This paragraph sums it up:
The project’s stated purpose in the EA is “economic development,” as part of the Governor’s Road Improvement Program created in the 1980s. See EA at 4. The NEPA regulations promulgated by the Council on Environmental Quality (“CEQ”) require agencies to examine the indirect impacts of projects — those growth-inducing impacts caused by a project, such as changes in land use and development patterns. 40 C.F.R. Â§ 1508.8(b). Yet over and over, when purporting to examine the project’s potential for indirect impacts on various natural resources, the EA repeats, “The proposed project is not expected to precipitate substantial development along the corridor.”
Other questions include, why not use a narrower median? Why not leave trees on the median?
Below is the full text of the letter Continue reading