March 29, 2007

Steve Wilson

HDR Engineering

109 Harrison Avenue

Panama City, Florida 32401-2726

Via Electronic mail to: denise.curry@hdrinc.com

Subject:  NWF Transportation Corridor Master Plan

Dear Mr. Wilson:

On behalf of the Florida Chapter of Sierra Club and the Panhandle Citizens’ Coalition and their members who live throughout Northwest Florida and the State of Florida, we submit these comments on the Northwest Florida Transportation Corridor Authority’s proposed corridors and final master plan.  We ask that this letter be distributed to all the board members of the Authority.

Our first concern is that the citizens of Northwest Florida have not been adequately informed about a proposal that has the potential for making vast changes in the way they live, commute and travel, and the costs for doing so.  

Recognizing the Legislature’s charge in s. 343.82 F.S. to the Authority, to prepare a corridor master plan by July 1, 2007, the Authority has a responsibility to engage affected citizens. We find no evidence of effective outreach to inform or engage citizens or their organizations in the process of developing this proposal.  We do not believe this plan should move forward without more interaction with the public, such as conducting a series of workshops.  At the outset the public should have been asked:  What is your vision for the Panhandle, and how can transportation projects enable that vision?   This never happened.  All they are getting now is the required public hearings. 

Yet the citizens are the ones that will have to pay the tolls resulting from these new highways, as well as suffering the effects of the mismanaged growth and loss of their resources.  We would trust that Governor Crist will not approve this plan until these important decisions are made with adequate public input and reconsideration of many of the proposals in the plan.

We are also concerned that the plan reflects not the needs of the public, but the wishes of the development sector, especially the St. Joe Company.   It appears from its proposals that the primary goal is to provide infrastructure for future development on St. Joe properties that are currently inaccessible or have limited access.  The state and its taxpayers should not be subsidizing development for St. Joe.  Florida, and particularly the Panhandle, have real transportation needs that should be addressed with our precious tax-dollars, not used to enhance property values.  

For example, building a major turnpike through north Bay County for the sole purpose of providing infrastructure for the proposed Panama City-Bay County airport will squander our transportation tax-dollars on an unwanted and unneeded project which the voters in Bay County turned down in a ballot referendum.  We also note that this turnpike was never included in the FAA's EIS analysis for environmental impacts.  Also, the airport project is currently under litigation, so no connector roads to it should move forward at this time.

Another major consideration that must be addressed is the environmental impacts that all of the plan's proposals will have on the wetlands, riverine and estuarine systems, and endangered species' habitats throughout the Panhandle. The Panhandle has some of the last fairly clean rivers and estuaries in the state. These resources must be protected - by law and by common sense. Building east-west corridors through large tracts of wetlands will impede ground and surface water flow from north to south. This impediment will cause massive adverse impacts to the near-shore waters of the Gulf of Mexico.

Some of these waters are among the most diverse and productive waters found in North America. St. Andrew Bay is among the six most diverse estuaries in our hemisphere. Apalachicola Bay is an extremely valuable shellfish harvesting resource and is one of the six most biodiverse areas in the Eastern United States. Development opportunities and economic windfalls for a handful of special interests do not outweigh the value of these resources. You only need to look at the impact Alligator Alley in South Florida had on Florida Bay to get a snapshot of what another major thoroughfare through NW Florida's wetlands would do to our estuaries. The cumulative impact of these roads will further degrade these valuable resources.

The routes assume expensive and unrealistic new projects that will require use of conservation lands and induce unsustainable growth and damaging impacts to the environment, like to the important/critical habitat for threatened and endangered animals and plants.  These new turnpikes being proposed are "roads to nowhere" that will open up undeveloped areas of the Panhandle, which will cause more sprawl and degradation of our rivers, springs and estuaries. The entire approach is counter to the direction the state is moving with regard to energy policy, growth policy and environmental protection. We doubt the Legislature considered that you would take on your duties with such grandiosity of vision as to rework the landscapes of the Panhandle with a new network of roads.

It is of grave concern that the Florida Legislature granted the authority the power to issue revenue bonds to finance the proposed projects in the various alternatives. Planning decisions should not be left to transportation planning agencies. Transportation plans should follow, not lead land use plans.

The work you have at hand has the potential to create great harm to the citizens you serve and their resources.    Our suggestion is that you go back to the drawing board.  If you proceed with any of these alternatives your efforts will be hindered by public opposition and likely litigation. You will need both state and federal permits and the federal permits will require, for example, a regional EIS, NEPA review, cumulative and secondary impact analyses, thorough review of practicable alternatives, and endangered species analyses.  

But what's really needed is a careful and thorough regional growth management plan for the area.  By creating a road plan first, you have turned the process on its head, by creating roads, and subsequent growth, that will change the face of the Panhandle, likely in ways that citizens never wanted.  This is not planned growth -- this is road-driven growth.   And it would be a terrible disservice to the citizens if this were to move forward.

Sincerely,

John Hedrick 

Chair, Growth Management/Sprawl Committee, Florida Chapter, Sierra Club and

Chair, Panhandle Citizens Coalition

Cc:  Governor Charlie Crist

       DCA Secretary Thomas Pelham