Mayor says “Community Grid is the right alternative” and notes there are “still elements that must be improved“
Dear Director Frechette and Administrator Marquis,
This letter is submitted on behalf of the City of Syracuse (the “City”) in order to provide comments regarding the Draft Design Report/Draft Environmental Impact Statement (the “DEIS”) prepared by the Federal Highway Administration (FHWA) and the New York State Department of Transportation (hereafter referred to collectively as the “NYSDOT”). I greatly appreciate the thorough process under which NYSDOT and FHWA have considered this project and the community outreach and engagement and public input that has occurred over many years. The Community Grid is the right alternative for Syracuse, Central New York and all of New York State (the “Project”). While there are still elements of the Project that must be improved, that fact remains clear.
Therefore, the purpose of this letter is not to dispute the preferred alternative proposed by the NYSDOT, but rather to request that further mitigation for the adverse environmental impacts associated with the Community Grid alternative be included in the Final Environmental Impact Statement (the “FEIS”). See 40 C.F.R. § 1502.14(f) (requiring an FEIS to include “mitigation measures not already included in the proposed action or alternatives”); 40 C.F.R. § 1502.16(h); (stating that an FEIS must discuss “[m]eans to mitigate adverse environmental impacts”). The FEIS should include a detailed discussion of measures that the NYSDOT shall undertake to mitigate adverse environmental impacts associated with the Community Grid alternative. Oregon Nat. Res. Council v. Marsh, 832 F.2d 1489, 1493 (9th Cir. 1987) (citing 40 1502.16(h)), rev’d on other grounds, 490 U.S. 360 (1989). A mere listing of mitigation measures would be insufficient. Rather, an adequate FEIS must discuss the mitigation measures in sufficient detail to reveal their efficacy. Okanogan Highlands Alliance v. Williams, 236 F.3d 468 (9th Cir. 2000).
It is our sincere hope that the feedback provided by this letter will assist the NYSDOT in crafting a better plan to mitigate the impacts identified in the DEIS. Syracuse will benefit from the Community Grid alternative, but only if adequate mitigation measures are provided by the NYSDOT in order to address impacts proceeding from the construction process and certain design elements of the Project.
First, my greatest concern has been and continues to be the people who live closest to the existing I-81 corridor. They have borne the biggest burden in the past, and their neighborhoods must be protected and invested in. I am concerned about the proposed design and position of the roundabout at Martin Luther King School. We cannot allow expediency of transportation to put our children at risk for decades to come. I request that you listen to the public’s feedback and suggestions on this critical element of the Project and modify this design element in the FEIS.
Second, I appreciate NYSDOT’s inclusion of a Land Use Working Group for surplus land that will become available as a result of the Project. This group must include the City, the school district, neighborhood representatives, environmental justice groups, economic opportunity and development organizations, and other stakeholders. Land use is a priority concern for the City and its residents, so there must be local control of decision making regarding surplus land, and priority must be given to land uses that benefit environmental justice communities.
Finally, I continue to challenge the State to aim high on local hiring. The City and NYSDOT have worked well together in planning to ensure city residents – especially women, people of color and veterans – get equitable opportunities for jobs and careers from the project. The most critical stages are happening now. I urge NYSDOT Federal Highway Administration to reach an agreement on the goals being put forth, developed in cooperation with community stakeholders, for local hiring and to provide state and federal funds to train and prepare city workers throughout this multi-year project.
The complete submission can be downloaded and read below.
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