January 9, 2014

Joy Oakes, National Parks Conservation Association

Morgan Butler, Southern Environmental Law Center
Elizabeth Merritt, National Trust for Historic Preservation
Christopher G. Miller, Piedmont Environmental Council
Stewart Schwartz, Coalition for Smarter Growth

Transmitted via email

Dear Consulting parties:

On January 6, 2014, we received your letter, signed by the members of the coalition of consulting parties
participating in consultation on the Bi-County Parkway Project (BCP) conveying changes that you would
like to see in the Programmatic Agreement (PA) being revised by the Federal Highway Administration
(FHWA) and Virginia Department of Transportation (VDOT). Thank you for sharing your concerns with
us and for recommending improvements to the proposed PA. We take very seriously your concerns about
the BCP and the adequacy of the PA to avoid and minimize adverse effects to historic properties. We are
sharing with the coalition the current version of the PA which incorporates changes to the 4
th
draft
circulated in December. We believe that VDOT has made a concerted effort to allow flexibility in the
design to develop a highway that minimizes harm to the historic landscape, including a process that
ensures collaboration among the consulting parties and signatories.

We appreciate that the coalition and other consulting parties were frustrated with the tight time frame
provided for the review of the 4
th
revised draft PA circulated by VDOT on December 13, 2013. Although
the consulting parties were provided only a short time to review the 4th draft, during the past year the
Section 106 consultation for the BCP has afforded consulting parties numerous opportunities to share
their concerns with VDOT and make recommendations to improve the draft PA`s. Since November 2012,
VDOT has hosted four face-to-face meetings and held a conference call for which all consulting parties
were invited to participate. In addition, the ACHP invited preservation organizations, including your
organizations, to participate in a conference call with the ACHP and the State Historic Preservation
Officer (SHPO) prior to the November 7, 2013 meeting with the PA signatories. That meeting was critical
to informing our understanding of the issues and concerns your organizations held regarding the adequacy
of the PA.

It is important to note that FHWA held only two signatory parties meetings, on November 7, 2013 and
December 30, 2013, to discuss the comments received from the consulting parties and next steps. We,
thereIore, take exception to your characterization oI a consultation that 'relied predominantly on
communications with signatories only and excluding the vast majority of consulting parties. This
statement is not supported by the record.




2

In response to your more specific comments and recommendations, we have worked to incorporate
language in the final PA that addresses issues discussed during the meetings. The current PA does not
extend the design parameters in Stipulation I to areas north of the MBHD. We agree that a less context-
sensitive design immediately north of the MBHD could exacerbate adverse effects on the setting of the
district. However, VDOT has not indicated that the design of the BCP will incorporate a sudden transition
in the design at the edge of the MBHD. Provisions are included in the PA to address indirect and
cumulative effects that may result from the BCP. This provision should be invoked and brought to the
attention of the affected county(ies), if appropriate.

Changes have been made to the current PA to address some of your other comments regarding Stipulation
I. The PA now makes a clear commitment to achieving a design that best fits its physical and historic
setting and minimizes adverse effects on historic properties within the Manassas Battlefield Historic
District (MBHD). VDOT has agreed to implement a reduced design speed as low as 55 mph for the BCP
within the District, reduce the width of the right of way and roadway section to the maximum extent
possible, and engage consulting parties in a series of meetings to assist in the design of the BCP. These
meetings with the project design team will ensure consulting party input into key aspects of the design,
including highway width and cross-section, the possibility of depressing the roadway below the present
grade, measures to reduce noise and visual impacts, and construction of the Pageland Lane interchange on
the MBHD and Manassas National Battlefield Park.

While the majority of the current PA focuses on mitigating the effects of the BCP to historic properties
within the area of direct impact, it also addresses indirect and secondary effects. The PA commits the
VDOT Chief Engineer to not propose to the Commonwealth Transportation Board the approval of any
future additional connections south of Route 234. Your suggestion to extend this commitment to the
entire length of the BCP would seem to preempt the local zoning process, which is perhaps a more
appropriate and logical forum in which to address the issue of additional access points.

With regard to Groverton Road and Featherbed Lane, the current draft clarifies that these corridors are to
be considered when evaluating secondary effects of the proposed BCP. During the consideration of traffic
calming measures, it is likely that issues such as safety and increased volume will be discussed. If the
coalition wishes to advance the notion of limiting access to these roads when the BCP is completed, we
would encourage it to raise this issue with the County. Finally, we recognize and appreciate that in part
due to the coalition`s lobbying eIIorts, more money will be made available to purchase property interests,
and thus, help address secondary impacts.

In closing, we appreciate the substantial effort made by the coalition to ensure that the Bi-County
Parkway was responsive to historic preservation issues. Because of your diligence, this proposed
transportation improvement will be more appropriate to the historic setting in which it is being
constructed.

Sincerely,



Reid Nelson, Director
Office of Federal Agency Programs

Enclosure