Lucinda Hebert’s and Steve Buck’s op-ed piece (BDN, April 19) on the Aroostook County Transportation Study cannot go unanswered. I am one of the leaders of the group Hebert and Buck refer to as “a handful of vocal dissidents” spreading “discord, disagreement and dissent” through “erroneous statements” and “espousing falsehoods about the entire process.”

We “dissidents” now number in the several hundreds, and quite possibly in the thousands. Our message is summarized in this piece and I would respectfully request that Buck, Hebert or the Maine Department of Transportation specifically point out the errors and falsehoods in our message. In fact, that is exactly what we have been begging for the last seven months: real answers to our questions.

The National Environmental Policy Act (NEPA) and the regulations developed pursuant to it require an environmental impact statement (EIS or DEIS) to be developed and sets forth procedures to accomplish that. Here is what just a few of those regulations say:

“NEPA procedures must insure that environmental information is available to public officials and citizens before decisions are made and before actions are taken. The information must be of high quality.”

Agencies must: “Use the NEPA process to identify and assess reasonable alternatives to proposed actions that will avoid or minimize adverse effects of these actions upon the quality of the human environment.”

“Alternatives including the proposed action.” “This section is the heart of the environmental impact statement. Based on the information and analysis presented in the sections on the Affected Environment (1502.15) and the Environmental Consequences (1502.16), it should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public. In this section agencies shall:

(a) Rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly

discuss the reasons for their having been eliminated.

(b) Devote substantial treatment to each alternative considered in detail including the proposed action so

that reviewers may evaluate their comparative merits.

(c) Include reasonable alternatives not within the jurisdiction of the

lead agency.”

“Until an agency issues a record of decision as provided in 1505.2 (except as provided in paragraph (c) of this section), no action concerning the proposal shall be taken which would: (1) Have an adverse environmental impact; or (2) Limit the choice of reasonable alternatives.”

In the DEIS published in February 2002, 40 corridors were initially studied and were weeded down to thirteen, which were numbered A through M. All 13 corridors were subjected to a screening analysis utilizing 17 factors relating to either transportation infrastructure improvement or economic potential benefits. For example: Factor 2 is titled “Enhance the marketability of Aroostook County’s existing and potential economic assets.” Factor 6 is titled “Enhance the reliability of Aroostook County’s transportation system.” All 13 corridors were ranked and indexed according to their performance in the seventeen factors. Eight corridors were eliminated from further study as failing to meet the purpose and need for the project. This left corridors A, B, H, J and K for more detailed study of the environmental impacts to both the natural environment and the human environment. None of the other corridors were subjected to this scrutiny.

Without any detailed explanation, corridors A, B and J were eliminated from further consideration and Composite Corridors 1 and 2 were added to H and K for public comment in March of 2002. H and K became Hm and Km. Remember that many portions of CC1 and 2 were never studied in detail, as required by the NEPA process.

Construction costs in year 2000 dollars in the DEIS are as follows. CC2 costs $634 million, CC1 costs $599.5 million, Hm costs $439 million, and Km costs $426.6 million.

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The Maine Department of Transportation will likely tell you that, based on the Environmental Protection Agency’s formal comments on the DEIS, corridors Hm, Km, and CC1 would not be environmentally permittable. The DOT has said this to the Public Advisory Committee (PAC) and the public on numerous occasions. Consider the following comments from the EPA to the DOT:

“The DEIS contains enough information to suggest that Corridors Hm, Km or Composite Corridor 2 may be unsatisfactory from the standpoint of environmental quality and that they would be likely to receive an adverse rating if they were advanced through the NEPA process.”

“Because the final corridor is not specified, and alternatives within that corridor are not yet developed, however, we are rating the overall project “Environmental Objections-Insufficient Information.”

“The DEIS defines two Composite Corridors 1 and 2 without providing an explanation of the decisions ultimately used to define these corridors. Composite Corridor 2 consists of corridors H, H/L, and D, E, I in the southern, central, and northern sections, respectively. However, the decisions used to select these corridors also are not clear. Please clarify the basis for defining these two Composite Corridors, and explain why other potential composite corridors were not defined or considered.”

Public officials and organizations from the County commented on their preference of corridors at the public hearings in March 2002 as follows: Corridor Hm was preferred by the Aroostook Municipal Association, Castle Hill, Chapman, Mapleton and Presque Isle. Mapleton and Presque Isle also commented that they would prefer a west bypass of Presque Isle. Corridor Km was preferred by LEAD, Caribou, Caribou Chamber of Commerce, Houlton Chamber of Commerce, Loring Development Authority, Madawaska, and St. Agatha. Composite 1 was preferred by Fort Kent and Van Buren, with Aroostook Municipal Association, Houlton Chamber of Commerce and St. Agatha commenting that they could also support this corridor. No town or organization commented that their preference would be Composite 2.

So, what does MDOT select in December of 2002 as the single corridor to study in the Final EIS? They selected Composite Corridor 2 with a bypass east of Presque Isle. With absolutely no detailed documentation to support their decision nor the study of alternatives as required by the NEPA process.

It gets worse. Consider what CC2 is going to do to our good neighbors on Route 161. Between the Caribou Country Club and Daigle, there are 195 houses directly impacted by the new road (a number of these are of historic significance). There are also 18 businesses, and accommodations will have to be made for 10 camp roads, 18 woods and farm roads, 14 paved roads, 5 bridges, 2 cemeteries, innumerable ATV and snowmobile trails, wetlands, deer yards, farms. Now that’s environmental impact! Just between Caribou and Daigle.

What is even worse, the DOT selected the current Daigle to Madawaska route without any form of impact study whatsoever. Where was the “Reasonable Notice” and “Public Comment” period on that one? As required by Title 23, Code of Federal Regulations, Part 771, Section 111?

The public has a right to know if there are alternatives that perform better than CC2. That is what we have been asking for these last seven months, and that is what we are currently demanding of this so-called public process.

Paul A. Cyr is a resident of Madawaska.