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Southeastern Regional Parkway
Position
Paper
Mr. Ken Wilkinson, SEPG Project Engineer
Virginia
Department
of Transportation
Sent VIA Email: sepg@virginiadot.org/SEPG
Dear Mr. Wilkinson,
The Back Bay
Restoration Foundation (BBRF) is a 501(c) (3) non-profit group committed
to the restoration, preservation and enhancement of
Back Bay
, its watershed, immediate tributaries and adjacent environs.
We
have approximately 700 members and appreciate the opportunity to comment on the
draft environmental impact statement (DEIS).
A number of
BBRF members attended the Public Hearing at the Virginia Beach Pavilion or the
Chesapeake
Conference
Center
the week of 11 July. I have learned
that the comments period has been extended until
August 8, 2005
. Even with this extension, it
is not a generous comment period given the extent and timing of the proposed
project. VDOT released an EIS
document consisting of more than 300 pages, plus reference material just a few
weeks prior to the Hearings. It’s very difficult for most people who work to
devote the time necessary to read and evaluate the project in short order.
I do question the need for the whole project. As we know
there is still a strong possibility that NAS Oceana will be closing before any
Southeast Parkway
could be completed. Regarding hurricane evacuation, it is clear that getting traffic to I-64
faster serves no purpose, because that is where the real bottleneck occurs. The
widening of I-64 between I-464 and Bowers Hill is a high priority, but that
improvement is not in the 2026
Long
Range
plan due to funding constraints. The
I-64 and Oak Grove Connector would be a better use of funds.
The section of I-64 between Oak Grove and Bowers Hill is the only passage to the
point at which the western escape routes on RT 58 and RT 460 converge.
These projects would also involve relatively minimal impacts to aquatic
resources.
Each day when I go
to work I travel along
Elbow Rd
and
Indian River Rd.
At
no point during the day have I encountered significant traffic problems.
However,
Indian River Rd
has NO shoulders, which is dangerous.
Improvements should be made to include shoulders
and bicycle paths along the length of
Indian River Rd.
It
is also noted that the DEIS dismisses light rail without mentioning the new
developments at
Town
Center
.
The construction of the SEP would result in the direct loss
of far more wetlands than any roadway project constructed in
Virginia
in modern times. It is highly unlikely that the functions and values of some of the
wetland types to be lost as a result of the project, such as deep swamp or
semi-permanently inundated wetlands, can be replaced by restoration of
previously converted croplands.
This
is a critical project for
Back Bay
- it cuts through the headwaters and much of the drainage, cutting
off hydrologic flows to the Bay, already on the list of impaired waters by the
state. This project cuts across the
headwaters and upper drainage areas of the Back Bay Wildlife Refuge and the
North
Landing
River
that drains into the
North Carolina
coastal bays. The project area
is critical to the health of these watersheds, yet there is no discussion of
those broader impacts. The Back Bay Wildlife Refuge is under great
pressure from development. It is
undergoing a water quality/TMDL evaluation that this project may impact. Yet
the Draft EIS doesn't even deal with the Back Bay/Albemarle/Southern Rivers
issues. On
the maps that I saw at the Hearing,
North
Landing
River
wasn’t even shown!
The bottomland
hardwood wetlands associated with Gum Swamp, West Neck Creek, and the North
Landing River are of particularly high value, and the areas where the SEP is
proposed to cross these systems are largely undisturbed by other roadways or
development. There are mature
stands of Swamp
Tupelo
, Swamp
Cottonwood
and
Cypress
.
These bottomland hardwood wetlands form critical habitat for birds
needing deep woods such as the Prothonatary
Warbler, which is declining. It
is also excellent habitat for Wood Ducks, Woodpeckers and Barred Owls.
The document indicates that the floodway associated with
Gum
Swamp
,
North
Landing
River
, and West Neck Creek may be bridged. The
floodway and 100-year floodplain associated with these three waterways should be
bridged to minimize project impacts to these high value aquatic resources.
However, these areas will be impacted even if crossed on bridges due to
fragmentation of the habitat and disruption of the hydrology.
Bridging
would only reduce the preferred alternative’s wetland impact by 26 acres
(about 10%). The
benefits and effects of other methods of minimization should be quantified. Describing
minimization possibilities without evaluating them is misleading.
Prior
versions of the project were criticized for spawning development, sprawl, and
increasing the impervious surface area in the watersheds of the project area.
At the public information sessions in May 2004, I understand that these past
claims were dismissed by staff with the assertion that the development had
already taken place, without the project having been built and therefore does
not have to be considered as part of this new project proposal. While this may hold for direct impacts, indirect and cumulative impacts
MUST consider the development that has already taken place. Cumulative impacts
analysis involve past, present, and reasonably foreseeable actions.
The DEIS mentions
the Chesapeake and Virginia Beach agricultural lands and open space programs as
part of local mitigation efforts. These programs are subject to change
with political and development pressures.
The
Virginia
Beach
agricultural land program and the city’s open space program currently have
inadequate funding to be significant mitigation factors.
The fact is that
significant areas are developed, with wetlands and watersheds already adversely
impacted within the project area. This
only means that the remaining natural resources within this project area have a
HIGHER ecological value than similar project impacts in a pristine
environment. This is due to the assumed impairment of the health and
resiliency of the affected ecosystems by this past development, making
protection of any additional wetlands and watersheds critically more important.
Given available
information, Back Bay Restoration Foundation concludes that the need for this
roadway is not supported, that the analysis of environmental impacts is
incomplete, and that the environmental impacts outlined in the DEIS exceed the
benefits. We are therefore opposed to the SEP and believe the I-64
and Oak Grove Connector portion is all
that is necessary on this project.
Respectfully
submitted,
Susan M. Admire
Executive Director
Back Bay
Restoration Foundation
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