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Letter | A full EIS is needed on tolling on I-90
WSDOT is doing an Environmental Assessment (EA) and not an Environmental Impact Statement (EIS) at this point. The difference is significant.
An EA and EIS are very different. Under an EA:
1. The project proponent has discretion about public involvement and will conduct only to the extent “practical” (in this case, it is not particularly well conceived, given the massive controversy involved).
2. The level of analysis is brief. EAs are supposed to be decision documents that lead an agency to a “Finding of No Significant Impact” (FONSI) or go back to the drawing board and prepare an EIS. There are no draft EAs — once issued, that’s it.
3. Once the FONSI is issued this November 2013 — it’s done. The project can go to the Legislature in 2014 for action, having completed the environmental review, and implementation in 2016.
4. There is flexibility in developing mitigation measures — but no commitments are required. An EA is really a rather minimalist tool and as currently being conducted minimizes public input and dismisses the depth and breadth of environmental impacts to the community and the region. The EIS process gives both local jurisdictions and the public considerably greater opportunities for input and participation. Under an EIS:
1. The proponent is admitting that there may be significant impact on the human environment.
2. There is formal review/comment period, public hearings are held where the proponent must address comments and concerns raised in writing.
3. The level of analysis is comprehensive and more in-depth. There are drafts to formally comment on, and again these comments must be addressed in writing in the final EIS.
4. Mitigation measures are developed to address significant impacts. These would be documented in a Record of Decision issued by a federal agency, such as FHWA.
Clearly, WSDOT hopes to terminate this assessment with a Finding of Non-Significance or No Significant Impact (FONSI), and it appears that WSDOT has concluded that the proposal likely will not create a significant impact on the human environment. No action I have ever seen proposed would have a more significant and possibly detrimental negative economic impact on this community.
At the WSDOT open house, many people hoped to interact and express concerns and to have a process laid out for public input that was significant and directed to the appropriate decision makers. Neither expectation was met, as there was no public comment period for sharing oral testimony. The format of the meeting effectively muzzled hundreds of people who wanted to be heard. I have concluded that this was in large part the result of WSDOT’s decision to do an Environmental Assessment (EA) rather than commit to a full Environmental Impact Statement (EIS). All of our elected officials should be advocating for completion of a full EIS.