Dear Director James:

On the heels of the 15th Anniversary of Hurricane Katrina and 57th Anniversary of the March on Washington, we are writing this letter in opposition to the Better Utilizing Investments to Leverage Development (BUILD) Transportation Discretionary Grant application submitted by the City of Gulfport, Mississippi.

The connector road project proposes to ‘add approximately 0.824 miles of 4-lane boulevard style roadways and 1.127 miles of 2-lane roadway complete with lighting, storm drain improvements, multi-modal paths etc. to implement critical links between existing commercial developments, provide public access to lands to encourage future commercial development, and ensure critical safety improvements to eliminate having a single point of ingress / egress for an existing outlet mall’.

However, while the proposal extols the potential CO2 emissions reductions through traffic decongestion mitigation, it grossly undermines the significantly greater environmental and climate perils posed to the low- income, minority residents of the historical Forest Heights Community and surrounding areas, as a result of the wetlands fill for this project and previously attempted, long-awaited new developments which will undoubtedly be fast-tracked. This community and Forest Heights Baptist Church endured substantial destruction from Hurricane Katrina and has already been plagued with increased development generated flooding woes since. There was absolutely no mention of this in the grant proposal.

Forest Heights is a unique, project model established in 1966 by the National Council of Negro Women, in cooperation with the Department of Housing and Urban Development and supported by the Ford Foundation. It has the distinction of being one of the nation’s first integrated home ownership developments for low income families. This is a lasting and endearing legacies of the incomparable Gulfport local legend, Mrs. Youther Lee Keyes, the revered Dr. Mary McLeod Bethune and Congressional Gold Medal recipient, Ms. Dorothy Irene Height. Forest Heights is not only entrenched in its community cultural heritage, but its origin is indelibly etched in our country’s history and therefore should be preserved and protected.

While the grant proposal elaborates on providing additional access points, critical connections between other planned improvements to facilitate increased commercial and industrial developments, in particular the Port of Gulfport and shopping malls, it is flagrantly devoid of any consideration of exacerbated flooding and/or increased pollution exposures to the low income and/or minority residents that will be most adversely impacted. Forest Heights and surrounding minority neighborhoods of the North Gulfport Community are already disproportionally suffering the brunt of most of Gulfport’s environmentally hazardous “expansion” ventures.

Interconnecting Gulfport boasts of the jobs and economic opportunities this project will bring. It clearly values profit over people. Gulfport is primed for development prospects in other areas that will not further burden, erode and imperil Forrest Heights and North Gulfport. Economic desperation should never be exploited to surrender property security and environmental health. Low income and/or minority communities should never be presented with living wage options that yield deadly consequences. This is yet another example of the rich and powerful getting richer at the expense and despair of the poor.

Additionally, potential tourists who are aware of such egregious human and civil rights infractions and disregard for people and property are not keenly motivated to patronize offending city.
Aside from the human rights aspects of this proposal, this is a civil rights/ environmental justice issue which disregards and/or circumvents several federal laws and policies. The EPA is abundantly clear on its positions the importance of wetlands and their protection and the definition of environmental justice as it ‘refers to communities of low income and/or color and in the presence of high-risk environmental hazards’.

The National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 97-258, § 4(b), Sept. 13, 1982) An Act to establish a national policy for the environment, to provide for the establishment of a Council on Environmental Quality, and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That this Act may be cited as the "National Environmental Policy Act of 1969." Purpose Sec. 2 [42 USC § 4321].

The purposes of this Act are: To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality.

TITLE I CONGRESSIONAL DECLARATION OF NATIONAL ENVIRONMENTAL POLICY Sec. 101 [42 USC § 4331]. (a) The Congress, recognizing the profound impact of man's activity on the interrelations of all components of the natural environment, particularly the profound influences of population growth, high-density urbanization, industrial expansion, resource exploitation, and new and expanding technological advances and recognizing further the critical importance of restoring and maintaining environmental quality to the overall welfare and development of man, declares that it is the continuing policy of the Federal Government, in cooperation with State and local governments, and other concerned public and private organizations, to use all practicable means and measures, including financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans. Section 404 of the Clean Water Act (CWA) ‘establishes a program to regulate the discharge of dredged or fill
material into waters of the United States, including wetlands. Activities in waters of the United States regulated
under this program include fill for development, water resource projects (such as dams and levees),
infrastructure development (such as highways and airports) and mining projects.’

The grant application asserts that ‘during design and planning stages, all necessary steps to receive a full National Environmental Policy Act (NEPA) clearance will be performed’. The application further states that ‘some work related to NEPA evaluation has already begun’.

We ask that the grant request is denied. Comprehensive economic impact studies are required to obtain millions of dollars in funding to stimulate developments. However, commensurate research must be compulsory to ensure that the most extensive level of analytical means is mandated to protect people and property as well. This includes, but is not limited to: environmental impact study (not simply an environmental assessment), flood risk assessment, mitigation contingency planning, comprehensive hydrologic and hydraulic studies and other necessary evaluation tools. The investment to facilitate this is a mere fraction of the overall costs of development projects.

Too many projects in Gulfport have already been completed with maximum economic funding, but only meeting the absolute minimum requirements as it relates to human health and home risks computations. Taxpayers deserve better.

We appeal to the Departmental Office of Civil Rights (DOCR) to adhere to its ‘central leadership role in ensuring that the Department of Transportation (DOT) fulfills its goals of advancing equality and opportunity for all individuals and communities throughout its programs’ on behalf of the low income and/or minority residents of Forest Heights and surrounding communities, who will be most negatively and disproportionately impacted.

Thank you in advance for your consideration. Sincerely,

Coalition to Preserve and Protect Forest Heights Please see attached signatories

C: Honorable Elaine Chao, Secretary USDOT
Honorable Benjamin Carson, Secretary HUD
Honorable Billy Hewes, Mayor of Gulfport
Honorable Cindy Hyde-Smith, U. S. Senator
Honorable Roger Wicker, U. S. Senator
Honorable Steven M. Palazzo, U. S. House of Representative Honorable Tate Reeves, Governor of Mississippi
Tom King, Southern District Transportation Commissioner, MDOT Melinda McGrath, Executive Director, MDOT
Harrison County Board of Supervisors
Gulfport City Council
Paul Gavin, Executive Director, Gulf Regional Planning Commission
Clay Williams, Executive Director, Gulfport-Biloxi Regional Airport Authority