EACritique

Coalition Comments 
of the 
Draft Design Report/Environmental Assessment
May 10, 2010


On May 10, 2010 Coalition submitted over 50 pages of comments, plus over 300 other letters and other documentation to the Town of Victor.  The documents submitted support the Coalition position that the Draft Environmental Assessment is a fatally flawed document that should be recalled and substantially revised. 

The Coalition has recommended to the Town of Victor and Federal Highway that no approvals be given until a new and substantially revised draft is produced.  

The National Environmental Policy Act (NEPA) requires an Environmental Assessment to be an unbiased document.  It should be a document that is based on high-quality scientific data, which enables planners to make the best decisions.   However, the draft Environmental Assessment which Fisher Associates prepared for the Town of Victor was written to justify and rationalize decisions that the planners made long ago.  

 Numerous examples are provided showing how the draft Environmental Assessment misrepresented facts, showed planner bias, and was written to justify a predetermined decisions. 










Misrepresenting the ADA 




Coalition Alternative Misrepresented 




A Recreational Trail Portrayed as a Transportation Facility 








APPENDIX 




Letters Submitted by Richard and Susan Pixley