There are Many Reasons Why Africatown Advocates Oppose Tolling on I-10

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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.


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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Petition Opportunity: Stop Alabama Power from dumping in Environmental Justice communities

As we are finding, many Clean Air Act pollution permits in and around the Africatown community in Mobile, Prichard, and Chickasaw make clear that there are major issues with how the Alabama Department of Environmental Management (ADEM) permits toxic dumping in low-income and predominantly Black communities in urban Mobile County.

But in rural north Mobile County near Bucks, there’s a mega coal and gas power plant called Plant Barry that’s owned and operated by Alabama Power and the residents near the plant are disproportionately Black and Indigenous, and there are schools and daycare facilities nearby.

And despite these facts, when Alabama Power asked for permission to release illegal levels of sulfur dioxide (SO2) from Plant Barry, ADEM agreed and chose not to enforce the Clean Air Act. So, clearly the challenge of environmental racism affect communities across Mobile County.

Breathing SO2 pollution is like getting a sunburn on your lungs, and if Alabama Power’s special permission stands, Plant Barry’s SO2 emissions could be more than two or three times the federal government’s health-based legal limit. Reliable models show the filthy plant’s air pollution is far-reaching, impacting both rural and urban communities already burdened by other pollution.

For this reason, MEJAC has joined forces with Sierra Club Alabama Chapter and GASP to petition the U.S. EPA to step in and properly regulate Alabama Power where Alabama’s state decision-makers didn’t.

By signing your name on the petition and adding your personal message, you’ll show the EPA that there are Alabamians who believe we all deserve clean air.

Scientific air modeling based on the proposed Clean Air Act Title V permit for Plant Barry shows levels of sulfur dioxide (SO2) that are in violation of the Clean Air Act’s National Ambient Air Quality Standards (NAAQS) at twice or three times the allowable levels immediately around the dangerous facility, and the illegal levels of this toxic air pollutant could even reach into already overburdened urban Mobile County communities like Africatown.

An image from the Attachments to Petition to Object to APC Barry Title V Permit, Sub-Attachment 1, page 3, with the Africatown Planning Area highlighted for orientation showing Africatown's air quality being impacted by illegally high levels of SO2

An illustration provided to EPA in the Sierra Club and GASP Petition to Object entitled “Attachments to Petition to Object to APC Barry Title V Permit”, Sub-Attachment 1, page 3 (page 235 in the PDF), with the Africatown Planning Area highlighted and labeled by MEJAC for orientation to show how Africatown’s air quality may be impacted by illegally high levels of SO2 from Plant Barry. The 1-hour average SO2 concentrations within the red, orange, and yellow contour lines exceed the NAAQS.

An image from the documentation provide to EPA in the Petition to Object entitled "Attachments to Petition to Object to APC Barry Title V Permit", Sub-Attachment 3, page 1 (page 274 in the PDF), with the Africatown Planning Area highlighted and labeled by MEJAC for orientation to show how Africatown's air quality may be impacted by illegally high levels of SO2 from Plant Barry

An illustration provided to EPA in the Sierra Club and GASP Petition to Object entitled “Attachments to Petition to Object to APC Barry Title V Permit”, Sub-Attachment 3, page 1 (page 274 in the PDF), with the Africatown Planning Area highlighted and labeled by MEJAC for orientation to show how Africatown’s air quality may be impacted by illegally high levels of SO2 from Plant Barry. All colored areas exceed the NAAQS.

Now is the time to act! New EPA leaders have committed to achieving environmental justice in overburdened communities – yes, even in Mobile County. Our actions can help them stop polluters and policymakers from turning Black, Indigenous, communities of color, and low-income neighborhoods into dumping grounds.

Add your name. Share your story. And tell a friend.

If we come together, we can make a big difference not only for our neighbors living nearest Plant Barry, but for all of us who are sick of dealing with Alabama Power’s dirty and dangerous special privileges.

And all of these concerns in an addition to all the existing concerns about Alabama Power’s Plant Barry toxic, leaking coal ash waste dump on the Mobile River!


Resources:

More De-Coding the City of Mobile’s proposed Unified Development Code (UDC)

De-Coding the City of Mobile's proposed UDC theme banner "More De-Coding: UDC Version 5 Update Breakdown"The City of Mobile’s proposed Unified Development Code (UDC) zoning code rewrite has changed yet again. For environmental justice advocates, there is some great news and some very disappointing news.

During its first Public Hearing at the Mobile Planning Commission on February 25, 2021, Africatown stakeholders and environmental justice advocates from across the City of Mobile came together to raise serious concerns with the fourth version of the UDC (UDCv4).

The Planning Commission then convened two “business meetings” on March 8 and March 29 to consider changes to UDCv4, which effectively modified it to a fifth version of the UDC (UDCv5). The final recommendation of passage of the UDCv5 by the Mobile City Council was voted on at the April 1, 2021 Planning Commission meeting, which saw a few small additional changes made to UDCv5 just before the vote to recommend adoption of the zoning code rewrite to City Council. The Mobile City Council has now received UDCv5, but to-date no Public Comment opportunities have been set.

Back at the February 25th Public Hearing, MEJAC and the Mobile Alabama NAACP continued their environmental justice partnership to make specific recommendations to the Planning Commission in writing. To provide context for the changes partly resulting from environmental justice engagement and advocacy in the code adoption process from UDCv4 to UDCv5, our 10 CONCERNS about UDCv4 are provided below along with 10 UDCv5 UPDATES.

Use this chart for quick reference and to click through to more documentation of our UDCv4 CONCERNS below and how they were or were not addressed in the UDCv5 UPDATES:

v4 Concern 1) Protection Buffers – Partially addressed by UDCv5
v4 Concern 2) Africatown Tank Farm Expansion – Not addressed by UDCv5
v4 Concern 3) Industrial Blight in Africatown – Partially addressed by UDCv5
v4 Concern 4) CPTED limited to Africatown – Not addressed by UDCv5
v4 Concern 5) Industrial Landscaping in Africatown – Resolved by UDCv5
v4 Concern 6) Riparian Buffer exemptions – Not addressed by UDCv5
v4 Concern 7) Water conservation in Africatown – Not addressed by UDCv5
v4 Concern 8) Coal ordinance concerns – Partially addressed by UDCv5
v4 Concern 9) Oil tank design standards – Not addressed by UDCv5
v4 Concern 10) Affordable housing concerns – Not addressed by UDCv5

A summary of all changes from UDCv4 to UDCv5 has been provided by City of Mobile here (https://mapformobile.org/wp/wp-content/uploads/2021/03/Summary-of-Changes-Post-Feb-25-2021-Public-Hearing-2.pdf).

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Africatown Public Comment Opportunity: Kimberly-Clark’s Air Pollution Permit

Speak Up for Environmental Justice TODAY!

The deadline for Public Comment on the Kimberly-Clark Corporation paper mill and distribution center’s Draft Clean Air Act Title V Major Source Operating Permit (Draft Title V Permit) is tomorrow, Friday, April 23 by 5pmCST, but there’s still time to demand that the Alabama Department of Environmental Management (ADEM) perform an Environmental Justice review as part of the permit!
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