April 12, 1996

Stephen J. Long
Virginia Department of Transportation
1401 East Broad St.
Richmond, Virginia 23219-1939

Re: Western Washington Bypass Major Investment Study

Dear Mr. Long

Thank you for the extension of the time frame for which to comment on the above referenced project. This project was presented to the agencies at the Interagency Coordination Meeting (IACM) on March 19, 1996. This letter is our written response for the record of that meeting.

The Virginia Department of Transportation (VDOT) previously coordinated this project on December 5th, 1995. The Purpose and Need (P&N) were presented and written documentation provided. EPA was present for the presentation and reviewed the documentation. EPA had several comments, questions and concerns at that time (see attached letter). VDOT, to our knowledge, has not addressed our concerns regarding the P&N, yet at the March 19 1996 IACM meeting presented what was referred to as the final selection of alternatives.

EPA understands that this project is considered a Major Investment Study (MIS) and that document preparation under the National Environmental Policy Act (NEPA) has yet to begin. The MIS process, as EPA understands it, calls for he early coordination and attempted resolution of environmental agency concerns. The MIS process is not prescriptive in this regard but is clear that the concerns of the environmental agencies should be addressed. EPA is concerned that VDOT has chosen to move ahead with the selection of alternatives without clarifying or resolving the issues related to purpose and need.

EPA recommends, in interest of full disclosure of the issues and in fairness to the local jurisdictions who will likely make planning decision based on the results of the MIS, that agency concurrence be sought at the major milestone for this project beginning with purpose and need. Resolving issues early and obtaining concurrence with major project milestones is a fundamental tenant of the MIS that will help ensure a smooth NEPA and permitting process thereby avoiding potential delays in project implementation in the future.

EPA recommends that the issues of purpose and need and the selection of alternatives be discussed at an upcoming IACM with concurrence requested after the concerns have been addressed to a reasonable level of satisfaction.

Thank you for this opportunity to comment. If you have any questions regarding this letter please feel free to contact Mr. Peter Stokely or my staff at 215-597-9922.

Sincerely,

Roy E. Denmark, Jr.
NEPA Program Manager

Copies Furnished:
U.S. Fish and Wildlife Service, White Marsh
Corps of Engineers, Norfolk District
Federal Highway Administration, Richmond


Return toThe List