• Exclusion in study of reasonable, feasible, and viable alternatives including an upgrade of U.S. Route 220, access management, a more thoroughly analyzed and presented TSM alternative, and a rails alternative.
  
• Bias in favor of building a new terrain facility and designating it as an interstate, despite the fact that this is not a requirement for this National Highway System roadway.
  
• Failure to adequately identify properties potentially eligible for inclusion in the National Historic Register.
  
• Exclusion of emissions analysis for each alternative to study ozone, nitrogen dioxides and particulate matter levels for the current 1 hour and soon to be implemented 8 hour National Ambient Air Quality Standards for ozone.
  
• Exclusion of emissions analysis to study impacts to the visibility in the Class 1 protected James River Face Wilderness area and Blue Ridge Parkway.
  
• Exclusion of analysis of impacts, especially noise, to the Appalachian Trail, a Section 4(f) national scenic treasure.
  
• Failure to study or list any impacts to Smith Mountain Lake which will be traversed by the eastern corridor, the surface of which is a publicly-owned recreation facility.
  
• Failure to complete a Biological Assessment to study significant impacts to critical habitat of endangered and threatened species including the Roanoke logperch, eastern cougar, Indiana bat, bald eagle, peregrine falcon, smooth coneflower, northeastern bulrush and ginseng.
  
• Failure to address and study impacts to impaired waters in the Roanoke River basin.
  
• Failure to adequately address the project’s secondary and cumulative impacts, including the impacts of development and new traffic induced by the project.
  
• Inadequate consideration of impacts to prime farmland.
  
• Failure to consider the impacts of loss of tree cover caused by the construction of I-73 and by the development induced by I-73.
  
• Failure to consider impacts to the Roanoke region's scenic values, tourism industry, and business-attracting quality of life.
  
• Failure to consider impacts to the German Baptist community located along Rt. 116 and vicinity in Franklin County.
  
• Inadequate consideration of impacts to minority and low-income residents.
  

These are major issues and impacts that are the core of the National Environmental Policy Act of 1969 as well as other enviromental protection and civil rights laws. By law, not only do these issues need to be fully addressed, but at the appropriate time in the process.

Sometime in May, VDOT will be presenting its preferred alternative to the Commonwealth Transportation Board. The CTB will likely choose a route on May 17, 2001. Spokespersons from the Virginia Dept. of Transportation have said that some of these issues will be addressed in the Final Environmental Impact Statement which will be completed approximately six months following the CTB decision.

This time frame circumvents the purpose of NEPA - to aid decision-makers in making informed decisions. It is not supposed to justify decisions already made. A route must not be chosen until these significant issues and impacts have been fully addressed.

Therefore, we respectfully request:

• Either a Supplement to the DEIS or a completely new DEIS be prepared to fully
  address these significant issues and provide real substance and meaning to the
  alternatives analysis process.
  
• VDOT be removed as the lead agency and FHWA’s main D.C. office assume
  responsibility for writing the I-73 Supplement or new DEIS.
  

With the CTB expected to make a decision soon, we look forward to your prompt reply.


Sincerely,



Mark E. Barker
BREDL SW VA Vice-President



Cc:

Ms. Shirley Ybarra, Virginia Secretary of Transportation
Office of the Governor
P.O. Box 1475
Richmond, VA 23218

Vincent F Schimmoller, Deputy Executive Director
Federal Highway Administration
400 7th Street, SW
Washington, DC 20590

Mr. Roberto Fonseca-Martinez
Division Administrator
Federal Highway Administration
P.O. Box 10249
400 N. 8th Street Rm. 750
Richmond, VA 23240