Wednesday, October 14, 2020

110 Organizations, Businesses to M-CORES Task Forces: "NO BUILD" is the only option

October 13, 2020

Kevin J. Thibault
Florida Department of Transportation
605 Suwannee Street, MS 54
Tallahassee, FL 32399

Via online portal and

 RE:  Joint Comments regarding Central-Southwest, Northern Turnpike, and Suncoast Connector Corridor Draft Task Force Reports (M-CORES)

Secretary Thibault: 

SB 7068 and section 338.223, Florida Statutes, charge each of the Task Forces to evaluate their respective Multi-use Corridors of Regional Economic Significance (M-CORES) Program corridors. The Florida Department of Transportation (FDOT), and the respective Task Forces, ultimately failed to provide comprehensive forecasts for future population, environmental and land use impacts, employment, traffic, and usage rates at the level of detail needed to warrant the continuation of the M-CORES program.

The work that FDOT failed to share with Task Force members was taken on by outside analysts. Using FDOT’s “economically feasible” framework and 500 simulated model trials, Cornell Consulting’s financial underwriting analysis (see here) found all of the M-CORES connectors to be financially infeasible.

Cornell Consulting estimated construction alone to be $10.3 billion for the three new toll roads. Meanwhile, in assessing the economic impact of toll roads, they found that the average rate of return for highways today are diminishing compared to early periods and are simply not worth the cost.

FDOT has not provided reliable robust traffic information to validate the need for these proposed toll roads through rural Florida that would address problems the existing FDOT work plan is not already aiming to solve. FDOT claims that increasing road capacity will reduce congestion are unfounded; in fact, examples abound from Florida and elsewhere of additional or widened highways leading to more rather than less congestion.

Broadband is a necessary utility that does not depend on the construction of new roads. In assessing broadband deployment, Cornell Consulting identified aerial fiber optic cable installation as a more efficient method of connecting underserved communities within the M-CORES study areas. Their projections saw that aerial fiber optic cable installation could be achieved for a fraction of the cost.  

While hurricane preparedness is necessary, the Florida Division of Emergency Management states on its website: “Select an evacuation destination that is nearest to your home, preferably in the same county, or at least minimize the distance over which you must travel in order to reach your intended shelter location.” Encouraging Floridians to attempt to outrun a hurricane is contrary advice. It has been over ten (10) years since a comprehensive statewide hurricane evacuation plan has been completed; a prerequisite before any new roads are proposed with the stated purpose of aiding in hurricane evacuation.  Any funding for broadband deployment or hurricane preparedness now part of the M-CORES budget should instead, through legislative action, be directed to the local governments or state agencies actually tasked with providing those services. Providing these services should not be tied to the development of new roads, as suggested in FDOT’s definition of “no build.”

In order for the goal of restoring and protecting Florida’s beleaguered water resources, including its springs, lakes, rivers, bays, and the Everglades to be achieved, it is imperative that no road project directly or indirectly impede or otherwise impact current or future restoration activities. Florida’s state waters are in crisis already. 

The locations of all three M-CORES corridors are contrary to the protection and acquisition of state conservation lands critical to the preservation of the state's remaining wild lands, for the people who explore them and the wildlife that depends upon them. Highways fragment wildlife habitat and collisions with vehicles are among the top causes of wildlife mortality. The science is clear regarding the endangered Florida Panther – additional fragmentation of remaining habitat will imperil their existence.  On the other hand, protecting umbrella species like the panther and the Florida Black Bear will thereby protect other listed and non-listed species as well.

These proposed corridor study areas encompass huge swaths of Florida’s agricultural land base. These ranchlands are indispensable to maintaining connectivity among existing conservation lands, many of which have been proposed for protection as approved Florida Forever projects and/or Rural and Family Lands projects. Agriculture’s contribution to Florida’s economy is second only to tourism and is at risk from these proposed corridors.

Floridians deserve the choice to enjoy the quality of life and natural beauty afforded in rural communities. Rural Florida residents and local governments are rightly concerned about the impact of toll roads on existing local businesses and their iconic way of life. History has shown that toll roads will either bypass historic downtowns altogether or replace them with mega gas-stations, fast food chains, and sprawl. Nothing in the reports, or in recent Florida history, provides any assurances that these fears are not warranted.

Any transportation capacity, operational or safety deficiencies within the state’s transportation system should first be met by improvements to existing transportation corridors. This is reflected in the draft task force reports, all of which express a preference for improvement or expansion of existing roadways and consideration of a “no build” option for the proposed M-CORES corridors.

The COVID-19 pandemic has underscored the need to prioritize human health and welfare in Florida; the priority should be responding to critical state needs resulting from the COVID-19 pandemic.  Siphoning billions of dollars from the state budget and directing FDOT to study and build these toll roads has already taken resources away from legitimate, identified state projects and must be stopped before more tax dollars are wasted. A delay of a "no build" decision until the Project Development and Environment (PD&E) study phase and continued funding of the M-CORES program would be an astronomical waste of taxpayer dollars, and contrary to the wishes of an overwhelming majority of Floridians.  M-CORES would dramatically strain the state budget while Florida is facing massive revenue shortfalls. We have already witnessed this:  Governor DeSantis vetoed $1 billion from the state budget – including $83 million for critical water quality projects – while the M-CORES project budget was increased.

SB 7068 in no way requires that any new toll road be built for any segment, let alone all segments of the three study areas. FDOT’s normal systematic approach to planning for the state’s transportation future had not, prior to the passage of SB 7068, identified a factual, objective specific transportation problem to be solved by any of these roads. The M-CORES process, a failed attempt to bypass the state’s normal transportation planning process, has neither evaluated nor identified any such factual, objective specific transportation problem to be solved. 

In order to protect Florida’s taxpayers, environmental assets and resources, and preserve areas providing habitat for plants and wildlife, rural lands, the agriculture industry, and the quality of life of our citizens, the only reasonable outcome of the three task force processes is a clear "no build" recommendation. 

Respectfully submitted,

Action Coalition of Cedar Key
Mandy Offerle, Member
Alachua Audubon Society
Debra Segal, President
Alachua County NAACP Environmental & Climate Justice
Nkwanda Jah, Chair
Alianza for Progress
Marcos Vilar, President
Animal Defenders International
Christina Scaringe, General Counsel
Apalachee Audubon Society
Donna Legare, President
Bay and Reef Company
Elizabeth Jolin, Co-Owner
Bear Warriors United
Katrina Shadix, Executive Director
Broward Climate Alliance
Steve Jens-Rochow, Secretary
Allie Preston, Director of Communications
Calusa Waterkeeper
John Cassani, Calusa Waterkeeper
Cape Coral Friends of Wildlife

Pascha Donaldson, Vice President

Cedar Key Community Garden
Many Offelre, Garden Director 

Cedar Key News
Frank Offelre, Editor
Center for Biological Diversity
Jacki Lopez, Florida Director
Center for Earth Jurisprudence
Margaret R. Stewart, Esq., MPA, LL.M., Director
Citizens Against Nonconcurrency Taskforce, Inc.
Barry J. White, President
Citizens for an Engaged Electorate
Drollene P. Brown, Co-founder
Coalition of Immokalee Workers
Lucas Benitez
Common Ground Florida
Lisa Perry, State Director
Concerned Citizens of Bayshore Community, Inc.
Steve Brodkin, Vice President/Secretary
Conservancy of Southwest Florida
Julianne Thomas, Senior Environmental Planning Specialist
Conservation Alliance of St. Lucie County
Pam Harting, Vice President
Cultural Arts Coalition
Dr. Anthony Greene, President
Cypress Cove Conservancy
Shane Duff, President
Democratic Environmental Caucus of Florida (DECF)
Janelle J. Christensen, PhD, MPH, President
Tania Galloni, Managing Attorney, Florida Office
Environment Florida
Jenna Stevens, State Director
Environmental Confederation of Southwest Florida
Becky Ayech, President
Everglades Law Center
Lisa Interlandi, Executive Director
eYes on Conservation 20/20
Barbara Manzo, Chair
Farmworker Association of Florida
Dr. Antonio Tovar, General Coordinator
Florida Bay Forever
Emma Haydocy, Executive Director
Florida Conservation Voters
Aliki Moncrief, Executive Director
Florida Defenders of the Environment
Jim Gross, Executive Director
Florida Oceanographic Society
Mark D. Perry, Executive Director
Florida Policy Institute
Sadaf Knight, CEO

Florida Public Interest Research Group (Florida PIRG)
Matt Casale, Environment Campaigns Director
Florida Rights of Nature Network
Chuck O’Neal, Chairman
Florida Springs Council
Ryan Smart, Executive Director
Florida Veterans for Common Sense Inc.
Gene Jones, President
Florida Voices for Animals
Myriam Parham, President
Florida Wildflower Foundation
Lisa Roberts, Executive Director
Florida's Nature Coast Conservancy
Jim Wortham, Vice President
Friends of Chassahowitzka
Ben Berauer, President
Friends of Lower Suwanee and Cedar Keys National Wildlife Refuges
John McPherson, President
Friends of Split Oak Forest
Valerie Anderson, President
Friends of the Everglades
Eve Samples, Executive Director
Friends of the Florida Panther Refuge
Nick Lefkow, President
Friends of the Wekiva River
John Pottinger, President
Friends of Warm Mineral Springs
Juliette Jones, Director
Goodwin Lumber Company, Inc.
Carol Goodwin, President
Green Horizon Land Trust Inc.
Marian Ryan, President
Hands Along the Water
Samantha Gentrup, Executive Director
Healthy Gulf
Christian Wagley, Coastal Organizer
Hillsborough County - Democratic Environmental Caucus of FL
Russell Conn, Chair
Humane Society of the United States (HSUS)
Kate MacFall, Florida State Director
Indivisible St Johns FL
Mary Lawrence, Founder
Institute for Regional Conservation
George Gann, President
International Dark Sky Association Florida Chapter
Diana Umpierre, Chair
Jefferson Against the Toll Road
Mike Willis
Jefferson Progress and Preservation Committee
Michele Arceneaux, President 
League of Women Voters of Florida
Patti Brigham, President
League of Women Voters of Hillsborough County
Emily Hinsdale, Transportation Committee Chair
Lee Future
Donald F. Eslick, Founding Member
Main Street Motor Parts, Inc., Lutz, FL
Barbara Fite, President
Glenn Compton, Chair
Martin County Conservation Alliance
Thomas P. Bausch, Member, Board of Directors
Miakka Community Club
Sarah Lewis, Vice President
Miami-Dade Democratic Environmental Caucus
Dustin Thaler, Vice President
Mountain Lion Foundation
Debra Chase, CEO
National Parks Conservation Association
Melissa E. Abdo, Ph.D., Regional Director, Sun Coast
National Wildlife Federation
David Muth, Director, Gulf Restoration Program
Natural Resources Defense Council
Alison Kelly, Senior Attorney
Adam Sugalski, Executive Director
Our Santa Fe River
Michael Roth, President
Paddle Florida
Bill Richards, Executive Director
Peace River Audubon Society 
Bren Curtis, Conservation Chair and Board Member
Pelican Island Audubon Society
Richard Baker, Ph.D., President
Physicians for Social Responsibility Florida
Marybeth Dunn, MPH, Executive Director
Progress Florida
Mark Ferrulo, Executive Director
Rainbow River Conservation
Burt Eno, President
Ralf Brookes, Attorney
Rebah Farm
Carol Ahearn, Owner
ReThink Energy Florida
Kim Ross, Executive Director
Ridge Audubon
Sandy Madden, President
Rum 138
Merrillee Malwitz-Jipson, Owner

Rural Levy Says No Toll Roads
Kim Wheeler, Founder
Sanibel Captiva Conservation Foundation
James Evans, Environmental Policy Director
Sanibel-Captiva Audubon Society
Karl Werner, Treasurer
Sarracenia Chapter of the Florida Native Plant Society
David Roddenberry, President
Save Orange County, Inc.
Kelly J Semrad, Vice Chair
Save Our Creeks
Carole Fields, Vice President
Save the Manatee Club
Pat Rose, Executive Director
Sea Turtle Conservancy
David Godfrey, Executive Director
Sierra Club
Cris Costello, Senior Organizing Manager
Silver Springs Alliance, Inc.
Chris Spontak, President
South Florida Wildlands Association
Matthew Schwartz, Executive Director
Speak Up Wekiva!
Chuck O’Neal
Springs Eternal Project
John Moran, Co-Director
Stonecrab Alliance
Karen Dwyer, Ph.D., Co-founder
The Howard T. Odum Florida Springs Institute
Robert L. Knight, Ph.D., Executive Director
United Waterfowlers-Florida, Inc.
Dennis Dutcher, Chairman of the Board
Vantage Point Network (VPN) Systems Inc.
Suzanne Suor and Edward W. Suor, Partners
W.A.R., Inc. (Withlacoochee Aquatic Restoration)
Dan Hilliard, President
Waterkeepers Florida 
Jen Lomberk, Esq., Vice-Chair 
WWALS Watershed Coalition
John S. Quarterman, Suwannee Riverkeeper
Young Leaders for Wild Florida
Oscar Psychas, Co-leader
100 Thousand Poets for Change
Michael Rothenberg and Terri Carrion, Founders

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Mike and Judi Kearney, Co-owners