U.S. Dept. of Interior correspondence with VDOT regarding I-73 DEIS
(includes Blue Ridge Parkway, Appalachian Trail, and U.S. Fish and Wildlife comments)

United States Department of the Interior
OFFICE OF THE SECRETARY
Washington, D.C. 20240

ER-00/849


FEB 0 6 2001


Mr. Roberto Fonseca-Martinez
Division Administrator
Federal Highway Administration
Post Office Box 10249
400 North 8th Street, Room 750
Richmond, Virginia 23240

Dear Mr. Fonseca-Martinez:

Thank you for the opportunity to review and comment on the 1-73 Location Study Between Roanoke and the North Carolina State Line Commonwealth of Virginia Draft Environmental Impact Statement (DEIS) and Draft Section 4(f) Evaluation - FHWA-VA-EIS-NH-962-2 (004), State Project: 0073-962-FO1, PEI0I.

We cannot at this time concur that there are no feasible and prudent alternatives to this project or that all possible planning has been (sic) done to mitigate harm to Department of the Interior (DOI) resources. Our concerns and comments are detailed below.

PARK AND RECREATION RESOURCES

The National Park Service (NPS) has a number of concerns with the document as currently presented and our primary concern at this point is with the failure of the Virginia Department of Transportation (V DOT) officials to consult with The Appalachian National Scenic Trail and the Blue Ridge Parkway (BRP) during the last 12 months of this process. (Communications prior to that 12 month period were generally excellent, and we believe that a similar level of coordination during the last 12 months would have corrected many of the flaws in both the preliminary draft and the subject DEIS.) Accordingly, we would like to reiterate our request for consultation by the Federal Highway Administration (FHwA) and the VDOT with the Appalachian National Scenic Trail and the BRP at every juncture throughout the National Environmental Policy Act process and Section 4(f) consultation process.

We have the following comments to offer on the DEIS. Comments for the Appalachian National Scenic Trail and the BRP are presented under separate sections of this correspondence.

APPALACHIAN NATIONAL SCENIC TRAIL COMMENTS

Description of the Appalachian National Scenic Trail and its significance:

The description of the Appalachian National Scenic Trail on page 3.5-13 should be changed to reflect recent history. The Trail is no longer located on private land. A more accurate first paragraph under Section 3.5.3.1 would be:

Portions of the Appalachian National Scenic Trail are located within the viewshed of the 1-73 Location Study. The Trail is a unit of our National Park System, and our nation's premier national long-distance hiking trail - a continuous, marked, 75-year old. 2,167-mile footpath that traverses the Appalachian Mountain chain through 14 states from central Maine to northern Georgia. The Trail is located almost entirely on public lands administered by the NPS and the U.S. Forest Service. The 15-mile section of the Trail potentially affected by the proposed project begins on Tinker Mountain west of 1-81, continues under 1-81 north of Exit 150, ascends Fulharts Knob, and continues in a northeasterly direction along the ridgeline north of the Blue Ridge Parkway. This section of the Appalachian Trail (from Tinker Mountain to Blackhorse Gap) is one of the more popular day-hike sections of the Trail in Virginia. This section of the Trail, which is located on both NPS and U.S. Forest Service lands, also is noted for its frequent and often dramatic vistas that overlook the rural countryside north and east of Roanoke.


Impacts to Scenic Values along the Appalachian National Scenic Trail:

As we indicated in our comments on the DEIS, the most serious omission with the document is that it contains little actual analysis of the potential impacts to the scenic values that are present along this section of the Appalachian National Scenic Trail Furthermore, the methodology used for analysis of impacts to scenic values appears to be fundamentally flawed, since it does not appear to accurately reflect the impacts of the proposed project on important national recreation resources like the Appalachian National Scenic Trail. We believe that the visual analysis should rely on a welltstablished, scientifically based methodology, such as the U.S. Forest Service's Scenery Management System.

For example. the information contained in Tables 4.5-2 and 4.5-3 (on pages 4.5-2 and 4.5-3, respectively) appears to indicate that the visual impacts of constructing Segment 372 would be "low," with a average score of "-3.32." This conclusion appears to be based on criteria that are in direct conflict with the narrative discussion of impacts to the BRP and Appalachian National Scenic Trail. These two resources are nationally significant units of the National Park System managed primarily for their scenic values, yet the visual analysis concludes that the potential visual impacts of Options I and lA on Segment 372 (which would require a significant road cut at the crossing of the BRP and be visible from 55 to 60 percent of the Appalachian Trail of the three-mile hike between Fulhart's Knob and Route 11 and be visible from a number of scenic vistas along the Trail north of Fulharts Knob) are "low." We question how this outcome is possible.

Furthermore. as noted in our comments on the Preliminary Draft, the visual resource analysis as currently displayed has the effect of canceling the adverse impacts on remote and highly scenic areas by citing a corresponding positive impact for future motorists on the highway. If the approach used in the preliminary document were taken to what seems to be its logical extreme, the cumulative visual impacts of putting a highway through a wilderness area would correlate roughly with the cumulative visual impacts of putting a highway through an urban setting: the existing wilderness setting would become an urban one for wilderness users, but motorists on the new road would enjoy the view!

In short, we believe that the visual analysis does not meet the minimum threshold for an adequate analysis. It should be reworked using a well-established, scientifically based methodology, such as the U.S. Forest Service's Scenery Management System.

Despite repeated requests in previous correspondence. coordination meetings and field reviews. we still have not been provided with copies of visual simulations as promised by VDOT representatives. As noted in our comments on the DEIS, these simulations, plus a narrative description of the visual impacts depicted in the simulations, are essential components of the analysis of impacts to scenic resources. We would appreciate being provided with copies of these simulations, as well as the written narrative prepared by the consultant responsible for the visual analysis as soon as possible.

Noise Impacts to the Appalachian National Scenic Trail:

The analysis currently states that "noise from 1-73 would dissipate to ambient or existing levels and not impact the Appalachian Trail." We believe that this is inaccurate. NPS employees have recently hiked this section of the Appalachian Trail, and found that traffic on existing highways and county roads, construction noise, and other sounds from the valley north of Roanoke can be heard clearly along the Appalachian Trail at Fulharts Knob and other locations. The dominant sounds that would be associated with the proposed northern route of 1-73 through this landscape - particularly the sounds of the truck traffic - will be far more apparent. Again, as noted in our previous comments, the NPS has conducted extensive studies of the effects of noise on visitor enjoyment in parks. "Natural quiet is an important component of many park experiences, and particularly important to backcountry recreational experiences like those found along the Appalachian Trail. This concept needs to be addressed in the noise analysis.

Moreover, the analysis of auditory impacts as currently presented in the preliminary draft seerns to be based on what people in a residential or work environment are accustomed to. In remote recreational areas, such as those found along the Appalachian Trail, manmade sounds are far more intrusive at low levels. In other words, although the incremental difference in sounds associated with the project may be as little as 20 percent above background noise, if the sound can be heard and recognized, it can change a remote backcountry experience to a developed recreational experience. To base analysis of the auditory impacts to a backcountry resource such as the Appalachian Trail on noise levels found in residential and work environments is inappropriate.

Impacts to the Recreational Experience Provided by the Appalachian National Scenic Trail:

Ultimately, changes in the visual and auditory environment of the Appalachian Trail have the potential to change the visitors' experiences while on the Trail. If these visual and auditory impacts are frequent. egregious, or inconsistent with visitors' expectations, they can change a remote recreational experience to one that is more likely to occur in a developed setting. None of these potential impacts is discussed in the current draft.

Section 4 (f) and Future Coordination and Consultation:

Lastly, we believe that the Appalachian National Scenic Trail should be considered as a Section 4 (f) resource in the document, based on the concept of constructive use. The proposed northern route of I-73 has clear, measurable impacts that affect the Appalachian Trail - impacts that have not been fully or accurately quantified in the DEIS. Perhaps the most appropriate forum for discussing this issue would be in a meeting attended by representatives from the BRP, the Appalachian National Scenic Trail, the Appalachian Trail Conference, the Roanoke Appalachian Trail Club, and the Jefferson and George Washington National Forests.

BLUE RIDGE PARKWAY COMMENTS

This section presents comments specific to the five locations that build alternative options are being considered for crossing of BRP land (see the following table).

Comments are based upon the review and evaluation of data relevant to the five-Parkway crossings discussed in CHAPTER 3.0 AFFECTED ENVIRONMENT and CHAPTER 4.0 ENVIRONMENTAL CONSEQUENCES. While this DEIS is more complete than the earlier Preliminary DEIS. agency reviewers still found that not all of the available data related to the Parkway were included in the DEIS. Data that the Service believes to be relevant to the evaluation of proposed Parkway crossing segments are also included as comments and in support of conclusions reached by the NPS.

Preliminary Preferred Parkway Crossing Conclusions:

The DEIS and supplemental data were used by the NPS to evaluate the five alternative build option segments and prioritize them in rank order from most preferred to least preferred. The following is a preliminary ranking of NPS preferences pending the outcome of a future on-site meeting in Roanoke, Virginia, being requested via this comment transmittal. Based upon the results of that meeting, the NPS will provide its final preference conclusions within thirty days of the on-site meeting.

Based upon current data, the NPS's most preferred crossing of the BRP is segment 118C, Milepost 121.4 included in Build Alternative Options 2b, 3, 3b, and 3c. This is the existing four-lane corridor of U.S. Route 220, a major transportation corridor that has been a part of the Parkway visitor driving experience since the Parkway was constructed through the Roanoke Valley during the late 1950's and early 1960's. Widening of the U.S. 220 corridor to accommodate 1-73 will further impact this area of the Parkway but the landscape changes would be more consistent with existing land use than they would be in the other four proposed Parkway crossing locations.

Segment 105, Milepost 124.1 included in Build Alternative Option 3a is the next most preferred crossing location. Between Parkway Milepost 121.4 at U.S. Route 220 and Milepost 126.1 there are four Virginia Secondary Route underpass crossings of the Parkway. Proposed Segment 105 is located within an existing underpass crossing of VA Route 615 and the Norfolk Southern Railroad. This is the next most preferred crossing by the NPS because this series of underpass structures is a prirnary character-defining element of this 4.7 - mile section of Parkway. While widening the existing corridor with side-hill cuts to accommodate a four-lane interstate would dramatically change the landscape, those changes would be more consistent with existing land uses and site conditions than the other three locations which are characterized by forest covered slopes or rolling rural residential and farmlands. However, from a natural resources perspective, this is a less preferred option because crossing here would result in extensive forest fragmentation and loss of canopy vegetation.

The remaining three segments--Segment 371, Milepost 126.5; Segment 372, Milepost 103.6 and Segment 376, Milepost 116.9 included in Build Alternative Options 4; 1 and la; and 2, 2a and 2c, respectively are all less preferred options, in our opinion. The construction of an interstate highway in any of these three Parkway landscape settings would dramatically change the existing view area's scenic quality, and land uses, all of which are absent of major roads seen from or crossing the Parkway. Increases in highway noise generated by interstate highway traffic volumes and vehicle speed would radically alter existing site noise conditions.

Segment 371, Milepost 126.5 is the southern most proposed segment, characterized by forest cover and is just south of Masons Knob Parking Overlook, a paved parking area for 28 cars. Both the existing land use and the proximity of Segment 371 to a formal overlook parking area are of great concern to the NPS. Noise increases, land use changes and view area scenic quality impacts form the basis for this being a least preferred crossing option.

Segment 372, Milepost 103.6 is the northern most proposed crossing of the Parkway. Between Parkway Milepost 90 and 104 the Parkway traverses primarily national forest land and the visitor experience is dominated by a forested road corridor with vistas of undeveloped forest lands. From Milepost 104 to 105.8 land use is rural residential with U.S. 460 crossing the Parkway at Milepost 105.8. The introduction of another four-lane highway, especially one meeting interstate standards into this forest dominated setting, greatly alters the existing visitor experience. Again, increased noise, changes in land use and view area scenic quality impacts form the basis for this being a least preferred crossing option.

Segment 376, Milepost 116.9 is in a section of Parkway dominated by rural farm and residential use. This portion of Parkway lies midway between U.S. Route 24 and U.S. Route 220. Views of roads in this area and within Parkway view areas are inconsequential. The narrow secondary routes that cross the Parkway do so under or over the Parkway on picturesque stone arch bridges. These structures are so well placed and their scale is such that they enhance the overall driving experience and do not dominate it. An interstate highway constructed through this area would overpower the current landscape setting with its scale, mass and engineered character. Again noise, land use changes and view area scenic quality impacts are of great concern in this location and make it a least preferred crossing option.

The foregoing is a summary of NPS conclusions based upon the following in-depth review and evaluation of DEIS data.

General Blue Ridge Parkway Review Comments:

While the NPS has reached preliminary conclusions on the order of preference for the five proposed Parkway crossings, there are additional data not included in the DEIS that Parkway Resource Planning staff would like to review. Therefore, the NPS requests that the VDOT schedule an on-site meeting in Roanoke, Virginia with Blue Ridge Parkway Resource Planning staff, the FHWA and appropriate DEIS consulting staff to review affected visual environment and environmental consequences data specific to the five segments crossing the Parkway and their associated landscape units. This meeting should be scheduled as soon as possible so that the NPS's preference for crossings can be finalized and transmitted to VDOT prior to finalization of the EIS.

The meeting is being requested because there is little definitive descriptive inventory and assessment data included in the DElS supporting conclusions and findings presented in the EXECUTIVE SUMMARY. CHAPTER 3.0 AFFECTED ENVIRONMENT OR CHAPTER 4.0 ENVIRONMENTAL CONSEQUENCES sections related to the BRP. Agency reviewers found it difficult to evaluate build alternative options affecting the BRP given the absence of affected environment and impact assessment data supporting the DEIS.

Specific Blue Ridge Parkway Review Comments:

The following comments are organized under chapter and section headings used in the DEIS.

CHAPTER 3.0 AFFECTED ENVIRONMENT

3.5 VISUAL SETTING

3.5.1 AFFECTED ENVIRONMENT

3.5.1.1 Definition of Existing Visual Environment

Under this section there is a discussion of the landscape classification system, definitions and a general description of landscape regions and districts. The next-to-the-last paragraph on page 3.5-1 in this section states that "Each landscape district was further divided into landscape units." In the last paragraph the classification of landscape units is said to have "..,considered topography, vegetation, proximity to proposed alignments, close and distant views, cultural landscape and land use, landmarks, historic structures, views, and the public's perception of visual importance. Special features and issues of each unit were described from a context of cultural, existing development, local perceptions, and community concerns. The variations of environment along the potential corridor-urbanization, farmlands, suburban development, parkland, etc. -were also recognized through the landscape unit definitions."

Study process and types of data studied are presented, yet there is no presentation of inventory or assessment data that was gathered for any of the landscape units. There is no written or graphic description of the affected visual environment or landscape units beyond the methods used to identify, inventory and assess them and maps showing their names and geographic locations. These data that were not presented are in fact the information that would define for the reader/reviewer the visual environment affected by the various 1-73 build alternative options.

3.5.1.2 Assessment of Existing Visual Ouality of Landscape Units

Again this section discusses visual quality definitions, evaluation criteria and visual quality rating of landscape units, but includes no discussion of what this process yielded in terms of visual character or scenic quality data for each option and/or segment landscape units. Even some general description here would better meet the intent of the affected environment chapter to provide the reader/reviewer with an understanding of what the visual setting is and how it varies by option, segment location and landscape unit. This information is necessary to provide the basis for understanding the segment impact ratings in CHAPTER 4.0 and to provide the context for the next phases of "context sensitive design."

3.5.1.3 Assessment of Views from the Blue Ridge Parkway

There is no description of the BRP's visual setting context or specific scenic attributes that articulate its scenic character or importance within the Roanoke Valley between rnilepost 103 and 127. This 24 mile-long section of Parkway establishes the resource context within which to evaluate proposed crossings and their relative visual impacts. There is no description of view areas or individual landscape unit assessment results presented in the DEIS.

The BRP planning staff made viewshed sensitivity mapping, view area maps and scenic quality assessment ratings for each view area for this Parkway section available to the DEIS project consultants to assist the DEIS team in their describing the Parkway's affected visual environment. Data provided by Parkway staff should have enabled the Parkway to be treated at two levels of detail - a general description of the Parkway's visual character, visual sensitivity and view areas' scenic quality between milepost 103 and 127; and specific treatment of these elements for each of the five proposed segment crossings.

The lack of information in this section does not create for the reader/reviewer an adequate mental and visual image of what the Parkway looks like or its scenic importance. Thus later in the impact analysis there is no visual data foundation for evaluating the relative impacts of the various options.

3.5.2 ENVIRONMENTAL CONSEQUENCES

The second paragraph states, "The impact analysis did not only consider direct impacts, but also secondary' and cumulative impacts on the visual quality." These data were not presented in the Affected Environment or the Environmental Consequences Chapters.

CHAPTER 4.0 ENVIRONMENTAL CONSEQUENCE

4.5 VISUAL QUALITY

4.5.4 Build Alternatives

4.5.4.2 Build Option 1 and 4.5.4.3 Build Option la

Segment 372 is the portion of Build Option 1 and 1a that crosses the BRP at Milepost 103.6. In Tables 4.5-2 OPTION 1 and 4.5-3 OPTION la VISUAL IMPACT RATING Segment 372 is comprised of 19 landscape units. When combined, those units have a "low" Visual Impact Rating. Segment 372 is one of the NPS's least preferred crossing options because the landscape unit tha encompasses this geographic area is comprised of forested and adjacent rural land uses that are currently unaffected by major transportation corridors in the immediate area of the proposed crossing. The introduction of an interstate highway in this highly visually sensitive area would cause a substantial adverse change and therefore should be rated as having a substantial adverse impact within this landscape unit. It is the NPS's conclusion that this crossing would have high visual impacts directly a Parkway land resources and secondarily on view area scenic quality rather than a low visual impact rating. This alternative would also affect the Appalachian National Scenic Trail's viewshed. Additional discussion of NPS conclusions follow below under Segment 372 BRP Evaluation comments.

4.5.4.4 Build Option 2, 4.5.4.5 Build Option 2a, and 4.5.4.7 Build Option 2c

Segment 376 is the portion of Build Option 2, 2a, and 2c that crosses the BRP at Milepost 116.9. In Tables 4.5-4 OPTION 2,4.5-5 OPTION 2a and 4.5-7 OPTION 2c VISUAL IMPACT RATING Segment 376 is comprised of 5 landscape units. When combined, those units have a "medium" Visual Impact Rating. The particular landscape unit that encompasses this geographic area is comprised of rural farm and residential land uses that are currently unaffected by major transportation corridors. The NPS reviewers concur with the statements on pages 4.54 and 4.5-5 essentially stating that this crossing would become a dominant visual element in the landscape and have high visual impacts directly on Parkway land resources and secondarily on view area scenic quality. Segment 376 is the second of three of the NPS's least preferred crossing options presented in the DEIS. It is the NPS's conclusion that this crossing would have high visual impacts directly on Parkway land resources and secondarily on view area scenic quality rather than the medium rating in Tables 4.54.4.5.5, and 4.5-7. Additional discussion of NPS conclusions follow below under Segment 376 BRP Evaluation comments.

4.5.4.6 Build Option 2b, 4.5.4.8 Build Option 3, 4.5.4.10 Build Option 3b and 4.5.4.11 Build Option 3c

Segment 118C is the portion of Build Options 2b, 3, 3b, and 3c that crosses the BRP at Milepost 121.4. In Tables 4.5-6 OPTION 2b, 4.5-8 OPTION 3, 4.5-10 OPTION 3b and 4.5-11 OPTION 3c VISUAL IMPACT RATING Segment 118C is comprised of 4 landscape units. When combined those units have a "low" Visual Impact Rating. The particular landscape unit that encompasses this geographic area is comprised of rural residences, agricultural lease lands, a major quarry operation and the four-lane highway corridor of U.S. Route 220. The NPS reviewers concur with the statements on pages 4.5-6.8, and 10, that this Segment 118C crossing would have a moderate to high visual impact primarily for surrounding homes. However, visual impacts to the Parkway visitor experience in this landscape unit are seen as being relatively low because this location is already dominated by highly impacting land uses including a quarry and a four-lane highway. The existing U.S. Route 220 corridor is a dominant visual element in the landscape and has directly affected the visitor's experience of the Parkway since the early 1960's. Additional and larger cut slopes and highway structures will impact the current landscape setting. but less so here than the other proposed crossing locations. The Segment 118C, by following the U.S. Route 220 corridor, would introduce less change in visual quality by comparison to current land uses in this location than at any of the other four proposed crossings. Additional discussion of NPS conclusions follow below under Segment 118C BRP Evaluation comments.

4.5.4.9 Build Option 3a

Segment 105 is the portion of Build Option 3a that crosses the BRP at Milepost 124.1. In Table 4.5-9 OPTION 3a VISUAL IMPACT RATING Segment 105 is comprised of 4 landscape units. When combined. those units have a "low" Visual Impact Rating. The landscape unit that encompasses this geographic area is comprised of forested slopes, a state secondary roadway, a railroad right-of-way and rural residences. Within this landscape unit there are four Virginia Secondary Route underpass crossings of the Parkway between Parkway Milepost 121.4 at U.S. Route 220 and Milepost 126.1. Proposed Segment 105 is located within one of the existing underpass crossings of VA Route 615 and the Norfolk Southern Railroad. This is the second most preferred crossing by the NPS because this series of underpass structures is a primary character-defining element of this 4.7 mile section of the Parkwav. While widening the existing corridor with side-hill cuts to accommodate a four-lane interstate would dramatically change the landscape, those changes would be more consistent with existing land uses and site conditions than three of the other crossing segments-371, 372 and 376. Additional discussion of NPS conclusions follow below under Segment 105 BRP Evaluation comments.

4.5.4.12 Build Option 4

Segment 371 is the portion of Build Option 4 that crosses the BRP at Milepost 126.5. In Tables 4.5-12 OPTION 4 VISUAL IMPACT RATING Segment 371 is comprised of 18 landscape units. When combined, those units have a "medium" Visual Impact Rating. This geographic area and its defining landscape unit is comprised of rural farm and forested land uses that are currently unaffected by major transportation corridors. There are no definitive statements about the visual quality or impact ratings for Segment 371 crossing the BRP. However, NPS reviewers believe that this crossing would become a dominant visual element in the landscape and have high visual impacts directly on Parkway land resources and secondarily on view area scenic quality. Segment 371 is the third of three of the NPS's least preferred crossing options presented in the DEIS. It is the NPS's conclusion that this crossing would have high visual impacts directly on Parkway land resources and secondarily on view area scenic quality rather than the medium impact rating shown in Table 4.5-12. Additional discussion of NPS conclusions follow below under Segment 371 BRP Evaluation comments.

4.5.5 Special Visual Concern Areas

4.5.5.2 Blue Ridge Parkway

General Notes

Under the "Qualitative Analysis portion of the following five Segment Evaluation sections the cell data could not be related to the legend for visibility data displayed on Figure 4.5-1 VISIBILITY OF ALTERNATIVE CROSSINGS FROM THE BLUE RIDGE PARKWAY. The contrast of the black to gray scale of the legend did not reproduce with enough clarity to distinguish the varying visibility of the different crossings. Reviewers require additional explanation of these data and a better quality graphic.

Comments have been combined for the Segment and Option Evaluation sections as a matter of efficiency since these sections seem to be somewhat repetitive.

Segment 105 and Option la BRP Evaluation
Qualitative Analysis:

The NPS reviewers agree with the DEIS conclusions that this crossing would have moderate foreground and high middle ground impacts. The DEIS described impacts to the "cinematic experience" are described as being relatively low. This is a correct conclusion in the NPS's opinion but because there is a series of underpass structures through this 4.7-mile section of the Parkway, they become a prinrary character~efining element of the visitors' cinematic experience. The sequential experience is a series of transitions going from forested slopes to bridge underpass structures. The Segrnent 105 crossing would be wider than it currently is and more noticeable than the other underpass crossings in this specific area but it would not alter the current pattern of visual experience.

Segment 118C and Options 2b, 3, 3b and 3c BRP Evaluation
Qualitative Analysis:

The NPS reviewers agree with the DEIS conclusions that this crossing would have low foreground and middle ground impacts and that the impact on the cinematic experience would be moderate. Reviewers are not sure how to interpret the meaning of the DEIS statement, "The corridor would have its own presence as an event in the choreographed sequence, rather than just an edge between forest and grassland field." If this means that it will be more visible, and therefore must be well designed and sited as it crosses the existing Parkway landscape, then this would be agreed with.

Segment 371 and Option 4 BRP Evaluation
Qualitative Analysis:

The analysis and conclusions of these sections are well stated and express the NPS's conclusions that this crossing would greatly affect the existing Parkway landscape setting and would cause maximum potential negative visual effects.

Segment 372 and Options 1 and 1a BRP Evaluation
Qualitative Analysis:

The NPS reviewers agree with the DEIS conclusions that this crossing would also have a relatively high impact on the foreground and cinematic experience of the Parkway.

Segment 376 and Ontions 2, 2a and 2c BRP Evaluation
Qualitative Analysis:

The NPS reviewers disagree with the visual impact analysis findings included in the DEIS for the Parkway foreground, middle ground and cinematic experience for this crossing segment. This crossing would be very obvious in the Parkway's foreground and middle ground views. This is especially the situation because this segment is proposed to cross over the Parkway motor road, not under it as proposed for the other four crossings. This view area is incredibly visible for southbound Parkway traffic because of the current broad unobstructed vista off to the right or southwest. A major bridge structure carrying four lanes of traffic over the Parkway would introduce a massive obstruction into what is now a very open view area. This segment crossing lies within Parkway Scenic Resource View Area RO-15 that was deterrnined by Parkway planning staff to have a scenic quality rating of 11, or moderate scenic quality. It is relatively intact as a rural residential and farm land scene and is one of the longer duration views in the Roanoke Valley. Construction of 1-73 as described in the DEIS would degrade the intactness and visual integrity of this view are that it most certainly would become one of the least scenic views in the Roanoke Valley. The NPS characterize this view area as having more importance than does the DEIS data.

Because of the differences between the NPS and the DEIS consultant staff conclusions, and this crossing over the Parkway, this segment needs to be discussed in much more detail at the requested on-site meeting. Visual simulation of this crossing would be most useful in evaluating potential visual impacts. Please consider preparing this for NPS reviewers to evaluate.

4.5.6 Mitigating Measures

This section does not present any specific mitigating measures but there are statements about VDOT's commitment to working with the NPS to minimize impacts to the BRP once an alternative is selected. The NPS is also committed to that phase of the planning and design process of the 1-73 project. Mitigating measures are going to play a significant role in maintaining the historical significance of the Parkway's designed landscape and scenic view areas.

4.7 NATURAL RESOURCES

The following comments are not organized under a specific section but are presented by build alternative options and segments.

Option 1 & la, Segment 372, Milepost 103.6

This site is located north of Route 460 in the Ridge District and is the most northern crossing and is a heavily forested site. It would require extensive cut slopes and excavation. Much of the canopy vegetation would be lost. Very little is known by Parkway biologists about the ecology of this site. Additional field review is needed by Parkway Natural Resource Management staff and VDOT for this option.

This is one of the least preferred options since extensive forest fragmentation would occur if crossings were constructed at this site. Secondary impacts from adjacent development is likely to occur. further impacting Parkway resources.

Option 2, 2a, & 2c. Segment 376. Milepost 116.9

This segment would cross through 4 agricultural leases (parcels IM-132, IM-134, IM-135 & 1M-136). There is a small spring/seep/wetland located in lease IM-132. In addition, there is rich cove forest, just north of MP 117. A small stream (which originates from the spring/ seep), flows through the forested area. There are numerous large diameter at breast height (dbh) oaks and maples within the wooded area. All of the agricultural leases at this location are highly visible from the Parkway.

This option is not preferred from a natural resources perspective but would be acceptable. This alternative would result in moderate impacts to natural resources, but these sites are already somewhat fragmented. If this is selected as the preferred alternative, a more comprehensive biological survey would be required.

Option 2b, 3, 3b. & 3c, Segment 118 C, Milepost 121.4

This alternative uses the existing Route 220 corridor and interchange. There is one agricultural lease (parcel IM-147) located on the north side of Route 220. This 1-73 segment will take the largest amount of BRP lands (approx. 8-acres). The existing access from Route 220 to the Parkway would be eliminated under this alternative. Approximately 1/3 of the agricultural lease will be lost under this alternative.

Under this alternative, new interchanges with the Parkway are proposed using existing state roads, but the DEIS does not really go into much detail about these interchanges or how much land they would impact.

Despite the fact that this alternative takes the most amount of land from the Parkway, this is the preferred alternative from a natural resource perspective because it uses an already heavily disturbed area--the existing U.S. Route 220 corridor.

The DEIS should be revised to include maps and additional information on the alternatives for the new interchange with the parkway. It is difficult to judge the total impact to the Parkway at this site without this additional information.

Mitigating measures should insure that vegetation which currently screens the Rocky Dale Quarry from the Parkway is left intact.

Option 3a Sezment 105, Milepost 124.1

This proposed crossing is located at the bridge over the Norfolk Southern Railroad and Route 615. 1-73 would cross under the Parkway here.

This area consists of a moderately steep ridgeline containing a xeric (dry) pine~ak forest. Dominant tree species include red oak, white oak, Virginia pine, eastern hemlock, mountain laurel and blueberry. Hurricane Hugo and recent ice storrns have heavily impacted this area. More than 70 percent of the canopy trees have some ice damage to them. Botanically. this is a unique area because it is recovering from several "natural" disturbances. The University of Tennessee has looked at this area as part of a study involving patterns of vegetation disturbance and recovery in the southern Appalachians.

Part of the 1-73 corridor would run through the 28-acre t'Lipscomb" Tract which was acquired by the Parkway during Summer 2000. The DEIS does not show the new BRP boundary. We suspect that more acreage would actually be taken from the Parkway than the 3.37 acres listed in the DEIS.

This is one of the least preferred options from a natural resource point of view because crossings would result in extensive forest fragmentation and loss of canopy vegetation. Secondary impacts resulting from adjacent development along the new interstate would result in still further impacts to parkway resources.

From a natural resource perspective, this option could heavily impact the Parkway. The forested area is still relatively intact; a unique situation since much of the Parkway in the Roanoke Valley has been heavily fragmented by development and roads. Extensive excavation would be required that would greatly alter a unique biological community. If this area becomes the preferred alternative, a more comprehensive biological survey of this area will be needed.

The DEIS should be revised to reflect the additional acreage of NPS lands recently acquired (Lipscomb Tract) that would be lost to 1-73 if this option is selected. Also, the Parkway may want to seek additional compensation (purchase of additional land somewhere else, etc.) for any use of the Lipscomb Tract. since the NPS has already invested considerable time and money in the acquisition of this tract.

Option 4, Segment 371, Milepost 126.5

This crossing is located 1/3 mile south of Mason's Knob Overlook. Agricultural lease IN-104, a small pasture lease. is located just to the north of the proposed crossing. This site is a mix of forest and small open farnil and. Extensive removal of canopy vegetation would likely be required. Several small strearns may also be eliminated by this crossing. No biological inventories have been conducted at this site. This site is slightly more fragmented than the previous site, primarily due to housing developments being constructed nearby. Natural resource information is generally lacking for this site. We strongly recommend that a biological survey of this area be conducted prior to further consideration of this site as a possible crossing.

This option is not preferred but would be acceptable. This alternative would result in moderate impacts to natural resources, but this site is already somewhat impacted.

4.9 HISTORIC AND ARCHEOLOGICAL RESOURCES

4.9.1 ARCHITECTURAL RESOURCES

NPS reviewers agree with the Virginia Department of Historic Resources determination that all build alternative options involving the BRP will use land from the Parkway, diminishing several aspects of its integrity and that all options are expected to have an adverse effect on the Parkway.

4.10 PARKLAND CONSEQUENCES

4.10.2 Environmental Consequences

Agency reviewers note that until this point in the DEIS there has been no discussion, or at least no direct description of how each segment of the build options would cross the Parkway as under or overpasses. As described Options 2, 2a and 2c (Segment 376) would cross over the Parkway. This option has serious visual impact implications for the Parkway foreground, middle ground and cinematic experience in this view area. Certainly, this proposed overpass is problematic with respect to effective mitigating measures. The U.S. Route 460 bridge overpass utilized as a mitigation measure stone masonry walls and arches to carry out the architectural theme of stone masonry bridges utilized throughout the Roanoke Valley. The discussion of proximity of interchanges is not coupled with statements about NPS concerns related to additional secondary impacts caused by visible interchanges. Potential impacts include night light intrusion from lighted interchanges, scale and mass of sound bar'riers, addition of lighted signage in advance df interchanges, and potential to cause land use changes adjacent to the interchanges and beyond. All of these secondary effects will need to be considered further prior to VDOT selecting the preferred option to be implemented. These are points of discussion to be addressed during the requested on-site meeting.

4.12 SECONDARY AND CUMULATIVE IMPACTS

General Comment:

Text description and tables in this section do not present. evaluate or compare secondary impacts of 1-73 project option segments or landscape units in terms of their potential effect on the Blue Ridge Parkway's scenic view areas. It describes land use change generally but not specifically related to Parkway view areas or the implications for crossings to lower Parkway view area scenic quality. The 1-73 project is not discussed cumulatively and in relation to existing major crossings and other major highway projects being proposed to cross the Parkway in Virginia.

However, the DEIS implies that change is inevitable so that a decline in the visual and scenic quality of the BRP is inevitable.

In spite of this apparent assumption. there are no maps included to show where the 28 percent of the land that is already planned for conversion from undeveloped to developed is located. This data presented on a landscape unit scale would certainly affect the NPS's evaluation and preference towards crossing options. Again the NPS requests that this data be presented at the requested on-site meeting with the VDOT and others.

4.13 SECTION 4(f)

4.13.1.2 Description of Section 4(f) Property

Table 4.134 lists overlooks that may be affected, but it does not list or discuss non-overlook view area vistas that have been identified throughout the entire project area by the NPS. These locations and the scenic quality ratings for these view areas should have been an integral part of the Section 4(f) Parkway discussion. View area vistas are a maintained design element of the Parkway just as are the overlooks. The inventory and assessment of potential impacts affecting view areas is important because not all of the affected view areas are of the same scenic quality, thus this be caused by the various options.

4.13.1.5 Measures to Minimize Harm

The NPS wants to emphasize the importance of the separate memorandum of agreement and the commitment to working with the VDOT if a build alternative is selected to minimize degradation of resources and to maintain a quality visitor experience of the Parkway. The identification of design standards, final alignment location, mitigating measures and management of Parkway closures would be principle topic areas for inclusion in the Memorandum of Agreement (MOA).

4.14 TEMPORARY EFFECTS DURING CONSTRUCTION ACTIVITIES

General Comment

Given the nature of the build option crossings of the Parkway with the construction of major bridge structures either over or carrying the Parkway, it would appear that the Parkway motor road would need to be completely closed to traffic for some length of time. Details related to closing the Parkway and potential inconveniences for Parkway visitors is a major concern of the NPS. The details of roadway closure and detours are a key area to be worked out between the VDOT and the NPS.

4.15 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

4.15.6 Aesthetics

The conclusion that construction of 1-73 would not have a long-term visual impact on the BRP because of mitigating measures and on-going sub-urbanization seems to be missing the point. If constructed. 1-73 would result in the introduction of a major visual intrusion into Parkway view areas. These view areas foreground are now characterized by forested, rural or suburban land uses. A four-lane highway being constructed within any view area will irretrievably affect its scenic quality negatively and diminish the visitor experience through that section of the Parkway. The tone of this DEIS section minimizes the cumulative impacts to Parkway resources arising from the proposal and other changes. An MOA and a cooperative effort in implementing mitigation measures are critical to the overall success of this project. Success for the NPS is based upon providing visitors a scenic experience of viewing undeveloped forest lands and rural landscapes.

SUMMARY of NPS CONCERNS

Before the VDOT selects a preferred corridor and prepares the final EIS, the NPS has two concerns to discuss with VDOT. The first concern is that this document minimizes the level of detail in the affected environment chapter and talks more about process than description of the affected environment, the issue being the absence of substantive data to compare the merits of the five option segments crossing the BRP or impacting the Appalachian National Scenic Trail's scenic viewshed. Secondly, inventory and impact analysis data are generalized into segment or option level of detail. However, for both the Appalachian National Scenic Trail and the BRP, specific landscape unit data are needed to effectively evaluate build alternative options and provide more meaningful comments to VDOT.

In summation, the NPS reviewers have a number of concerns that are not adequately addressed in the draft. Before the NPS will finalize its position. the NPS requests that the VDOT schedule an on-site meeting in Roanoke, Virginia with Appalachian National Scenic Trail and BRP planning staff and representatives of other land-managing agencies charged with stewardship of our Nation's parks and forests, the FHWA and appropriate DEIS consultant staff. The meeting purpose would be to review affected visual environment and environmental consequences data specific to the five segments and their associated landscape units crossing the Parkway and visible from the Appalachian National Scenic Trail. This meeting should be scheduled as soon as possible so that the concerns identified above can be addressed in the final EIS.

Prior to attending the meeting Appalachian National Scenic Trail and BRP staff would like to receive copies of the Visual Quality and Parklands Technical Memoranda prepared for this project by members of the DEIS consultant team. Also copies of proposed crossing visual simulations or other graphic materials that further illustrate build alternatives are also requested. The DEIS referenced a FHWA publication Visual Impact Assessment for Highway Proiects, 1981, and both the Appalachian Trail and Parkway staff request that they be provided a copy each of that manual for their use in reviewing the DEIS. These technical documents would assist NPS staff in further evaluating potential impacts and making recommendations for preferences of the five build crossings potentially affecting visual resources.

Please schedule meetings with, and transmit requested written and graphic materials to Don Owen of the Appalachian National Scenic Trail, at (304) 535-4003, and Gary Johnson of the BRP, at (828) 271-4744; extension 210. Thank you for your assistance in this matter and we look forward to an early and productive meeting.

FISH AND WILDLIFE SERVICE (FWS) RESOURCES

Endangered Species Act Comments

The federally endangered Roanoke logperch (Percina rex) is found throughout the Roanoke River drainage basin in the project study area. The federally endangered smooth coneflower (Echinacea laevigata) is documented in the project study area. The federally endangered northeastern bulrush (Scirpus ancistrochaaetus) and Indiana bat (Myotis sodalis) may also occur in the project study area.

A species of freshwater mussel was recently documented in the Dan River drainage in Stokes County, North Carolina. At this time, the taxonomic status of this mussel is undetermined and DNA analysis is ongoing. It is possible that this mussel is a federally listed species. Therefore, the FWS will recommend that the Federal Highway Administration and the VDOT conduct surveys for this mussel for various project alternatives within the Dan River drainage.

The FWS recommends further coordination with FHWA and VDOT to determine the extent of all endangered species occurrence within the project study area and specifically, along the corridor of each project alternative. As the FWS stated in its letter to FHWA dated September 12, 2000, the FWS recommends a meeting with all interested parties to discuss these listed species and the need for surveys within the study area. This meeting should include species experts, for the species listed above, to discuss survey needs and likely species occurrence within the study area.

The FWS notes that a Biological Assessment (BA) has not yet been prepared for this project. The BA should be included in the final EIS. Guidelines for preparation of a BA were provided by the FWS to the FHwA in its letter dated September 12, 2000.

The FWS recommends that all survey results be included in the BA that will be included in the final EIS. In order to prevent any unnecessary project delays, the FWS recommends that all endangered species coordination be completed as soon as possible. If the BA does not thoroughly address the impacts of the various alternatives on all federally listed species, the FWS may seek referral of this project to the Council on Environmental Quality pursuant to 40 CFR 1504.

Fish and Wildlife Coordination Act Comments

The FWS is concerned about the large scale impacts to forested habitat and farmland that are likely to occur if this project is constructed. All candidate build alternatives would adversely impact thousands of acres of natural habitat and fannnland. Such federally-funded habitat destruction would have substantial negative impacts on the fish and wildlife resources in the construction area and wildlife-related recreation. FWS notes that in 1996 for example, 77 million U.S. residents of age 16 and older expended over 100 billion dollars on fishing, hunting, and other fish and wildlife related recreation (DOI - 1996). The FWS does not support the expenditure of Federal funds that results in unmitigated destruction of fish and wildlife habitat.

The FWS recommends habitat restoration/enhancernent, offsetting negative impacts to fish and wildlife. as well as wildlife-related recreation. Habitat/riparian/floodplain restoration/reforestation or establishment of vegetated buffers along field edges are some of many options that should be considered.

Literature Cited

The DOI, Fish and Wildlife Service and U.S. Department of Commerce, Bureau of the Census. 1996 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation.

GEOLOGICAL/BIOLOGICAL RESOURCES:

Page 3.7-9, Chapter 3.0 AFFECTED ENVIRONMENT, Section 3.7 Natural Resources,
Subsection 3.7.2.1 Forest Lands, Paragraph 3.7.2.1.5 Wildlife Species Associated with Forest Habitat:

The report mentions white-tailed deer (Odocoile S virginianus) as occurring in the proposed project
location. And, while some mitigation for wildlife was suggested (page 4.7-3, Chapter 4.0
ENVIRONMENTAL CONSEQUENCES, Section 4.7 NATURAL RESOURCES, Paragraph 4.7.3
Mitigation), nothing was said about preventing white-tailed deer/vehicle collisions.

To address this issue, the U.S. Geological Survey (USGS) recommends consideration of two current research projects. Although the second project focuses on mule deer (O.hemionus), the highway behavior paflerns of the two deer species are similar: Effectiveness of big game highway crossing structures, and hierarchical approach for studying mule deer behavior and habitat relationships.

Descriptions of these projects can be accessed from the USGS URL http://biology.usgs.gov, under
Current Projects, mule deer, or under Coop Units, Utah Cooperative Fish and Wildlife Research Unit.
Research Projects, Mule deer.

We appreciate the opportunity to offer comments on this project. For additional information regarding park and recreation resources please contact Don Owen of the Appalachian National Scenic Trail at this number: (304) 535-4003, and Gary Johnson of the BRP, at (828) 271-4744; extension 210. For information regarding fish and wildlife resources please contact Mr. William Hester of the Virginia Field Office, FWS at (804) 693-6694; extension 134. For information on geological/biological resources. please contact Ms. Michalann Harthill (703) 648-4077, of the U.S. Geological Survey.

Sincerely,



Willie R. Taylor
Director, Office of Environmental Policy and Compliance

COMMONWEALTH of VlRGINIA
DEPARTMENT OF TRANSPORTATION
1401 EAST BROAD STREET
RICHMOND, 23219-2000

CHARLES D. NOTTINGHAM , COMMISSIONER
J. T. MILLS , STATE LOCATION AND DESIGN ENGINEER


February 23, 2001

Mr. Don Owen C/O ATPO
Harpers Ferry Center
Harpers Ferry, West Virginia 25425

Mr. Gary Johnson
Blue Ridge Parkway
199 Hemphill Knob Road
Asheville, North Carolina 28803

Dear Mr. Owen and Mr. Johnson:

We have received comments from the Department of the Interior regarding the Draft Environmental Impact Statement (DEIS) for the 1-73 Location Corridor Study between Roanoke and the North Carolina State Line. Included in these comments were those from the Appalachian National Scenic Trail and the Blue Ridge Parkway among other interests.

After reading these comments it becarne very evident that we should have provided both of these groups with a copy of the Visual Quality Technical Memorandum which has been prepared in conjunction with the DEIS. This additional information should enable you to better understand how the specific findings were developed.

We hope this document also will address the concerns that have been raised in the Department of the Interior's letter. If, following your review of the Visual Quality Technical Memorandum, you still feel a meeting will be necessary, please contact Mr. Mark Wittkofski, in our Environmental Division at (804) 371-6867) or myself at (804) 786-2566 and we will try to set one up towards the middle of March to discuss your concerns further.

We appreciate your thorough review of the documentation leading up to the publication of the DEIS and hope that this supplemental information will serve to further enhance your understanding of the reasoning of the findings and conclusions in the DEIS. We regret that this information had not been provided with the DEIS, and apologize for any inconvenience that the additional review time required for this material may cause. We look forward to your comments and as stated above we will be more than glad to meet to discuss this additional information.

Thank you again for your review of this material and your continued interest in this most important highway project.

Sincerely,

Patsy Napier
Transportation Engineer
Program Manager

Cc:
Mr. Roberto Fonseca-Martinez
Mr. Ed Sundra
Mr. Fred Altizer
Mr. Earl T. Robb
Mr. Calvin Boles

WE KEEP VIRGINIA MOVING

L3027

March 13, 2001


Mn Earl T. Robb
State Environmental Administrator
Virginia Department of Transportation
1401 East Broad Street
Richmond, Virginia 23219-2000

Dear Mr. Robb:

We have received and reviewed the Visual Quality Technical Memorandum for the 1-73 Location Study Between Roanoke and the North Carolina State Line, Corrrrnonwealth of Virginia Draff Environmental Impact Statement (DElS) and Draft Section 4(f) Evaluation-FHWA-VA- EIS-NH-962-2 (004), State Project: 0073-962-F01, PE101. We appreciate the opportunity to review the visual inventory and analysis data included in the technical memorandum.

The memorandum provided the visual quality data required for us to better understand the five proposed build alternatives. Based upon our review, we agree with the stated effects on the Blue Ridge Parkway for segments 371 (build options 4) and 372 (build options 1 and 1a). These two segments and associated build options located at Milepost 126.5 and 103.6 have the maximum potential for visibility from the Parkway motor road vistas and paved parking overlooks. Visual impacts would be substantially adverse for both of these two segments. The National Park Service (NPS) continues to find these two segments the least preferred of the proposed Parkway crossings. This conclusion is based on the Service's understanding of the potential for visual quality and natural resource impacts resulting from either segment crossing.

Segment 118C at Milepost 121.4, included in build options 2b, 3, 3b and 3c continues to be the most preferred crossing of the Blue Ridge Parkway. From the visual quality and natural resource data provided, NPS reviewers find that constructing an interstate highway within the existing U.S. Route 220 is the most preferred crossing option. Segment 105 at Milepost 124.1 is the next most preferred crossing from the potential for visual resource impacts. However, this crossing would result in extensive forest fragmentation and loss of canopy vegetation and is one of the least preferred crossings based upon natural resource impacts. If this option is selected then agreeing on mitigating measures will be critical.

Segment 376 located at Milepost 116.9 is included in build options 2, 2a, and 2c. According to the technical memorandum analysis this crossing provides the lowest visibility from the Blue Ridge Parkway and would have the least effect on visual quality. However, in the draft environmental impact statement this segment is described as an overpass crossing which seems to be directly contradicting the visual analysis effect finding.

Review of the technical memorandum did not resolve two issues-1. Conflicting visual analysis data and proposed overpass crossing of segment 376, and 2. Visual impact score of "none" for segments 118C and 371. While the technical memorandum data is helpful, we respectively request a meeting on-site to review the crossing details to obtain answers to the above questions. After the meeting, Blue Ridge Parkway management will provide you with a prioritized list of most to least preferred crossings.

By copy of this memorandum we are requesting that Mr. Mark Wittkofski in VDQT's Environmental Division arrange an on-site meeting in Roanoke for April 4th or 5th This request is in accordance with Patsy Napier, VDOT Program Manager letter dated February 23, 2001. Please advise Mr. Gary Johnson, Chief Resource Planning and Professional Services Division of the scheduled meeting date at (828) 271-4744 or e-mail gary_w_Johnson@nps.gov.

Thank you for providing us the technical memorandum. It was very helpful. We look forward to further discussions about the 1-73 alternative build options.

Sincerely

Daniel W. Brown
Superintendent


cc:


Mr. Don Owen c/o ATPO
Harpers Ferry Center
Harpers Ferry, WV 25425

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

Mr. C. F. Boles
Assistant Division Administrator
Virginia Department of Transportation
1401 East Broad Street
Richmond, VA 23219

Mr. Fred Altizer
District Administrator
Virginia Department of Transportation
P.O. Box 3071
Salem, VA 24153

Mr. Mark Wittkofski
Environmental Division
Virginia Department of Transportation
1401 East Broad Street
Richmond, VA 23219

Gjohnson:bk:3/13/01:271-4770x210

L3027

April 12, 2001


Mr, Roberto Fonseca-Martinez
Division Administrator
Federal Highway Administration
Post Office Box 10249
400 North 8th Street, Room 750
Richmond, Virginia 23240

Dear Mr. Fonseca-Martinez:

We have reviewed the 1-73 Location Study Between Roanoke and the North Carolina State Line Commonwealth of Virginia Draft Environmental Impact Statement (DEIS) and Draft Section 4(f) Evaluation FHWA-VA-EIS-NH-962-2, State Project: 0073-962-f01,PE 101; Visual Quality Technical Memorandum, October 2000; and 1-73 Location Study. In addition to reviewing the referenced documents, Gary Johnson, Chief Resource Planning and Professional Services Division, met with Virginia Department of Transportation (VDOT) and project consultant staffs in Roanoke, Virginia on April 5, 2001 to discuss the five build option segments that may potentially cross the Blue Ridge Parkway. The meeting was most informative and we appreciate the opportunity to directly discuss Segments 105, 118C, 371, 372, and 376 with VDOT and consulting staffs.

Based upon review of pertinent documents and our discussions, Parkway staff and management offer the following preferences and conclusions on potential 1-73 crossings of the Parkway.

Most Preferred Crossing - The National Park Service's most preferred crossing of the Blue Ridge Parkway is segment 118C, Milepost 121.4 included in Build Alternative Options 2b, 3, 3b, and 3c. This is the existing four-lane corridor of U.S. Route 220, a major transportation corridor that has been a part of the Parkway visitor driving experience since the Parkway was constructed through the Roanoke Valley during the late 1950's and early 1960's. Widening of the U.S, 220 corridor to accommodate 1-73 will further impact this area of the Parkway, but the landscape changes would be more consistent with existing land use than they would be in the other four proposed Parkway crossing locations. Mitigating measures should insure that vegetation that currently screens the Rocky Dale Quarry from the Parkway is left intact.

Despite the fact that this alternative would require the most land from the Parkway, this is the preferred build option from a natural resources perspective because it uses an already heavily disturbed area- the existing U.S. Route 220 corridor.

However this crossing would eliminate the existing Parkway interchange with U.S. 220 and the options for providing a connection between 1-73 and the Parkway are less-than satisfactory. As you know Parkway planning staft VDOT and consulting staff all have studied possible connections. To date all of the studied routes would require visitors exiting 1-73 to follow frontage roads, two other city streets and then finally connect with the Parkway motor road via Mill Mountain Spur Road. Finding a more direct connection while maintaining ample driving time to transition from an interstate highway to the Parkway is a major concern to us. Mso the difficulty of way finding for travelers is a concern. The scenic quality of the route is a very important factor for the route as well.

Second Most Preferred Crossing -Segment 376, Milepost 116.9 is in a section of Parkway dominated by rural farm and residential use. This portion of Parkway lies midway between U.S. Route 24 and U.S. Route 220. Views of major road corridors in this area and within Parkway view areas are inconsequential. The narrow secondary routes that cross the Parkway do so under or over the Parkway on picturesque stone arch bridges. These structures are so well placed and their scale is such that they enhance the overall driving experience and do not dominate it.

An interstate highway constructed to underpass the Parkway through this area with its scale, mass and engineered character could overpower the current landscape setting. But after fiarther study by our Resource Planning staff, we believe that an alignment carried across the Parkway on an overpass has great merit and it is our second most preferred crossing. The Parkway, as it comes out of the forest from the north and enters this rural landscape setting, passes through a cut section where the topography rises above the motor road on both sides. This area with some additional earthwork-fill offers an opportunity to create a crossing that could follow the existing landform pattern thus lying more gently on the landscape. By crossing the Parkway overhead much of the interstate alignment would not be visible to the Parkway traveler because they would be below the grade-separated structure and cut slopes. Placement of trees and shrubs along the interstate corridor would flirther soften and screen the four-lane corridor from view. Please see the three-page enclosure that graphically illustrates our thoughts on this overpass crossing.

This segment would cross through four agricultural leases one of which has a small wetland area. In addition just north of milepost 117, there is a rich cove forest where there are numerous large diameter oaks and maples. This option is not the most preferred from a natural resource perspective but would be acceptable because resources are already somewhat fragmented. If this build option is selected a more in depth and comprehensive biological survey would be required to address mitigating measures.

Noise, land use changes, and view area scenic quality impacts are of great concern in this location and degree of impacts would be directly proportional to the alignment location scale of cuts and fills, and mitigating measures such as the placement of vegetation to buffer the road corridor.

Third Most Preferred Crossing- After reviewing all available materials and including staff input, we now rank Segment 105, Milepost 124.1 included in Build Alternative Option 3a as our third most preferred crossing location. This ranking is based upon our understanding of potential visual and natural resources impacts and consistency of the visitor experience through this section of Parkway perspective. Between Parkway Milepost 121.4 at U.S. Route 220 and Milepost 126.1 there are four Virginia Secondary Route underpass crossings of the Parkway. Proposed Segment 105 is located between the existing underpass crossings of VA Route 615 and the Norfolk Southern Railroad and VA Route 613. This series of underpass structures are a primary character-defining element of this 4.7-mile section of Parkway. While construction of a new corridor with side-hill cuts to accommodate a four-lane interstate would dramatically change the landscape, the crossing of another road corridor would be more consistent with the existing visitor's experience of encountering a series of roads over passed by the Parkway motor road. Existing land uses and site conditions made visible by this underpass crossing would be more consistent with the current experience here than at the other three locations which are characterized by forest covered slopes or rolling rural residential and farmlands.

From a natural resources perspective, this is a less preferred option than Segments 118C and 376 because crossing here would result in extensive forest fragmentation and loss of canopy vegetation. In our review of the visual simulation for this crossing the extent of forest cover being removed is very obvious. If this option were selected, planting cut slopes would be an important and necessary mitigation to be applied here.

Least Preferred Crossings - Two of the remaining three segments--Segment 371, Milepost 126.5, and Segment 372, Milepost 103.6 included in Build Alternative Options 4; and 1 and 1a, respectively are grouped together as the Service's least preferred of the proposed crossings. The construction of an interstate highway in both of these Parkway landscape settings would dramatically change the existing view area scenic quality, and land uses, all of which are absent of major roads seen from or crossing the Parkway. Increases in highway noise generated by interstate highway traffic volumes and vehicle speed would radically alter existing site noise conditions

Segment 371, Milepost 126.5 is the southernmost proposed segment, characterized by forest cover and is just south of Masons Knob Parking Overlook, a paved parking area for 28 cars. Both the existing land use and the proximity of Segment 371 to a formal overlook parking area are of great concern to the NPS. Noise increases, land use changes and view area scenic quality impacts form the basis for this being a least preferred crossing option. This build option would result in moderate impacts to natural resources, but the site is already somewhat impacted, so while it is not preferred this would be an acceptable option.

Segment 372, Milepost 103.6 is the northernmost proposed crossing of the Parkway. Between Parkway Milepost 90 and 104 the Parkway traverses primarily National Forest land and the visitor experience is dominated by a forested road corridor with vistas of undeveloped forestlands. From Milepost 104 to 105.8 land use is rural residential with U.S.460 crossing the Parkway at Milepost 105.8. The introduction of another four-lane highway, especially one meeting interstate standards, into this forest dominated setting greatly alters the existing visitor experience. Again increased noise, changes in land use and view area scenic quality impacts form the basis for this being a least preferred crossing option. From a natural resources perspective this is one of the least preferred options because there would be extensive forest fragmentation.

Again, we want to emphasize the importance of a separate memorandum of agreement (MOA) and our commitment to working with the Federal Highway Administration and VDOT if a build alternative is selected. Our goal is to minimize the degradation and long-term impairment of Parkway resources and to maintain a quality visitor experience for Parkway travelers. The identification of design standards, final alignment location, mitigating measures and management of Parkway closures would be principle topics for inclusion in the MOA.

We understand that for you and us this is a long and tedious undertaking. Both FHWA and VDOT continue to meet our requests for information and discussion on this project and it is very much appreciated. If this project comes to fruition, it will take cooperation by all parties involved to meet the numerous goals and needs that we each have. Mr. Gary Johnson will continue to coordinate this project for the Parkway and he can be reached by telephone at 828/271-4744 ext. 210 to discuss this letter as needed.

Sincerely,

(SGN) JOSEPH W. AULL


Daniel W. Brown Superintendent

Enclosure

cc:
Plateau District Ranger w/enclosure
Plateau District Facility Manager w/enclosure

Mr. Willie R. Taylor w/enclosure
Director, Office of Environmental Policy and Compliance
United States Department of the Interior
Office of the Secretary
Washington, D.C. 20240

Ms. Pam Underhill
Park Manager
Appalachian National Scenic Trail
Harpers Ferry Center
Harpers Ferrv, West Virginia 25425

Mr. C. F. Boles, III w/enclosure
Assistant Division Administrator
Virginia Department of Transportation
1401 East Broad Street
Richmond, Virginia 23219-2000

Mr. Earl T. Robb wlenclosure
State Environmental Administrator
Virginia Department of Transportation
1401 East Broad Street
Richmond, Virginia 23219-2000

Mr. Fred Altizer
District Administrator
Virginia Department of Transportation
P.O. Box 3071
Salem, Virginia 24153

Gjohnson:bk.4/12/01 :271-4779xl10

Overpass Study Concept Pictures