WBFC considers the DEIS legally faulty and incomplete for many reasons, including:
– Destruction and disturbance of State of Maryland and National parklands with wetlands, including but not limited to several miles of Rock Creek Regional Park (including moving substantial stretches of Rock Creek), and ca. 80 acres of the Chesapeake & Ohio National Historical Park (CONHP), including ca. 5 acres of the 12 acre Plummers Island and moving “Rock Run”.
– The destruction of “Rock Run Culvert” in building the American Legion Bridge violates the integrity of Plummers Island (CONHP, Montgomery Co., Maryland).
– Lack of understanding or recognition of the value of the extensive historical and ongoing biological research on Plummers Island and the WBFC’s 120 years of contributions and commitments to that. Records of many rare plants, animals and habitats from the Island were not considered.
– Lack of Due Diligence on study of impacts on Plummers Island’s wetlands and rare plant communities, and rare plant and animal species (the evaluation of the organisms on the Island was apparently based on one summertime visit to the head of the Island in 2019).
– Lack of alternatives to condemning part of Plummers Island for the ALB proposed project.
– Lack of consideration of the impact of the Covid-19 epidemic on present and future transportation loads and patterns (many folks are teleworking and attending virtual meetings). With peak traffic flows down due to changed behavior patterns resulting from Covid-19, toll lanes will be unlikely to provide revenue streams of sufficient reward to P3 contractors, likely leaving taxpayers on the hook for billions of dollars.
– Lack of forward thinking on Climate Change (only more cars powered by petrol).
– Lack of accepted Build options with mass transportation options (trains, light rail, monorail, etc.)
– Because the DEIS’s analysis is incomplete, it is impossible for the concerned Agencies to assess, and the public to comment on, the proposed project’s impacts. The Agencies cannot wait until a final EIS is complete to analyze the project’s full impacts, as it will then be too late for the public to meaningfully comment on them and for the Agencies to consider the public’s comments and choose the alternative that best alleviates the impacts based on this information. We respectfully request that the Agencies conduct a supplemental EIS to provide the public the ability to meaningfully review and comment on the impacts before a final EIS is produced.