This column, which also appeared in The Daily Hampshire Gazette, was written by
land use attorney and Hadley resident Alexandra Dawson.
March 2007
Here’s the skinny on the Route I-91 project.
A study on congestion at the Coolidge Bridge, entitled "The Connecticut River Crossing Transportation Study", was completed in 2004. The author VHB, a prominent road designer, concluded that a new bridge to the north would not do much to relieve problems because the worst congestion is found on I-91 South, both coming and going. This conclusion, which matches well with commuters’ experience, was based on "origin and destination" information obtained from trapped drivers.
The study discussed a number of smallish projects in the area that would be beneficial (e.g. another turn lane where River Road meets Route 116). Of the major "infrastructure" proposals, it set out a series of "concepts" for solutions on the Northampton side of the river. Of these, four long-term alternatives meriting more study were briefly described but not analyzed. All involved changes at the Damon Road-Route 9 intersections, some far more radical than others.
Well and good.
Except that someone—who knows who?—has definitely jumped the gun and selected alternative concept # 15 without further cogitation. Congressman John Olver has come up with a million dollars to design this alternative. It seems likely VHB will get the job. And the Secretary of Environmental Affairs has certified (EOEA #13935) that the project does not require an Environmental Impact Report under the MEPA law.
The Secretary was within his rights because the project does not trip the thresholds for a "mandatory" EIR, even though it creates a bunch of new highway ramps, fills four acres of floodplain and 4,000 square feet of Riverfront, invades rare species areas, and is likely to slice up the Elwell State Park. Not to mention taking several homes. It was, nevertheless, a most unfortunate decision.
Apparently someone has misled the new Secretary Ian Bowles about how MEPA works, by telling him he is to require EIRs only for projects in the "mandatory" category. This is a mind-bendingly incorrect reading of the law, which contains two levels of impact thresholds. At the lower level, information is published in the Environmental Monitor and people are asked to tell the MEPA office, often at a site visit, whether an EIR should be required. What would be the point of all this ink if only mandatory projects counted? Very simple: No Monitor, no ENF, no public comments—life in the fast lane. Perhaps an example of "streamlining permits," a notion admired by the new administration.
In his Certificate, Secretary Bowles opines that public questions will be answered at Wetlands Act and MassHighway hearings. Unfortunately, the new MHD Manual (on which I worked) requires only one public hearing, and that far too late to discuss alternatives. Wetlands hearings are held only after a design is prepared. He asks that the Crossing Study Advisory Group be reconvened. But nowhere does he require that the four alternatives set out in that study be analyzed. One, at least, Concept 13, seems to solve the south-going-and-coming problems without taking houses, tearing up Damon road, or bringing a whole slew of new traffic, via a new exit ramp, right onto the very spot where traffic is already struggling to turn left onto I-91 south.
These alternatives, included the dreaded roundabout at the Damon Road intersection, deserve analysis; but, absent an EIR, there is no place to conduct the analysis. Instead we are being herded into an expensive and divisive pre-chosen project, with MHD and VHB on one side, enraged bicyclists on the other, and no place at all for the user-public to review the options in a sane, selective manner.