April 20, 2006

Mr. Christopher Collins, Project Study Manager

Virginia Department of Transportation

1401 East Broad Street

Richmond, VA 23219

Dear Mr. Collins:

The Virginia Association for Parks appreciates the opportunity to comment on the Interstate 81 Tier 1 Draft Environmental Impact Statement. While we support balanced transportation planning, we have a number of concerns about the study and the related methodology.

First and foremost, we think that the study is fundamentally and fatally flawed in its approach to the rail component. The study’s view of the problem and the solution as being constrained within Virginia’s borders is neither prudent nor realistic. We believe that a multi-state rail approach must be one of the considered options.

Both Pennsylvania and Tennessee are faced with the same problem as Virginia regarding I-81 traffic. This fact, plus the fact that the longer the distance covered, the more cost effective inter-modal transfer from truck to rail to truck becomes, and the fact that railroads produce one- third the pollution and use one-fifth the energy to move a ton mile of freight, argue strongly for consideration of a multi-state rail component. Another point that argues for a multi-state rail component is that railroads seldom need more land to add significant new capacity. And, last, but not least, a multi-state approach to the problem and the solution should result in increased financing opportunities, subsidies, and tax credits to more effectively address the problem.

The virtually one-dimensional paving approach the study proposes will result in additional air pollution and environmental damage to an already much suffering area in these respects. For example, the Blue Ridge Parkway is experiencing air pollution problems and the Shenandoah National Park is already the third most polluted park in the country due to air pollution resulting in large part from automobile and truck discharges. Also, any plan should include a complete study and mitigation of the impact it will have on the numerous historic resources of the Shenandoah Valley including Cedar Creek Battlefield and the historic sites of the Shenandoah Valley Battlefields National Historic District.

Virginia also has a number of state parks and natural areas located along the I-81 corridor that would suffer adverse consequences from the pollution, increased road traffic, and tolls that would result from the proposed project. These state parks and natural areas include the Raymond Andy Guest Shenandoah River State Park, Sky Meadows State Park, Goshen Pass Natural Area, Poor Mountain Natural Area Preserve, Claytor Lake State Park, Shot Tower and New River Trail State Park, and Hungry Mother State Park. We question the adequacy of the study’s assessment of related impacts on the state parks and natural areas along the I-81 corridor.

In sum, we urge you to expand the study to seek lower cost, lower impact alternatives to the present proposal, including consideration of a multi-state rail component that would extend into Pennsylvania and Tennessee.

Sincerely,

Johnny Finch, President

Virginia Association for Parks

Cc: Governor Timothy M. Kaine

Senator John Warner

Senator George Allen

Representative Eric I. Cantor

Representative Frederick Boucher

Representative Virgil H.Goode, Jr.

Representative Robert W. Goodlatte

Senator H. Russell Potts, Jr.

Senator Mark D. Obenshain

Senator R. Edward Houck

Senator Emmett W. Hanger, Jr.

Senator R. Creigh Deeds

Senator Stephen D. Newman

Senator J. Brandon Bell, II

Senator W. Roscoe Reynolds

Senator Phillip P. Puckett

Senator William C. Wampler, Jr.

Delegate Beverly J. Sherwood

Delegate Joe T. May

Delegate Clifford L. Athey, Jr.

Delegate C. Todd Gilbert

Delegate Edward T. Scott

Delegate R. Steven Landes

Delegate Rob B. Bell, III

Delegate Benjamin L. Cline

Delegate Watkins Abbitt, Jr.

Delegate Lacey E. Putney

Delegate H. Morgan Griffith

Delegate David A. Nutter

Delegate Allen W. Dudley

Delegate C. W. Carrico

Delegate Joseph P. Johnson, Jr.