On August 26th, Minnesota Department of Transportation Commissioner Daubenberger responded to a dozen elected officials in the state legislature asking for a Pause in the Rethinking I-94 project and the Highway 252/I-94 project. In the letter, the Minnesota Department of Transportation (MnDOT) “acknowledges” many of the harms residents and communities along I-94 are raising: historic displacement, reduced connectivity, health impacts, constrained economic opportunity, unsafe infrastructure, and disproportionate impacts on historically marginalized communities.
But instead of explaining how the alternatives currently being advanced in these projects will repair those harms, MnDOT is asking these communities to trust the answers will come later on as part of the project process.
MnDOT’s response is flawed in numerous ways.
1. “The data will go out of date” is not a reason to avoid a pause.
MnDOT’s central argument is that pausing the project could make existing data and public input irrelevant and require a complete restart.
In MnDOT’s words: “Pausing or delaying these studies could render the data and public input no longer relevant, requiring a complete restart of the process and limiting our ability to address documented needs while postponing the improvements these communities say they need.”
Nothing in state or federal environmental law says this is the case. No formal expiration clock voids scoping records and the underlying data that underpins them.
And MnDOT’s reference to “years of engagement” cannot substitute for actually responding to what community engagement has told them so far: meaningfully studying alternatives that consider highway removal. Engagement in this case isn’t meaningful simply because there has been a lot of it. It is meaningful when what communities say changes what gets considered and what gets built ultimately.
Additionally, a larger question is, if the underlying information is so fragile that a pause could invalidate it, is it sufficient to support decisions that could shape these corridors for the next 100 years?
2. MnDOT is conflating the problem of the projects with its preferred solutions.
The letter recites real harms that elected officials have consistently raised in PAC meetings since 2023, when it became clear MnDOT was conducting a process that centered traditional measures of vehicle throughput over the values of our state (Environmental Justice, Community Health, Tax base and Economic Development, accessibility, safety, and multi-modal connections).
To quote MnDOT: “Communities along I-94 continue to experience the legacy of the highway’s construction, including historic displacement, reduced connectivity, health impacts, and constrained economic opportunity. These urgent challenges are compounded by aging infrastructure and safety concerns that disproportionately affect historically marginalized communities. The Highway 252/I-94 corridor faces pressing concerns including fatal and serious crashes, congestion, multimodal safety concerns, and neighborhood connectivity.”
Residents, coalition partners, and community groups have also raised and reiterated these concerns named in MnDOT’s letter, including: displacement legacy, severed connectivity, health impacts, fatal crashes, missing pedestrian crossings, and unreliable transit. They then present continuing the current study as the remedy. But highway construction and expansion produced those harms.
The question is largely not whether the corridors need attention. We agree that projects in these contexts should create significant opportunities for repair. However, the alternatives currently under study on both corridors will not address the challenges MnDOT listed in its response that are critical to the community and to the legislators who signed the letter.
The obvious question for MnDOT is: which alternatives still under consideration would reduce displacement pressure, restore street connectivity, improve transit reliability, and address environmental justice, public health, climate change, land use, tax base, and development?
The alternatives MnDOT is pursuing will worsen these documented harms on both projects, harms MnDOT acknowledges “disproportionately affect historically marginalized communities.” Identifying the harms isn’t enough; continuing the existing process won’t resolve them. The solution has to be evaluated against the problem.
3. Initiatives like the Journey to Community Wellness and livability program are offered as a substitute for changing the project, but they are non-binding and largely underfunded.
Instead of meaningfully addressing community and elected officials’ requests, MnDOT has consistently invented new processes that are non-binding outside of the project’s formal process. This is a tool to placate these requests rather than meaningfully incorporate them into the project development and design, which would be binding and produce meaningful benefits for residents.
The letter’s own description of these initiatives as “goes beyond state and federal environmental processes” sits outside the decision documents that guide the environmental process, carries no enforceable commitment, and can be defunded or narrowed at will.
Offering these separate programs as the direct response to community concerns is a tell that the concerns won’t be addressed inside the project itself.
The agency is essentially asking us to take their word for it as marginalized communities continue to bear all the harms they acknowledged in the letter. Meanwhile, the federal process strips away the protections that exist within the federal dimensions of the environmental review process. It also continues to ignore the calls of elected officials who urge careful, deliberative work to address these concerns and represent their constituents meaningfully.
4. The federal question still needs an actual answer.
Legislators asked about federal directives and Minnesota values. MnDOT replied that state statutes guide the process “regardless of federal policy.” That’s a non-answer; these are joint processes with federal co-lead agency involvement with the United States Department of Transportation (USDOT), federal funding, and federally shaped process requirements. The Federal Highway Administration (FHWA) is in the room for all major project decisions; there is no way to sneak these priorities past a hostile federal administration seeking to import its values onto ours.
MnDOT must prove, in detail, that it is still advancing these priorities, as the legal reality shows clearer daylight between NEPA and MEPA Processes. Communities and legislators deserve to understand how specifically Minnesota’s environmental justice, climate, equity, health, and multimodal priorities will be protected and reflected in the actual alternatives and decisions moving forward. Simply saying our values still apply is not enough.
5. Engagement volume is not the same as responsiveness.
“Years of engagement with residents and local partners” documented the needs, but the corridors’ most affected communities have been asking for specific things for years, and the letter never says which of those asks are reflected in the alternatives that will actually move forward. Municipal consent, cited as a safeguard, is a narrow and late check on layout specifics, not a meaningful check on whether the right alternatives were studied at all.
MnDOT’s letter acknowledges the very harms that communities and advocates have been raising with these divisive highways. But acknowledging the harm while continuing a process that will reproduce it is not progress.
We don’t need another promise that displacement, health, climate, connectivity, and equity will be considered later. We need those values to determine what gets built in communities long harmed by transportation projects. That’s why we should pause the Rethinking I-94 and the 252/I-94 projects and restore community-preferred alternatives so communities have a real chance to shape the outcomes of these projects.
Don’t just promise us another process to participate in, if will not be responsive to what many communities have already said.
Go the extra mile
Call Governor Walz’s office to ask for a pause on the Rethinking I-94 and Highway 252/I-94 projects. Contact Governor Walz: 651-201-3400
About Twin Cities Boulevard
The most responsible option for the future of the Rethinking I-94 project is a multi-modal boulevard that returns the surrounding land to neighborhoods and fulfills calls for reparative justice along the corridor. The Twin Cities Boulevard will create healthier air, much-needed economic opportunity, and accessible, affordable, and sustainable transportation access to places all along the corridor.