…More importantly, EPA is concerned that for all intents and purposes, the document includes only one "build" alternative.
…certainly the draft EIS could have presented another alternative to meet the project's purpose and need and objectives, whether from the original list of 59 alternatives listed in Appendix S, or a totally new alternative, such as routing all truck traffic to the Queenstown-Lewiston Bridge.
…EPA is also concerned that traffic management systems, congestion pricing during peak hours or preferential passage of NEXUS or FAST users, were not included in the alternatives analysis.
…it is not clear within the draft EIS why the preferred alternative was chosen, rather than a replacement bridge or a bridge to the north.
…The preferred alternative also includes a visitor center, duty free shop and a 477 space parking garage. It is these attributes of the alternative that would result in the highest impacts to the low income residential neighborhood. To minimize these effects, the document should assess alternatives that locate the visitor center elsewhere in the city (e.g., downtown).
Also, we could find no information in the document that supports the need for such a large parking structure at this port of entry…
The draft EIS should contain a discussion of the likelihood of the Canadian government constructing even more additional truck or car booths, and whether more truck or passenger car booths would negate the need for a companion bridge.
Water Ouality
The preferred alternative would cause the permanent loss of up to 1500 square meters of aquatic habitat in the Niagara River. A mitigation plan for this loss of habitat should be included in the final EIS. Also, all reasonably foreseeable construction impacts to water quality should be analyzed, such as the use of jack-up barges and temporary berthing areas for marine equipment.
Wildlife and Aquatic Resources
The document states on page 300, "It is not believed that the siting of a bridge south of the existing Peace Bridge structure would impact the New York State Department of State designated significant habitat known as North Buffalo Harbor." All possible project impacts to this significant habitat should be analyzed before the preparation of the final EIS…
Air Ouality
EPA is concerned about the potential diesel particulate matter (PM) impacts to sensitive subgroups (such as children) during construction. …Appendix C, which describes proposed staging during construction, shows plans to reroute traffic along Porter Avenue to Niagara Street during several stages of the construction. A public school, PS 3, is near the intersection of
Porter and Niagara.…
Cumulative Impacts
The Mid-Peninsula Highway Project is now known as the Niagara-GTA Trade Corridor,
and a Planning and EA Study was released in June 2007. This should be corrected
throughout the document, and included in the cumulative impacts analysis.
