Michigan Land Use Institute

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United States Environmental Protection Agency Region 5

Damage warrants denial

February 4, 1999 |

Mr. James A. Kirschensteiner, PE
Federal Highway Administration
315 West Allegan
Room 207
Lansing, Michigan 48933

Dear Mr. Kirschensteiner:

In accordance with our responsibilities under the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act, the United States Environmental Protection Agency (U.S. EPA) Region 5 has reviewed the information submitted along with your January 5, 2000 cover letter. The Federal Highway Administration (FHWA) submitted the information to us to provide additional information to address issues that were discussed in the U.S. EPA's Draft Environmental Impact Statement (DEIS) comment letter issued on August 10, 1999 and subsequent letter on October 18, 1999. We are providing this letter as part of NEPA/Section 404 process under the concurrence point for "Alternative Carried Forward".

The U.S. EPA provided concurrence with the purpose and need for the project in a letter dated May 4, 1999. As stated in that letter, we recognized that a replacement for the existing Cass Road Bridge must be provided for in the near future. We also recognized the importance of the replacement bridge in the safe and efficient flow of east-west travel in the Traverse City area.

The DEIS evaluated two build alternative, the South Airport Road Widening and the Hartman-Hammond Connector alternatives. Both of these alternatives included the widening of Three Mile Road. U.S. EPA did not provide concurrence with the Alternatives Brought Forward because of the No Action alternative and Alternatives Evaluation issues that we expressed.

Since the U.S. EPA issued the August 10, 1999 letter, our original questions and concerns have been resolved by information that you sent to our Agency. The additional information that we received on the TDM alternative, Transit investigation, Section 4(f) Impacts to the Nature Preserve, TC-TALUS 2115 Socio-Economic Forecasts, excerpts from the Regional Corridor Study for US-31 and the Origin and Destination Survey for the Traverse City area satisfy our early questions and concerns with those areas. This information and analysis should be included in the Final Environmental Impact Statement (FEIS).

Based on the information provided since the August 10, 1999 letter, our Agency believes that the DEIS includes all feasible alternatives meeting the purpose and need of the project that merit detailed analysis. Therefore, we are providing our concurrence with the Alternatives Brought Forward.

We recommend that additional information be included in the FEIS to clarify how roadway improvements will actually function and operate once a build alternative is constructed. We suggest including more details in the FEIS to describe the operation of the roadway such as speed limit on the roads, number and type of access points, signage and other descriptive features. Existing land use information for the entire study area should also be included in the analysis. This map should be compared to maps depicting land use with a build alternative implemented. This information and analysis needs to be included in the FEIS.

We note that Michigan Department of Transportation (MDOT) has stated that it will determine whether there is a need to further analyze the recommendations from the Traverse City regional corridor study (the bypass study) after the Grand Traverse County Road Commission's project (this project) has been analyzed. Therefore, we are formally requesting a copy of any future NEPA documents from your Agency that may be issued that evaluate bypass corridors for this area.

If you have any questions about our NEPA/404 concurrence or if you would like to discuss our comments, please contact Sherry Kamke of my staff at (312) 353-5794.



      Cc: Mr. Michael K. Dillenbeck, Grand Traverse County Road Commission
      Ms. Lori Noblet, Michigan Department of Transportation
      Gerald W. Fulcher Jr., P.E., Michigan Department of Environmental Quality
      Gary R. Mannesto, U.S. Army Corp of Engineers
      Craig A. Czarnecki, U.S. Fish and Wildlife Service

    Michigan Land Use Institute

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