The TWG (Technical Working Group), acting in response to over 10,000 petition inputs, has written to Federal Highway (FHWA) and National Environmental Protection Act (NEPA) authorities urgently requesting them to delay any FONSI (Finding of No Significant Impact) approval of the Route 278 Corridor Project until we see a well-documented and justified plan that addresses Citizen concerns.

For years, we have been reviewing and commenting on various SCDOT project plans, conveying growing concerns about their methodology and emerging results. It now appears that a request for a FONSI may be imminent, ignoring major issues, public backlash now exceeding 10,000 petition signers, and the emerging actions of a new Hilton Head Town Council.

Our analysis of problems and report shows that SCDOT’s plan:

·     Ignores the NEPA concept of logical termini by deliberately excluding important nearby congestion, safety and impact areas. As a result, the solution proposed may cause large impacts, without demonstrating that it can meet a key project goal - reducing our actual congestion problem.

·     Pays insufficient attention to public safety, violating FHWA’s guidance that: “Safety should be considered first, every time, and at every stage of a project”.

·     Provides insufficient information on what is in, and what is out of the plan, and the resulting impacts and costs.

·     Contains confusing delay data, which combined with the other problems, makes it impossible to determine if the project actually meets its needs and purpose.

·     Gives the appearance of being “approved” by Beaufort County Council. However, their process has involved massive political manipulation, likely unethical acts, and suppression of public input. As a result, a Citizen’s grass roots movement exceeding 10,000 petition signers has requested an Independent Study to obtain a second opinion. 

·     Because of the above, other better (including environmental and community impact) solutions to the stated project goals may have been excluded from the planning process. 

A (10/4/22) Beaufort County Council Memorandum of Agreement (MOA) with the outgoing Lame-Duck Town Council could become an enabler for a premature FONSI ducking the issues we have raised.  That would be a disaster if it short-circuited a transparent resolution of the problems we have discovered. 

Even though that MOA states that the Town of Hilton Head Island does not provide its “Municipal Consent” yet, it states such consent ‘will not be unreasonably withheld.’ There is also a lack of clarity in the MOA that may permit large parts of the project (e.g. expensive bridges) to use up most of the project funding outside Hilton Head’s boundaries, without dealing with our congestion problem. 

In a positive step, the incoming Town Council (2/21/2023) passed a Resolution stating that the Town will hire a consultant to conduct an end-to-end simulation and study of the Project including the establishment of a Citizens Advisory Committee to help guide the work. That Independent Study (different from a County version) is about to start, may confirm the issues in our report as well as others, and could propose solutions that would impact the current project plan, negating a premature FONSI. 

We must not be forced or locked into the wrong plan because of County machinations, or the existence of a premature FONSI. Thus, we must hold-off any FONSI approval of the present plan until the Town’s Independent Study is complete, and there is full public review and comment on its findings. 

We have heard warnings of the potential loss of funding with any delay, but we believe that it is better to measure twice and cut once than to prematurely rush to commit large sums of taxpayer funds to a project that is sending alarm signals, has been insufficiently vetted, and may be heading in the wrong direction. While we need to conduct the Independent Study as rapidly and carefully as possible, we have been assured by our State Senator that the required funds will flow, once a well-planned and supported project is defined.

Finally, we wish to emphasize that Citizens are not the cause of the delay. As described in our report, we have warned of these issues since 2020. In that time, solutions could have been developed had not public input, and progress on further analysis, been suppressed by actions of key members of Beaufort County Council.

We are hopeful for success of the Town’s Independent Study. The best course is to support it, seek SCDOT cooperation, and temporarily hold off on any FONSI approval until we see a well-documented, justified and publicly reviewed plan that shows where we are going and why.

If you would like a full copy of our letter and the included 18 page report, please send your email address to: hiltonhead.twg@gmail.com

If you want to make a difference, please sign the free petition at  https://chng.it/gxXykZBv   The more names, we get, the more traction we will have with Federal Authorities to get this project on the right track.

Sincerely, 

TWG Members:

Diederik Advocaat

Steven M. Baer

Richard Bisi

Joseph Kernan 

Gray E. Smith 

Stephen R. Woodall, Ph.D.