PennDOT's Bayfront Plan: Erie Deserves Something Better
Environmental assessment necessary before construction
The National Environmental Protection Act of 1969 (NEPA) requires federally funded infrastructure projects to complete an environmental assessment (EA) to examine the project's impact on residents and the environment.
EAs are a lot of work. Because of "simple" maintenance projects like the refilling of potholes, a "categorical exclusion" option was created. If a project isn't controversial and will have minimal environmental impact, agencies can skip doing the EA with a categorical exclusion.
PennDOT applied to the Federal Highway Association (FHWA) claiming their $100M project would not harm the environment and did not have significant opposition. Guided by PennDOT's statements, FHWA granted a categorical exclusion.
Unreliable Administrative Record
In December 2020, the environmental law firm Earthjustice filed a lawsuit seeking an EA on behalf of PennFuture and the Erie NAACP.. PennDOT and the FHWA were required to submit documents justifying the approved categorical exclusion. Months after certifying that the record was complete, the FHWA altered "crucial data" regarding the categorical exclusion. In January 2022, the FHWA changed their records again. The FHWA's two false certifications that their record was complete casts doubt on the integrity of their EA approval process. In the only two other similar cases, those parties responsible for changing the administrative record after certifying their contents did not find themselves in favorable rulings.
PennDOT should be ordered to cease construction and complete the EA.
ED. NOTE: This piece was written prior to Earthjustice asking for a preliminary injuction in the Erie Bayfront Parkway case.
Visitors to PennDOT's Open House
The August 2022 PennDOT Open House was attended by a young couple named Dylan and Jamie, who recently bought a home above the Bayfront. They are hoping for the "least amount of traffic possible." Jamie (pondering an eventual child and concerned about PennDOT's plans) commented, "I want to live in a city, not on a highway — I couldn't imagine pushing a stroller over the highway to get to the water."
Trained as an orientation and mobility specialist, Freda Tepfer identified a lack of protection for pedestrians, bicyclists, and seeing, hearing, and mobility-impaired residents. Tepfer urged four-way stops at Holland and at East Second and Front streets.
Roland Slade of Connect Urban Erie stated "as a citizen walking the area — the Holland Street pedestrian bridge" plan — with their lack of streetlamps — is a concern. In addition, he says that given the challenge of snow removal, forcing people to an elevated route doesn't seem "practical or safe."
Drawings Camouflage Functional Shortcomings
PennDOT's illustrations don't clarify the following:
Removal of the Holland Street sidewalk and elimination of at-grade, north-south pedestrian and bike connections
Installation of many large highway signs that will be necessary to guide drivers through the roundabouts, underpass, ramps, and exits
Doubling of traffic by attracting more drivers cutting through Erie
Increasing noise and pollutants that will reduce the health and quality of life of residents and negatively impact the environment
Installation of guard rails and fencing to prevent pedestrians from taking direct routes to their destinations
Additional distances pedestrians will be forced to walk out of their way
Elimination of library parking lot spaces
Vulnerability of pedestrians and bicyclists with no right-of-way protection from drivers spinning off the roundabouts
Connect Urban Erie (CUE) President Adam Trott commented, "PennDOT's design updates do nothing to address the serious design concerns we expressed since the beginning of their proposed expansion."
PennDOT's design is pursuing a Bayfront where vehicles never have to stop. Uninterrupted flowing traffic is ideal for an interstate but a disaster for downtown.
21st Century Redlining
Redlining is a now-outlawed federal program that designated disinvestment in non-Caucasian urban neighborhoods across the U.S.
Twenty years ago, PennDOT's $180M Bayfront Connector (Route 290) divided east side neighborhoods for the convenience of drivers heading to the waterfront.
Since the demolition of the McBride Viaduct in 2019, residents have been forced to walk and bike along Route 290. If PennDOT's Bayfront plan is completed, they will be enduring even more traffic along their highway walk to school, work, etc.
Demolishing the viaduct and expanding an arterial highway on the Bayfront are examples of Erie's 21st century redlining. Both are harmful to people and the environment — and are missed opportunities to revitalize the city.
12th Street Option
Unnecessary through-city traffic should be lured to an improved 12th Street including overpasses at several locations including State, German, and Parade streets and East Avenue.
Skip the Highway, Build a Boulevard
At the August 2022 Community Town Hall, concerned citizens convened to discuss the Bayfront. Ben Crowther of America Walks and Tony Dutzik of Frontier Group reported that around the world, cities are getting rid of or covering over urban highways and repairing the harm caused by severing communities. Encouragingly, the federal government is providing $1 billion in funding for such infrastructure work through the Reconnecting Communities Pilot Program and another $3 billion+ from the new Inflation Reduction Act's Neighborhood Access and Equity Grants – "a new program that aims to rework overbuilt arterial roads" like the Bayfront.
Erie should take advantage of this opportunity and fix the current proposal.
When PennDOT has completed its Bayfront project, will an eight or 80-year-old be able to walk to the waterfront easily, safely, and joyfully?
To get to "yes" Erie needs to skip the highway and build a Bayfront Boulevard with frequent at-grade, north-south pedestrian and bike connections.
Connect Urban Erie President Adam Trott commented "informed by an EA, PennDOT could still reallocate the targeted funds to create a Bayfront Boulevard instead of an arterial highway." A boulevard will not only "protect water, air, sound level" but will "enhance public health" and "foster a thriving, sustainable urban waterfront better connected to the city that will benefit all residents and stakeholders, including developers."
A stunning urban Bayfront Boulevard that connects residents to the waterfront will attract tourists (and new residents) while protecting the environment and helping to foster a sustainable, thriving economy.
Another Considering the City essay by Lisa Austin, CIVITAS. Austin can be reached at firstname.lastname@example.org