Tuesday, April 27, 2010
Letter to NDOT and the FHWA about Project NEON
Mr. Saul Willis at his home in West Las Vegas, near F Street and McWilliams. Mr. Willis has received no compensation for the damage done to his home and business.
Mr. Cooke and Mr. Abdalla,
I am expressing my concerns to the FHWA and NDOT so they are in the loop about my concerns. I actually have some revisions to the statements I made on this project, but I understand the public comment period has expired. I would like you to reconsider the deadlines and include these comments.
After again reviewing the limited amount of information on the Project NEON survey of potentially displaced people, it appears to me that you may have a major Environmental Justice issue on your hand with Project NEON. You had some of the information buried in a CD that is not even in the paper copy of the Draft EIS.
Given both agencies' track records on environmental injustice from 1956 to the present, I would encourage you to review my concerns. Based on this abysmal record, I do not trust that the Relocation Program will be just or fair or that you have given a reasonable effort in conducting your surveys.
I am letting you know of these concerns so there is not another F Street situation and lots of wasted money and resources to remedy the situation.
According to Executive Order 12898 as well as FHWA guidelines, protected groups include people under the poverty line as well as people of color.
Your "Relocation Impact Study" by Mayo and Associates in 2005 only had 76 respondents for the survey and only 46 respondents for the income portion. The number of people potentially displaced was 852. So that's a 9% response rate (76/852), not a 22% response rate as mentioned on pg 3-14 of the Draft EIS. The percentage of people who answered the income questions was 5% (46/852). (Note: the number of people potentially displaced comes from pg 3-27 of the Draft EIS, FHWA-NV-EIS-09-01-D).
The survey also indicated that of the respondents who did answer, the median income was $32,863 in 2005, versus a median family income of $44,069 of the City of Las Vegas in 2000. Although these may not be poverty-level numbers, you listed 37 of the 46 respondents had income below median levels. You do not mention how many people fall into the poverty category. You also didn't mention whether the survey was also available in Spanish.
I would argue that these response rate may not yield valid results. Income statistics may also have changed dramatically in this area, due to the recession and to the economic damage already created by Project NEON, where those with higher incomes may be leaving the impact area.
I would like to know whether the FHWA and NDOT are compliant with procedures/ guidelines on this type of survey. Is there a standard for response rates? I would also like to review whether there may have been any fraud or unethical behavior involved in gathering and/or publicizing the survey data by Mayo and Associates.