Jeffrey Thomas Medford

403 Woodland Dr

Summerville, SC  29485

225-266-2836

 

Monday, June 11, 2018

U.S. Army Corps of Engineers

ATTN: REGULATORY DIVISION

69A Hagood Avenue

Charleston, SC 29403

Re:  SAC 2015-0807

 

To Whom It May Concern:

I am writing regarding SAC 2015-0807as a part of the public comment period that ends on June 14th, 2018. 

I respectfully request that a public hearing be held to consider this application, and that a sufficient notice of at least six weeks be given from the date the hearing is announced to the date it is held in order to make sure the residents of the Town of Summerville have sufficient time to become aware that the meeting will take place and to schedule to attend it.

I have spent the past two weeks immersed in this issue, after I “accidentally” found out about it from the Mayor during a private meeting with him regarding another issue.  Tonight I attended the Town of Summerville’s monthly Standing Committees Meeting in order to finalize my information-gathering process before writing this letter.

In short, I am a fervent opponent of this project, and I will break down my reasons why this project is definitively NOT in the public interest.  The project should not be approved for the following reasons:

·       The “vision” and design for this roadway was conceptualized in the 1970’s—over 40 years ago—and has not changed despite massive changes in the public road infrastructure since that time, most importantly the four-laning of Bacon’s Bridge/SC 165, which is a mere 300 yards away from the location of this proposed 4-lane roadway.

·       The Town of Summerville’s council has rubber-stamped this project since its inception under the sway of property developers, even announcing on several occasions the when construction would begin despite the permitting process not being completed, including at tonight’s meeting

·       The Town of Summerville’s council has apparently suppressed information about the comment period in order to avoid any significant degree of public reaction.  Indeed, almost nobody in the town knows this proposed roadway is being pushed by the Council.  The link on town’s website in its “Road Projects” section (http://www.summervillesc.gov/roadprojects) for this project takes you straight to a satellite image with a line drawn on it to indicate the location of the “proposed” road.  NOWHERE AT ALL ON THE SITE DOES IT INDICATE THE PRESENCE OF A PUBLIC COMMENT PERIOD WHATSOEVER.

·       In addition, during the town Council meeting on Monday, the topic of the proposed roadway wasn’t even on the agenda, despite this being the last week for public comment.  In fact, a number of significantly small projects with insignificant updates were discussed in the meeting, but this one didn’t even make it to the agenda.  The only time it was brought up is when I asked about it at the close of the meeting.  After bringing it up, the person who responded said “We just learned that the Corps will be scheduling a public hearing about the project.”  That new information was not important enough to make it onto the agenda, yet these things were:

·       The proposed roadway is being incorrectly linked to the need for flood control work, which has nothing to do whatsoever with building a highway; flood control efforts are completely and wholly independent of highway construction

·       The proposed roadway is being upheld as a wise plan because “the funding is already approved,” as if the famous Bridge To Nowhere wasn’t a sufficient-enough example why funding does not equal prudence.

·       The public at large has very little “need for” this additional roadway.  Indeed, a 40+ year-old plan that has not been updated to reflect the changes since that time and the property developers backing various council members who own property along the proposed roadway and have put  it up for sale (34 acres directly to the north of Newington Plantation) are the only thing driving this process, not the community itself in any way at all.

·       The notion of an “historic property” as considered by the State Historic Preservation Office is typically relegated to only half of what constitutes “real property,” namely buildings.  However, the Saw Mill Branch is historic in a very relevant sense because the land is continuous, undeveloped, and flows through the heart of the community in a way unrivaled by any other town in the Lowcountry, and should be considered as a historical property as such.  Indeed, if preservation can’t protect land and merely protects buildings, then we are only protecting something temporary, as every building ever built eventually ceases to exist.

·       The proposed roadway would create two parallel four lane roads within 300 yards of each other in the heart of Summerville, a situation without equal across all of the municipalities in the entirety of the Lowcountry

·       The application as posted on the Corps of Engineers website conspicuously ends mid-sentence at the end of page 13 under the section “Alternatives Considered but Eliminated” which indicates an extremely careless clerical error at best, and potentially a desire to truly avoid looking at or notifying the public about the alternative of widening the EXISTING 2-lane roadway of US ALT 17 a mere 300 yards away—a road that this additional proposed parallel thoroughfare is linking up with only 3 miles away.

·       A rational analysis of the absence of seriously considering widening the EXISTING roadway as opposed to building a completely new one on pristine parkland leaves one mind boggled.  Indeed, the proposal is akin to the Town of Mount Pleasant proposing to put a 4 lane road down Shem Creek:


Proposed Berlin G Meyers Phase III

HYPOTHETICAL Town of Mount Pleasant’s Proposal to replicate Summerville’s plan and destroy a pristine, undeveloped waterway with an unnecessary road down the middle of Shem Creek.

·       Furthermore, the backers of the project in the town council I spoke with all concede that the existing US ALT 17 (reminder:  it is located a mere 300 yards away from the proposed roadway) will be 4-laned at some point in the future based on the needs of growth.   This would put three parallel 4-lane roads within 600 yards of each other, a situation unparalleled (pun intended) in the entire state of South Carolina.

·       The proposed roadway would destroy the only continuous and undeveloped greenspace left in the Town of Summerville and would significantly affect the exquisitely unique character of 5.5 miles of the Sawmill Branch Trail, a pristine bike trail in the heart of an urban environment that is without equal in all of the Lowcountry.

·       The proposed road completely goes against the modern developmental trends Smart Growth, which highlight the need to preserve green space to increase a community’s desirability.  Doing so makes the town more attractive for businesses and their employees, which will raise property values and the town’s tax base.  Summerville already has an underdeveloped business tax base as it is.

·       The project robs the town of Summerville of an opportunity to constructively think about how the existing green space could be utilized to increase quality-of-life and community desirability for new residents who will value things in ways that reflect the changing attitudes of society.  Indeed, properly conceived and planned, the Saw Mill Branch could become Summerville’s very own version of Central Park in NYC or the C&O Canal National Historical Park

·       The Town of Summerville is in urgent need of addressing actual traffic problems on Berlin G Meyer that create a bottleneck from the section beginning at the end of the overpass at E 3rd St. and that extend to its connection with N Main St instead of spending money on construction that will only increase the bottleneck that currently exists. 

·       The project is a perfect implementation of the fallacy contained in the fundamental law of road congestion:  NEW roads cause the intensity of traffic to stay the same instead of alleviating traffic.  In other words, BUILDING NEW ROADS DOESN’T REDUCE TRAFFIC. 

The last point is particularly relevant to this project:  if ever there were a proposed road that would do absolutely nothing positive for the traffic situation in a community, but would rather rob the community of a uniquely precious resource in the process, The Berlin G Meyers Phase 3 is it. 

Please allow the public to have a hearing to give their input to this project.  I promise you will be surprised by the large opposition to this idea that you will witness at the meeting. 

The best way to sum up this letter is quote Joy Riley, the project manager for this project with SCDOT, in reference to getting a permit from the Corps of Engineers:

“I don’t know what else I can do to try to get a solid permit application in that they can’t say no to.  The local politicians in Summerville are very interested in this project”[1]

Please note the glaring absence of any reference to the public desire for, or indeed—the actual need—for this road.  It is SOLELY about the local politicians.



[1] Kreber, Monica, "Waiting on the final leg of Berlin G. Myers Parkway." The Summerville Journal Scene Summerville, SC March 29, 2017 (emphasis added)