Challenges & Recommendations
In order to successfully stop the DIFT and implement an alternative plan it is critical that CBRA continues to openly challenge the need for the DIFT. The Mercer Report Findings were driven by economic and are now outdated. Since the publication of the Mercer recommendations in 1994, many new intermodal facilities have been built in the GDA. In addition, truck size and bulk regulations have relaxed substantially in the last few years and as a result truck transportation has become more economical and popular.
It is also important that CBRA understands National Environmental Policy Act (NEPA) regulations requiring entities receiving federal funds to complete an environmental assessment of development projects that takes into consideration aspects such as cumulative impact and dispropriate burden, two indicators that will work in CBRA's favor if measured accurately effectively. The Federal Clean Air Act and Michigan's Clean Air Implementation Plan will also help CBRA by providing guidelines for measuring environmental impacts. Highway Engineering Journals may contain useful information about DIFT project impacts on transportation.
CBRA should take inventory of major public institutions such as schools, hospitals and nursing homes within ½ mile of the DIFT area to see how they may be affected by the proposed DIFT. This information will be useful in the future stages of the DIFT project, namely the environmental assessment phase.
CBRA should also continue to approach project decision makers and stakeholders with evaluation findings and their alternative plan. Intermodal transportation is considered interstate commerce under the commerce clause of the U.S. Constitution. Therefore it is extremely important that CBRA approach state and federal level decision makers as well as local decision makers.
Finally, CBRA should continue to do everything in its power to slow down the implementation process of the proposed DIFT project in order to buy time to further develop and build support for their alternative plan. If the DIFT is considered a non-conforming use according to the City of Detroit's zoning ordinance and/or Comprehensive Plan, MDOT's implementation process may become more complicated. Permits and/or amendments to the zoning ordinance or Comprehensive Plan may be necessary.