To make your voice be heard, send your comments to:

Mr. Brian C. Davis, Division Engineer
Alabama Department of Environmental Management
P.O. Box 2745
Birmingham, AL 35202-2745
ATTN: Mrs. Sandra F. P. Bonner

Sample comments to use and adapt:

Re: Comments on Project Number: HPP-1602(532), Birmingham Northern Beltline from East of SR-75 to East of CR-30 (Old Springville Road):

Dear Mr. Davis:

I am submitting the following comments concerning the segment of the proposed Birmingham Northern Beltline from East of SR-75 to East of CR-30 (Old Springville Road). This portion of the project will pass through a unique and ecologically diverse portion of Jefferson County. In the middle of this segment is Red Mountain, and from the mountain clear headwater tributaries flow into the Black Warrior and Cahaba Rivers. Areas such as this are vital to the health of watersheds and communities, so I urge you to reconsider the path of the road.

To the East of Palmerdale where Clay-Palmerdale Rd. intersects with Cedar Mountain Rd., the beltline will cross Dry Creek just upstream of a large lake. This lake will undoubtedly face negative impacts caused by sediment runoff from construction of the road. Indeed, I have yet to see a road being constructed by the Alabama Department of Transportation (ALDOT) devoid of serious erosion and sedimentation issues. The road will then all but destroy Dry Creek to its headwaters at the base of Butler Mountain, the highest point in Jefferson County at 1,445 feet. This headwater reach of Dry Creek is as beautiful a stretch of a mountain stream as I’ve seen in the Black Warrior basin. Rock outcroppings form caves and bluffs, the ground is scattered with flowers such as trout lilies and Virginia bluebells, the rare Alabama Snowreath occurs in relative abundance, trees of countless species dot the landscape, and last but not least the creek itself runs crystal clear supporting all sorts of riparian plants.

Dry Creek is an important tributary of Turkey Creek and both are home to a federally endangered fish, the vermilion darter (Etheostoma chermocki). This beautiful fish needs high quality water, and the greatest threats to its survival are degradation of water quality and habitat from sediment and other pollutants. These creeks are two of only a few places that this fish lives in Alabama. The vermilion darter is endemic to the Black Warrior River basin, living only in the Turkey Creek watershed and nowhere else in the world. Turkey Creek is a tributary of the Locust Fork of the Black Warrior River.

Once the beltline paves over the headwaters of Dry Creek, the road will cross over Red Mountain into the Cahaba River watershed in Clay. Not only will this portion of the road plow through numerous headwater tributaries of the Cahaba, but also it will cross the main stem of its uppermost reach. This is a major mistake that will undoubtedly take its toll on this already taxed drinking water supply.

I would ask ALDOT to use more protective designs for the road, including bridging streams rather than using culverts, stormwater conveyance that does not promote high runoff velocities and downstream erosion, slighter slope gradients that promote stability and discourage collapse, and other context sensitive designs. I would ask ALDOT to go farther than just using the required best management practices (BMPs), which often do not adequately prevent erosion and sedimentation. There are many new and innovative sediment and erosion control techniques out there, but ALDOT has been slow to embrace them. The quickest and cheapest way, just because it’s the way things have always been, does not necessarily get the job done. I would ask ALDOT to try something new and believe they will find many other states are getting the job done more efficiently with less damage to local streams and habitat. The damage done to streams where culverts are used or where wetlands are filled and paved over requires mitigation and I want to know what ALDOT’s plans are in this arena. I would ask ALDOT to consider the post construction impacts of the project on water quality and have offered resources that can help roads leave less of a scar on our environment. I would ask ALDOT to document efforts to improve their practices.

Of concern are pieces of this puzzle that are missing. The re-evaluation of the project’s Environmental Impact Statement is incomplete at this point, lacking information on historic architectural resources, potential hazardous material sites, endangered species, and potential wetlands sites, which are all “currently under study.” In the materials provided it is noted that only one archaeological site was found, yet I have a hard time believing this considering the amount of Native American activity that has occurred throughout the Black Warrior River basin. Additionally, the indirect and cumulative impacts analysis is incomplete, not to mention that these significant impacts were wholly omitted from the original EIS. If the EIS re-evaluation is not to be submitted and reviewed by officials until mid to late 2007, how am I expected to have enough information to adequately address concerns with this segment?

Since the primary purpose for this road is for economic growth, the question of need must be asked. We have a tremendous opportunity to revitalize existing infrastructure, communities, and brownfields rather than develop undeveloped land and contribute to sprawl. Will the building of this road truly benefit local communities, or will it take away the charm that makes them what they are? A concern arises around post-project development and what affect it will have on this sensitive area. Typically interstates and associated interchanges attract big commercial and industrial development and large residential subdivisions are soon to follow. From infrastructure pressure on roads, utilities, rescue services, and the local budget in general this sort of development is not sustainable in the long run. So, if the main driver for this road is development, then the question is no longer do we need this road? The question is do we need this sort of development? There are other ways for communities to revitalize their economies. The most important driver is quality of life.

Nelson Brooke
Black Warrior RIVERKEEPER®
712 37th Street South
Birmingham, AL 35222
p.(205)458-0095
f.(205)458-0094
www.blackwarriorriver.org