Cape Cod Canal Bridges Study; My Comment on your Draft version of

[Stephen Buckley]

U.S. Army Corps of Engineers

New England District

696 Virginia Road

Concord, MA 01742-2751

(via email, above)

November 15, 2019

To whom it may concern,

The purpose of this message is to respond to your public request for comments on your Draft Major Rehabilitation Evaluation Report (Draft MRER) and Draft Environmental Assessment (Draft EA) for the Cape Cod Canal Highway Bridges, Bourne, Massachusetts.  https://capecodcanalbridgesstudy.com/

My primary comment is that, as an Environmental Engineer and experienced federal reviewer of documents such as these, I can find no discernible scientific or "engineering reasoning contained in the Draft EA that supports the final conclusion that is proposed in the "Finding of No Significant Impact" on Page FONSI-4:

".. that replacement of the Bourne and Sagamore bridges is not a major federal action significantly affecting the quality of the human environment." 

According to the corresponding study by MassDOT covering both the Canal bridges and the connecting roadways on both sides of the Canal, MassDOT estimates that, during the summer season's peak traffic period, the flow of traffic coming onto Cape Cod would increase by 25%, based on the type of new bridge being proposed by the Corps.  https://www.mass.gov/cape-cod-canal-transportation-study

See page 4-92 here for "Peak Hour Volumes, Route 25 Southbound (3545-2825=720 --> +25%):

https://www.mass.gov/doc/chapter-4-4/download

With the current bridges, the population on Cape Cod during peak summer season triples and, in some places like Chatham, it is five times the normal, year-round population.  The current public infrastructure for transportation, water and wastewater treatment, etc. is already beyond peak design, so an expected increase in summer visitors, somewhere on the order of 25% or more, would certainly be considered by any reasonably knowledgeable person as to have an effect on the "human environment" on Cape Cod area that would be "significant".

I recommend that the USACE decide to proceed a "detailed statement" (i.e., Environmental Impact Statement) containing the information needed to make a fully informed decision that will consider all aspects and effects of the proposed action, as required by the regulations issued by the  President's Council on Environmental Quality (CEQ) at 40 CFR 1500-1508.

sincerely,

Stephen Buckley

15 Balfour Lane

Chatham, MA 02633

https://twitter.com/openchatham

P: 508-348-9090

P.S.  Please also consider that the Draft EA (p. EA-100) does not follow logically about "Induced Demand".

WCAI - NPR's Cape & Islands Radio:

Are We Missing an Environmental Opportunity in the Plan to Replace the Canal Bridges?
By EVE ZUCKOFF • OCT 30, 2019

https://www.capeandislands.org/post/are-we-missing-environmental-opportunity-plan-replace-canal-bridges