The Mobile Metropolitan Planning Organization (MPO) proposed a Draft Amendment to the Envision 2045 Long Range Transportation Plan (LRTP) which would allow for selective tolling along I-10 to fund a bridge across the Mobile River.

The Mobile MPO sets the agenda for spending all federal surface transportation dollars in urban Mobile County. Together with the Eastern Shore MPO, the combined MPO allocations account for the vast majority of federal surface transportation spending in urban South Alabama.

In response to the proposed Draft Amendment, several local, regional, and national groups have joined to produce a fact sheet about the risks to Africatown of tolling of any nature on I-10 to pay for a new bridge over the Mobile River, even a truck-only toll bridge.

So what does the plan for a truck-only I-10 toll bridge mean for the Africatown community?

• Major Truck Traffic
• Toxic Air Pollution
• Health and Safety Risks
• Limited Access to Historic Sites
• Environmental Racism

Check out the fact sheet for more details on each of these points and share widely to anyone who might be interested!

The Mobile MPO will meet in-person on June 2, 2021 at 10am at the South Alabama Regional Planning Commission Board Room at the GM&O Building to conduct a regular business meeting with the pro-tolling Draft Amendment to its LRTP included on its agenda.

Thank you, Deep South Center for Environmental Justice, CHESS – Clean Healthy Educated Safe & Sustainable, Mobile County Training School Alumni Association, Mobile Alabama NAACP, Union of Concerned Scientists, and the HBCU-CBO Gulf Coast Equity Consortium.

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Also, Ramsey Sprague, MEJAC President and Chair of the Mobile AL NAACP Environmental and Climate Justice Committee, submitted the following Public Comment to the Mobile MPO regarding the Draft Amendment. The comments were encouraged by Mobile MPO staff to be submitted with annotations “(x/10)” due to the 1,000 character limit given for the Mobile MPO electronic Public Comment portal:

“(1/10) My name is Ramsey Sprague. I am the President of the Mobile Environmental Justice Action Coalition and the Chair of the Environmental and Climate Justice Committee of the Mobile NAACP. I live at [Mobile, Alabama].

These comments harken to fairly recent transportation decisions that have had profoundly negative impacts in the Africatown community.

These comments are also a reminder to the Mobile MPO of the May 2, 2019 Public Comment submitted by numerous community organizations representing Africatown community groups, historic churches, as well as regional advocacy organizations when the last I-10 Toll Bridge was proposed, because community conditions described in that letter have not changed. [Those comments are available to read here (https://www.mejacoalition.org/2019/05/07/i10bridgecomment/)]

(2/10) The entities who signed that Public Comment include (Africatown~C.H.E.S.S.), Yorktown Missionary Baptist Church, Union Missionary Baptist Church, the Center for Fair Housing, the Mobile County Training High School Alumni Association, the Mobile AL NAACP, the Sierra Club’s Mobile Bay Group, and the Mobile Environmental Justice Action Coalition.

We stand united against any proposed tolling along the I-10 corridor until engaged Africatown stakeholders can review a commitment to a contractual Community Benefits Agreement that requires a portion of toll revenue be reinvested into communities directly impacted by inevitable toll aversion routes like Africatown Blvd, whether the toll applies to all vehicles or just to heavy trucks.

Cogent and sound rationales for our concerns as well as direction with respect to what we wanted to see in a potential transportation plan that we could support were provided.

We provided a list of what we wished to see that read as follows:

(3/10) • Timed traffic lights at the intersections of Africatown Blvd with both Magazine St and Robert’s Cutoff Rd;
• Responsive pedestrian cross walks at the intersections of Africatown Blvd with both Magazine St and Robert’s Cutoff Rd;
• The speed limit on Africatown Blvd lowered to 35 mph;
• A speed caution light at the crest of the Africatown Bridge warning of the traffic light at the bridge’s base;
• A rumble strip on the bridge’s descent to encourage westbound bridge traffic to slow in its approach to historic Africatown;
• Installation of appropriate air quality monitors along the traffic corridor;
• A long-term traffic study that documents existing and future Hazardous Cargo traffic flow along Africatown Blvd;
• A commitment in the form of a contractual Community Benefits Agreement requiring a portion of toll revenue be reinvested into the communities directly impacted by potential I-10 Toll Bridge and Tunnel traffic flows and toll avoidance routes like Africatown.

(4/10) Reviewing the LRTP literature, there are several outstanding concerns that must be addressed.

First, despite having previously submitted those clear and constructive comment, none of the signatory organizations were directly solicited to participate in any discussions related to the development of the LRTP Draft Amendment to test for consensus or feedback.

Toll aversion traffic was previously projected to cause an almost immediate and certainly alarming spike in traffic along Africatown Blvd to levels the community wouldn’t otherwise expect until the 2040s in a scenario where the I-10 Toll Bridge was not built.

While the type of traffic proposed to be tolled has shifted, there has been no satisfactory documentation to directly address potential toll aversion impacts to Africatown. With neither heavy trucks nor hazardous cargo proposed to be barred from the Africatown Bridge but otherwise tolled, clear communication around toll aversion impacts is necessary.

(5/10) Additionally, in reviewing Alabama Department of Environmental Management Clean Air Act permits in and around the City of Mobile’s Africatown Planning Area, we’ve found many, that were extremely deficient in terms of both enforceability as well as how facilities quantified how many tons of toxic pollutants they release into the Africatown neighborhood over the course of a year. These include Plains, Kimberly-Clarke, UOP, and Kemira. The need for clear consideration and monitoring of air quality impacts along the Africatown Blvd traffic corridor stands.

The demands of the Africatown community to see sound demonstration of how the I-10 Toll Bridge project improves their environmental and community conditions is a must.

(6/10) Pedestrian and bicycle infrastructure improvements along Africatown Blvd is great to read about in writing, however, the LRTP Amendment only describes pedestrian crosswalks and ignores community demands for rumble strips, warning lights, stop lights, and lowering the speed limit along Africatown Blvd.

The City of Mobile is currently investing millions of dollars into tourist infrastructure on Africatown Blvd. With homes and churches along the corridor, the current 45 mile per hour interstate speed limit is simply too fast, especially with what many residents describe as a lack of speed enforcement which results in traffic often flying past the beauty bust of Oluale Kossola aka Cudjo Lewis in excess of 80 miles per hour.

(7/10) Also, the City of Mobile changed the name of Bay Bridge Road to Africatown Blvd in 2016. In May 2019, the State of Alabama changed the name of the Cochrane-Africatown USA Bridge to simply the Africatown Bridge. And although ALDOT has yet to commence with the replacement of all physical and virtual signage, all new official state documents should reflect all the name changes. Not doing so, again, reflects a lack of community engagement.

Neglecting to clearly communicate to potentially impacted environmental justice communities of concern, especially after they have clearly expressed interest demonstrates a deprioritization of environmental justice perspectives in the consideration of this LRTP amendment.

(8/10) Speaking to the history of the Africatown community with regional transportation efforts, our agencies have scoured available public records at ALDOT for documentation related to how previous transportation leadership has or hasn’t listened to the community. As evidenced in the Federal Environmental Impact Statements (FEIS) for the I-165 elevated Interstate construction, the expansion of Africatown Blvd (then Bay Bridge Rd), and the Africatown Bridge reconstruction (then Cochrane-Africatown USA Bridge), each of the major infrastructural expansions through the Africatown community faced sound and reasonable community opposition only to have the vast majority of their concerns ignored. Resident advocacy groups even offered engineering alternatives that aligned with ALDOT alternatives only to have those also ignored.

(9/10) In the case of the Bay Bridge Rd expansion project, the community’s once-thriving downtown business strip was demolished. Whether or not compliance with federal laws requiring reconstruction and proximate relocation of businesses condemned by federal highway projects was adhered to or not is unknown, although it is plainly obvious that none of the condemned commercially zoned parcels in the City of Mobile were replaced in the city’s now-defined Africatown Planning Area.

We don’t know of that project’s Civil Rights Act compliance because its FEIS is missing from ALDOT’s Montgomery offices, and the vast majority of it was also mysteriously lost in ALDOT’s Mobile office except for the public participation and public comment sections. For what they are worth, these sections offer illuminating insight into how acutely aware the community has been of the threats it was facing then and still faces today at the hands of inconsiderate and derogatory regional planning decisions.

(10/10) In conclusions, the Mobile MPO must not repeat the past mistakes of previous transportation decision making bodies that rendered Africatown as simply a vocal minority to be ignored, particularly at a time when the City of Mobile is ostensibly committed to engineering Africatown into a heritage tourism powerhouse for South Alabama.

Africatown’s engaged community stakeholders should be invited to participate more fully as partners in planning the future of our region’s obvious transportation needs. Africatown Blvd, the Africatown Bridge, and I-165 offer a plethora of opportunities for use in service of mitigating the serious ongoing harm resulting from decades of disrespectful and derogatory infrastructural development on top of and through Africatown’s vulnerable neighborhoods and historical attraction.

Thank you for your careful consideration of these Public Comments regarding the Draft Amendment to the Envision 2045 LRTP. [Ramsey Sprague]”

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