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Highway Expansion - Creating Tomorrows Problems Today
Highway Expansion will cause
Irreversible and Unmitigatable Impacts

Impact Mitigation Strategy
The primary objective of impact mitigation strategy is to minimize impacts in the first place. An EIS should select an action alternative that AVOIDS most impacts, instead of the selecting the most harmful and impactful action alternative (highway widening) which CDOT has spent $25 million dollars aggressively pursuing from 2000 through 2006 in the PEIS process. State and Federal taxpayers should be outraged!
The alternative selection process is the single most beneficial tool available for the mitigation of both construction and environmental impacts. Avoidance of impacts requires the selection of the least harmful action alternative which results in fewer mitigation requirements and expense.

OR
The benefits of selecting an improvement activity or activity sequence that has less economic, social, community, historic, cultural, economic, environmental and mobility impacts to the mountain corridor communities, is that the less harmful alternative will require fewer mitigation measures and less mitigation expense. A more harmful action alternative may also have impacts that are virtually impossible to mitigate, regardless of the mitigation strategies.
Avoidance of impacts needs to be the primary mitigation strategy in the PEIS process. Highway improvements as the priority action of the PEIS process will require extremely difficult and extremely expensive mitigation measures and could have devastating consequences throughout the highway construction period and beyond.
Is it more advantageous to take a proactive or reactive approach to true impact mitigation?
CDOT is discouraging the use of impact avoidance in Tier 1. Instead, they are pursuing a more harmful action alternative (highway expansion) and ignoring the mitigation discussions and expenses until Tier 2. Tier 2 Impact Mitigation is relatively meaningless if the most harmful alternative is selected in Tier 1, which appears to be the current CDOT plan.
Here is an excerpt from the document "Eco-logical: An Ecosystem Approach to Developing Infrastructure Projects FHWA-HEP-06-011" on line at
http://www.environment.fhwa.dot.gov/ecological/ecological.pdf
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