In keeping with our mission to protect and restore the Black Warrior River and its tributaries, Black Warrior Riverkeeper is in opposition to the proposed Birmingham Northern Beltline interstate project.

            The majority of the project’s footprint is within the Locust Fork subwatershed of the Black Warrior River and the southwestern portion is within the Valley Creek subwatershed.  The northeastern segment of the Northern Beltline is slated to run through a spectacular mountain valley where rare plants and crystal clear water flow beneath Jefferson County’s tallest point, Butler Mountain.  The route will destroy Dry Creek’s pristine headwaters by putting most of it in a box culvert.  This creek is a tributary to Turkey Creek and both supply the only known habitat for the endangered vermilion darter (Etheostoma chermocki), an endemic species of fish.  The route will then travel around Birmingham to the southwest crossing and/or impacting seventeen other significant streams within the Black Warrior River basin.  Dozens of acres of wetlands, which provide habitat, floodwater retention, pollutant filtering, and groundwater recharge are going to be impacted.  Five Mile Creek’s greenway route will be interrupted and the route passes through property protected by the Freshwater Land Trust dangerously close to Bayview Dam on Village Creek.  The route connects with I-59 & I-459 at McCalla, an area already being taxed by development runoff.  The current alignment chosen by ALDOT is the most environmentally damaging of all routes considered.
            The Alabama Department of Transportation’s (ALDOT) track record regarding its handling of erosion control and sediment control best management practices on road construction projects is not pretty.  Most ALDOT work sites contribute tons of sediment to local streams during and after construction.  A few projects of this sort in the Black Warrior basin over the past several years are Corridor X (future I-22), the I-59 expansion between Birmingham and Tuscaloosa, and the Hwy. 69 expansion between Tuscaloosa and Moundville. 
            ALDOT disagrees with the need for more progressive ways of dealing with polluted stormwater runoff and increased velocities from impervious surfaces.  They are content with doing things like they’ve always been done.
            The Environmental Impact Statement (EIS) performed in 1997 is outdated and does not adequately consider impacts to rare, threatened, and endangered species that have been discovered recently and the indirect and cumulative impacts of the project.  ALDOT has moved ahead with re-evaluation of the EIS and right-of-way acquisition on certain segments of the project without properly assessing the entire project’s indirect and cumulative impacts first, segmenting the process and violating the National Environmental Policy Act (NEPA).
            ALDOT’s public involvement process has been totally inadequate.  “Hearings” have been held at inopportune times and there is no forum for public comments to be heard.  The written comment period of ten days following hearings discourages public participation.  We have representation in a “stakeholder” group that was created for this project, yet that process fizzled out and has never yielded any outcome.
            We are unhappy with the proposed route and its impacts to the Black Warrior River watershed, ALDOT’s unwillingness to adopt watershed sensitive practices for the entire project, and ALDOT’s advancement of the project despite inadequate environmental, cultural, and historical analysis of the route and its indirect and cumulative impacts.  

            Black Warrior Riverkeeper has been working with the Cahaba River Society, the Alabama Rivers Alliance, the Friends of the Locust Fork River, Conservation Alabama, and the Southern Environmental Law Center for the past several years to influence ALDOT’s & the Federal Highway Administration’s (FHWA) handling of this proposed road project.  We have been to many meetings with both ALDOT and FHWA.
            We asked for better construction and post construction engineering practices that will minimize polluted stormwater runoff, stream alterations, wetlands destruction, and stream bank scouring due to increased water velocities.  Although ALDOT has agreed to bridge the Self Creek portion of the route instead of using culverts, we don’t believe this concession to the U.S. Army Corps of Engineers satisfies our requests for better overall practices throughout the proposed beltline route.  ALDOT has not agreed to better their practices or try new technologies anywhere else in the project’s route.
            We asked that ALDOT perform a supplementary EIS to address new issues that have cropped up since the original EIS was finalized in 1997.  ALDOT & FHWA have refused to do so.  We requested that ALDOT perform new habitat and species surveys, given that new endangered species have been listed since the EIS was finalized.  ALDOT’s EIS did not adequately asses the project’s cumulative and indirect impacts, so we asked for them to consider doing this.  For certain segments of the route ALDOT is performing re-evaluations of the EIS, looking at indirect and cumulative impacts, and going ahead with right-of-way acquisition.  By doing so piecemeal, ALDOT is violating the NEPA.
            Jefferson County and Birmingham’s air quality is not in attainment with the Clean Air Act in regard to fine particulate matter (PM2.5) and is in and out of attainment with regard to ozone.  We asked ALDOT to demonstrate that this project would not contribute to the problem and/or delay the area’s attainment of standards.
            We are concerned that this project will generate sprawling development that time and time again takes its toll on sensitive watersheds and the streams that drain them.  Headwaters of the Black Warrior and Cahaba river basins will be heavily impacted, harming the region’s water supply and sensitive parts of both watersheds.  We encourage local governments to implement sound land use planning and growth management strategies to minimize damage to sensitive watersheds and encourage smart growth.  Today there are better, more protective ways of developing that encourage sustainable community growth good for all not just a few.  Open space initiatives like greenways, parks, and recreational opportunities are an integral part of a healthy community and should be promoted.
            This project’s impact on the region’s economy has not been adequately addressed.  Who will pay for maintenance, cleaning, and patrol of an additional 55 miles of interstate?  Who will pay for ancillary improvements to artery roads, sewer, water, and other utilities?  Who will pay for maintenance of these improvements?  As populations rise, so do school and emergency service needs; these services will need to be improved.  Have costs to the local environment been factored into the equation?  Will the region’s investment in turn provide adequate economic benefit to local governments and citizens through growth revenues?  Is an investment in regional public transit not a wiser move than a new road?  Our existing roads and infrastructure have maintenance needs that precede the necessity for a new road.
            The stakeholder processes created by ALDOT are inadequate, as they discourage public input and involvement.  We have asked that ALDOT improve their public participation opportunities, yet they have been unwilling to do so.  In order for written comments to be fully considered, ALDOT claims that stakeholders’ must have been to the hearing on that particular segment of the project.  This minimizes those who were unable to be there and gives their comments less credence than those who made it.  There is no just reason for this sort of preferential treatment.
            We continue to be unhappy with ALDOT’s proposed route and their unwillingness to adopt more watershed sensitive practices. 
 

Black Warrior Riverkeeper’s stance in opposition to the proposed Birmingham Northern Beltline interstate project is that of our own and is not a reflection of our work with the above named organizations.