this flawed and unwise project

Note: this comment on the Circ EIS was filed by Bruce S. Post of Essex Junction, who served for years on the staff of the late Senator Robert T. Stafford.

Dear Mr. Sikora [of the Federal Highway Admistration]:

My name is Bruce S. Post, and from 1981 to 1985 and from 1986 to 1988, I served on the staff of the late U.S. Senator Robert T. Stafford, who secured the original federal seed money for the Chittenden County Circumferential Highway "demonstration project." I was first a professional staff member of the U.S. Senate Education Subcommittee, chaired by Sen. Stafford, and later I was his State Director here in Vermont. As such, I am very familiar with the rationale for his sponsorship of the original circ appropriation in 1982 and with his later thinking on his action. While many others have made eloquent comments on the EIS, I will add what I can from a perspective of one of Sen. Stafford's closest aides.

It has been circulated among a close circle of his former staff that Senator Stafford considered the appropriation of these funds as perhaps "the biggest mistake of his political career."  While I do not know the exact justification for his regret, I will put it in the context of his career so that we can reasonably and confidently surmise why he may have felt this way:

first, as you may know, the demonstration funds (better known today as "earmarks" or "pork") were intended to demonstrate how quickly a highway could be built with federal, state and local cooperation. By any measure, the circ proposal is an utter failure in this regard; to the contrary, it has demonstrated the persistent shelf life of a bad idea. Senator Stafford himself, when he took the first ceremonial ride on the Essex section, commented to the press, "I thought I would never live to see this day." To those unfamiliar with Senator Stafford's wry and often self-deprecating humor, they might think that he was discussing his health. To those of us who knew him well, we recognize the understated but unmistakable inference that the circ project certainly had failed to measure up to the marketing promises of its supporters in Vermont;

second, Senator Stafford, who died last December, left an estimable environmental legacy: a contributor to the federal Clean Air Act, a visionary behind the Superfund law and a sponsor of many other pieces of environmental legislation. As we traveled together through the hills of Vermont, he often viewed with sadness the increasing haze on our horizons. He distinguished for me between wet deposition sulfur dioxide (acid rain) and dry deposition sulfur dioxide (the summertime haze formed by the undesirable combination of heat and high humidity levels with the imported air pollution from the high sulfur coalburning plants of the Midwest). He commented often on the irony about ozone: a beneficial element in our upper atmosphere but a danger at ground level.  As the federal EPA website itself states: Ozone (O3) is a gas composed of three oxygen atoms. It is not usually emitted directly into the air, but at ground-level is created by a chemical reaction between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Ozone has the same chemical structure whether it occurs miles above the earth or at ground-level and can be "good" or "bad," depending on its location in the atmosphere.

In the earth's lower atmosphere, ground-level ozone is considered "bad." Motor vehicle exhaust and industrial emissions, gasoline vapors, and chemical solvents as well as natural sources emit NOx and VOC that help form ozone. Ground-level ozone is the primary constituent of smog. Sunlight and hot weather cause ground-level ozone to form in harmful concentrations in the air. As a result, it is known as a summertime air pollutant. Many urban areas tend to have high levels of "bad" ozone, but even rural areas are also subject to increased ozone levels because wind carries ozone and pollutants that form it hundreds of miles away from their original sources.

Senator Stafford was troubled by these facts and by their visual evidence in Vermont's Green Mountains. Because automobile exhaust is such a localized factor, I am certain that this wieghed heavily on him as he considered his original involvement with the circ. I personally have written in the local press that the circumferential highway is a "growth bomb." Yet, recalling now Senator Stafford's personal lectures about the threat of ground level ozone and knowing that automobile-generated carbon emissions having been the fastest increasing carbon pollution in Vermont, I am certain Bob Stafford would question not only his early role but also the sanity of continuing with this flawed and unwise project. I can imagine him saying, "If the circ were a horse, I'd put it out of its misery"; and

Finally, he would also observe that the promises of local circ boosters to include bike paths and other pro-pedestrian services were the first to be jettisoned as the costs of this project soared.

There is not much more that I can add to the volumes of testimony against the circ, but I conclude with these personal thoughts:

I am not a NIMBY (not in my back yard). Why? The circ already is in my back yard. As a resident of Essex, I can walk from my back door, through the Town Forest and to the circ without seeing another house or crossing another road. The destruction of habitat and walking trails that once linked neighborhoods is evident. I hope we do not visit such destruction on other areas of Chittenden County by completing this road to ruin; and

I have traveled the length of the entire proposed route with David Pinkham, when he was the director of the Circumferential Highway District. Mr. Pinkham personally related how one developer in Essex held up the circ for years because he feared it would decrease property values of additions to his development. Yet, in later years, this developer, having made his peace with the circ, proposed to our local planning commission that we remove the limited access designation, that we increase curb cuts and that we scale back scenic setbacks and greenbelts. To me, this is evidence that such a project is a seductive magnet for local development pressure and increased highway traffic. I miss Senator Stafford. He was my employer, my teacher and, most of all, my friend. I value his impact on my life and the lessons he taught me.  I cannot now speak for him as I once did, but I sincerely and earnestly appeal: Do not sully the undeniable environmental legacy of U.S. Senator Robert T. Stafford by continuing to support what has become a policy embarassment and a public health nuisance.

Sincerely,

Bruce S. Post
Essex Junction, Vermont 05452