information is required to support the analysis and findings in the document," he wrote.

WisDOT's analysis of the impacts of vehicle-related pollutants "is not consistent with current academic literature and other published guidance," the EPA said in a comments attached to the letter.

WisDOT said in the DEIS that potential impacts of the pollutants could not be quantified.

Current literature, though, says that "reasonable scientific evidence exists that indicates adverse impacts may occur as a result of MSAT (Mobile Source Air Toxics) emissions, particularly at locations in close proximity to concentrated motor vehicle activity," the EPA said.

"We believe more could be done to quantify MSAT concentration in those areas where potential higher concentrations may be expected," the agency added.

On the wetlands issue, the EPA noted that the impact statement repeatedly mentioned degraded floristic quality of the wetlands.

"While many of the wetlands in the study area are limited in their floristic quality, they remain critical to the water quality of the region," the EPA said.

The 56 acres of wetlands that WisDOT says will be affected by the project "is a high number, but reflects the length of the project and its linear nature," the EPA said.

About 49 acres of affected wetlands will have to be replaced on a 1:1.5 ratio, meaning about 73.5 acres will need to be restored, the EPA said.

"The restoration project(s) need to replace the wetland types lost, such as riparian forested wetlands, shrub swamps and wet meadows," the EPA said. "The wetlands need to be provided for in one or more of the project's watersheds. "

Another 14 acres of wetlands may be needed to replace 7 acres that could be filled for the project, the EPA said.

"It is absolutely critical that these 14 acres contribute to restoring wetlands in or next to the primary environmental corridors of the Des Plaines and / or Root Rivers, and to continue the water quality function of wetlands for this region," the EPA said.

The agency recommended WisDOT correct the EIS shortcomings in the final version of the document.

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