October 15, 2002
Mr. Ed Hassinger
District Engineer
MoDOT - St. Louis Area District
1590 Woodlake Drive
Chesterfield, MO 63017-5712
Dear Mr. Hassinger:
The Clarkson Valley City Council has been discussing with its citizens, MoDOT representatives and citizens of other communities the proposed sound walls along Clarkson Road. As I have indicated in previous discussion, we appreciate the time your people have spent with us in discussing this matter and a formation of a citizens committee. However, as more information is made available, we have concluded this project should be curtailed immediately for the following reasons:
Ø
Under 23 U.S.C. 109(c), federal law mandates that all new highway
construction (which includes sound walls) should "take into account
Clarkson Valley prides itself on its sense of community, scenic green space, and its great aesthetic characteristics. There is a reason that property values in Clarkson Valley are some of the highest in the state of Missouri. The sound wall proposal has not provided any data or documents addressing these concerns, nor any data or documents indicating the nature of the adverse impact of the sound wall on the community.
Ø
Under 23 U.S.C. 109(h), the federal statute mandates that the U.S.
Secretary of Transportation develop regulations for all highway construction
projects in which Federal funds are used in order "to assure that
possible adverse economic, social, and environmental effects relating to any
proposed project on any Federal aid system have been fully considered in
developing such project, and that the final decisions on the project are
made in the best overall public interest taking into consideration the
need for fast, safe and efficient transportation, public services, and the costs
of eliminating or minimizing such adverse effects and the following:
(1)
air, noise, and water pollution;
(2)
destruction or disruption of man-made and natural resources, aesthetic
values, community cohesion and the availability of public facilities and
services;
(3)
adverse employment effects, and tax and property value losses;
(4)
injurious displacement of people, business and farms; and
(5)
disruption of desirable community and regional growth. (emphasis
added)
Once again, the information from MoDOT appears that its engineers have only considered two elements: 1) decibel level and 2) "affected" homeowners' request for a sound wall. Clarkson Valley requests that MoDOT address in writing the review process concerning the destruction of Clarkson Valley's "man-made and natural resources, aesthetic values, community cohesion" due to the proposed sound walls and the data that supports its apparent conclusion "that (the) possible adverse economic, social, and environmental effects relating to (the sound wall project) have been fully considered in developing such project, and that the MoDOT's "final decisions on the project have been made in the best overall public interest." This information is required under Federal law.
The federal highway representative stated in a recent town hall meeting (09-24-02) "this meeting satisfies this requirement". It is inconceivable that a town hall meeting could satisfy this criterion. A decision to move forward must be based on empirical data.
Ø The sound study has not been confirmed by on-site readings. We were told an aerial photo into a computer model was the approach used in this case. Thus far we are told there will be no verification of the results.
Ø The allocation of costs $790,000 far exceeds the MoDOT policy of $30,000 per home. There are 21 homes included.
Ø No consideration has been given to the affect of those homes at the end of the walls - experience tells us their noise level will increase without a readily available solution.
Ø We believe an environmental impact study is necessary; using a 1970 version is not acceptable.
Ø Under Chapter 23 Code of Federal Regulations Section 772.9 Analysis of traffic noise impacts and abatement measures, MoDOT is required to "determine and analyze expected traffic noise impacts and alternative noise abatement measures to mitigate these impacts, giving weight to the benefits and cost of abatement, and to the overall social, economic and environmental effects." We have had discussions about noise abatement; however, no definitive information has been received on what, if any alternative measures (other than sound walls) were analyzed and why they were discarded.
The City Officials at Clarkson Valley have not seen any data from MoDOT document that:
Ø
We believe these dollars could be utilized in a more effective
manner in servicing the transportation needs of Missouri's citizens.
Perhaps the information we have requested can provide some additional details for further discussions. Therefore, we request that work on the project be stopped until these concerns can be addressed and the requested information can be obtained.
Sincerely,
CITY OF
CLARKSON VALLEY
Scott Douglass
Mayor
cc:
Sen. Christopher "Kit" Bond
Sen. Jean Carnahan
Governor Bob Holden
Congressman Todd Akin, U.S. House of
Representatives
Sen. John Loudon, State Senator
Honorable Neal St. Onge, State
Representative
Honorable George "Buzz"
Westfall
Mr. Greg Quinn, County Councilman
Honorable Robert E. Jones, Mayor,
City of Ballwin
Honorable John Nations, Mayor, City
of Chesterfield
Honorable Jeffrey Khoury, Mayor,
City of Ellisville
Duane S. Michie, MoDOT Commission
Member
James B. Anderson, MoDOT Commission
Member
W. L. "Barry" Orscheln,
MoDOT Commission Member
Bill McKenna, MoDOT Commission
Member
Ollie W. Gates, MoDOT Commission
Member
Marge B. Schramm, MoDOT Commission
Member
Les Sterman, East-West Gateway
Coordinating Council