On May 30, 2024 the ReThink 17 coalition submitted comments on the Route 17 Notice of Intent. In our comments, Mountainkeeper partnered with leaders across the region and the state to call on decisionmakers to a purpose and need statement and project that provides a more comprehensive vision for the corridor.
In particular, and in addition to providing safe, accessible and reliable transportation, this vision can: connect our communities, support smart, sustainable growth, meet climate mandates under the Climate Leadership and Community Protection Act (CLCPA) and Justice 40 initiatives, and encourage economic growth in the region.
This overall vision is also supported by specific recommendations. Click here to read more.
1. The lead agencies must provide context behind the purpose and need statement, including the benefit to communities and rationale for interstate designation.
2. The lead agencies should develop an expansive purpose and need statement aligned with the corridor vision/goals outlined in the 2021 PEL study.
3. The lead agencies must explain upfront capital costs and ongoing maintenance costs for each identified project concept.
4. The project should prioritize accessibility, safety and optimize the full range of community transportation needs.
5. The lead agencies should propose a more comprehensive set of alternatives that: aim to reduce vehicle miles traveled (VMT), consider impact on local roads, consider non-motorized options, and consider mitigating greenhouse gas emissions (GHGs) and prevent disproportionate burdens in disadvantaged communities (DACs).
6. The lead agencies’ analysis of impacts, including climate and environmental justice impacts, must go further than contemplated in the NOI. Additionally, the lead agencies should work with local groups and experts with local knowledge of the project area to better understand these impacts.
7. The landmark New York State Climate Leadership and Community Protection Act (CLCPA) must be fully incorporated into project planning and decision making, especially since its dual mandate applies to NYSDOT, primarily through Section 7.
8. NYSDOT must evaluate the GHG emissions intensity of the proposed project and each alternative. This evaluation must also consider an analysis of the proposed project and each alternative’s consistency with the Climate Action Council’s Scoping Plan.
9. In considering the proposed project and each alternative, NYSDOT must abide by CLCPA Section 7(3)’s strict requirement to avoid “disproportionate” burdens in DACs when choosing between project alternatives. This includes avoiding air pollution burdens and GHG emissions and co-pollutants, while also prioritizing GHG emissions and co-pollutant reductions within DACs.
10. The lead agencies must develop more accessible and equitable means to engage the public throughout the NEPA process, including hosting public information sessions in a
variety of locations and formats, such as virtual information sessions and information sessions hosted in collaboration with stakeholders and municipalities along the Route 17 corridor. Prior, timely notice of these opportunities for public engagement must be considered as well.
