Circ EIS Comments Filed by Environmental Organizations

Comments filed today on the Circ/Williston Draft EIS by the Conservation Law Foundation; Friends of the Earth; Vermont Sierra Club; Vermont Natural Resources Council; Vermont Public Interest Research Group; Smart Growth Vermont; Vermont Smart Growth Collaborative.

Note from Wayne Senville: I'm setting out below excerpts from the start of the comments filed. I'd recommend you download the full comments, and if you want to see an excellent in-depth analysis of the major flaws in the Draft EIS, also download the technical analysis.

• Download the full comments (17 pages; pdf file)
• Download the technical analysis supporting the comments (27 pages; pdf file)

Excerpted from the beginning of the comments:

Based on our review we find:

• The DEIS violates crucial provisions of the National Environmental Policy Act (NEPA).
• A 404 Permit cannot be issued for the project as presented.
• The DEIS fails to perform the requisite analyses or implement the proper procedures pursuant to federal law, including illegally segmenting review of the overall Circ-Williston project.

In light of the following comments, the identified deficiencies in the environmental analysis should be corrected before issuing a final Environmental Impact Statement (FEIS) and selecting a preferred alternative.

Based on the analysis in the DEIS, none of the Circ A/B alternatives should be selected as the preferred alternative.

• The DEIS improperly excluded alternatives, including increased transit and transportation demand management (TDM) as well as rail projects that would be able to meet Chittenden County’s needs to move people and goods safely and efficiently at a lower cost and with less pollution and fewer environmental impacts than the alternatives considered.
• The DEIS improperly changed the purpose and need after eliminating alternatives from consideration.
• The analysis in the DEIS demonstrates that alternatives other than building within the Circ A/B Corridor would meet Chittenden County’s transportation needs at a lower cost and with fewer environmental impacts.

Note from Wayne Senville: my thanks to Vermont's environmental community for the time and effort that went into analyzing the morass of information (and mis-information) in the draft EIS. Also, thanks to those of you who took the time to file individual comments!