1. What is the nature of the Greene County non-attainment? 
2. We are a relatively undeveloped County, how is this possible?
3. Would the building of the Corridor 18 NAFTA international-free-trade interstate be compatible with the EPA goals of cleaner air here?  Under what conditions would it not be compatible?
4. The project claims 12,305 trucks would use this route per day. Currently Greene County has no four lane highways.  Could it be that this project is not compatible with our needs? 
5. Does the issuance of a Tier 1 ROD preclude any further consideration of this matter?
6. As a cyclists could you direct me to documents that I might study and present to the study that might show health effects possible or likely as a result of this project for those of us using Bicycles for exercise and transportation?
7. So to I have noticed that all of the counties around Indianapolis and Evansville are also in non attainment.  What comment will you make to this issue?  I am in touch with the state level Indiana Bicycle Commission (IBC) who has been asked to participate also.

• Also, during the DEIS stage of the Evansville to Indianapolis study of I-69, the EPA expressed great concern that the Karst of Monroe and Greene County had not been given significant enough study or consideration for the costs of mitigating this area.  This was an area that I tried to explain to the study as well.  What was it that INDOT did to satisfy this EPA concern between the DEIS and the FEIS that allowed the Tier 1 ROD?
• In my opinion, your DEIS comments were absolutely correct and were not addressed.  Please see these documents:

1. Your comments to the DEIS:  http://www.commonsensei69.org/documents/EPALtr11-07-02.pdf
2. My press release telling INDOT that their source data is inadequate: http://www.i69tour.org/fax-kruzan-karst01.html
3. These claims were documented after the closing of the public comment period for the Tier 1 FEIS by a study completed by Munson, Frushour, Peterson and Munson: http://www.i69tour.org/feis/karst94.pdf
4. (Munson's provided several documents: http://www.i69tour.org/feis.html)

• I asked US Dept. of Transportation Field Operations Engineer if this oversight could cause the reversal of the 3C routing of I-69, and he said no, the ROD had concluded this was the route.  He seemed to tell me that there was no going back on the decision of the ROD, until I asked if a law suit might be the only option for citizens.  At first he agreed and then after a several minute absence from the CAC meeting, he returned, broke into the meeting with a correction.  He corrected his earlier statement, saying that a revised ROD was possible.  I want to know, how do we proceed to have this Karst problem given proper consideration?
• Regarding the actions of the Evansville consultants, Bernardin, Lochmueller and Associates,  who had better Karst data and who chose to use documents that were clearly labeled not sufficient for this level of study, does the EPA find any reason for concern with the handling of this issue?  Our INDOT commissioner first denied lack of knowledge of this data and then defended this lack of consideration as appropriated for Tier 1.  One should question better information was available in house, "Why did the consultants contract for a less accurate assessment of Karst in this region?"
• Could you provide any documentation regarding the potential or likely health effects on our lives from Karst runoff issues for this infrastructure and please provide these references?
• Are there cost analysis tools and/or researched articles regarding methods of mitigation for such dense Karst?  If so, please provide those references too.

Dear Mr. Smith,

I am responding to your questions regarding karst concerns for the I-69
Tiered EIS.   Please see responses in bold at each question in your
below email.   In addition, attached are electronic versions of EPA's
February 11, 2004, FEIS comment letter and EPA's March 23, 2004, letter
to FHWA concerning a citizen groups' letter regarding karst information
and the Tier 1 EIS.

(See attached file: I-69 Tier 1 FEIS FINAL Comment Letter (dated and
signed by Bharat Mathur ) 02 11 04.wpd)

(See attached file: I-69 Tier 1 FEIS KARST letter FHWA 03 23 04
electronic signature.wpd)



Virginia Laszewski
Environmental Scientist

US EPA, Region 5
OSEC, NIS
77 W. Jackson Blvd. (mail code: B-19J)
Chicago, IL  60604-3590
Phone:  (312) 886-7501
Fax:  (312) 353-5374
email:  laszewski.virginia@epa.gov
_____________________________________________________________________________


Dear Mr. Smith,
      I am responding to your questions about air quality concerns in
Greene County, Indiana.
Please see responses in bold below each question.  I have referred your
questions about karst areas to another  specialist at USEPA.

Patricia Morris
Environmental Scientist (Highlighted here in Green)



----- Forwarded by Sharon Reinders/RTP/USEPA/US on 12/14/2004 10:46 AM
-----
                                                                        
             Bikesmiths                                                 
             <info@bikesmith                                            
             s.net>                                                  To 
                                     Sharon Reinders/RTP/USEPA/US@EPA,  
             12/14/2004              Barry Gilbert/RTP/USEPA/US@EPA     
             10:15 AM                                                cc 
                                     Timothy Richard Sahr               
                                     <sahr.6@osu.edu>, Kevin Enright    
                                     <keenrigh@indiana.edu>             
                                                                Subject 
                                     Regarding air and water Corridor   
                                     18, SIU 3, 3C, section 4 +.        
                                                                        
                                                                        
                                                                        
                                                                        
                                                                        
                                                                        




Dear EPA officials,

    I am a member of a Citizens Advisory Council for the study of the
Corridor 18, SIU 3, route 3C section 4, as part of the Evansville,
Indiana to Indianapolis study of I-69.

    Today I have visited your web pages regarding non attainment of the
8-Hour Ground-level Ozone Designation.  My county of residence is Greene
County, Indiana and it is among those in non attainment/ "Basic".   The
organization that I am officially representing in the CAC is the
Bloomington Bicycle Club, though my personal interest in this project
goes far beyond my professional and social bicycling.  I have yet to see
any advantage other than a few minutes travel savings to Evansville
where the EIS shows few care to travel currently.  On the other hand, I
see many disadvantages.

My questions:

Regarding Air

   1. What is the nature of the Greene County non-attainment?  Greene
      County is nonattainment for the 8-hour ozone standard and is
      classified as basic.
   2. We are a relatively undeveloped County, how is this possible?
      Ozone is a secondary pollutant.  It is formed by a reaction of
      volatile organic compounds and oxides of nitrogen in the
      atmosphere in the presence of sunlight.  Ozone is often found
      several hours downwind of major sources of pollution.
   3. Would the building of the Corridor 18 NAFTA
      international-free-trade interstate be compatible with the EPA
      goals of cleaner air here?  Under what conditions would it not be
      compatible?  Section 176(c) of the Clean Air Act requires
      transportation projects to "conform" to the purpose of the State
      Implementation Plan for air quality.  This project must meet the
      requirements for "conformity".  The transportation conformity
      regulations are found in 40 CFR Part 93.
   4. The project claims 12,305 trucks would use this route per day.
      Currently Greene County has no four lane highways.  Could it be
      that this project is not compatible with our needs?  The
      Envinronmental Impact Statement provides a purpose and need
      section.
   5. Does the issuance of a Tier 1 ROD preclude any further
      consideration of this matter?  Further analysis of environmental
      effects will be required for the Tier 2 analyses.
   6. As a cyclists could you direct me to documents that I might study
      and present to the study that might show health effects possible
      or likely as a result of this project for those of us using
      Bicycles for exercise and transportation?  Our website at
      http://www.epa.gov/epahome/ozone.htm  gives information on the
      health effects of ozone.
   7. So to I have noticed that all of the counties around Indianapolis
      and Evansville are also in non attainment.  What comment will you
      make to this issue?  I am in touch with the state level Indiana
      Bicycle Commission (IBC) who has been asked to participate also.
      Any portions of the project which are planned to be built in
      nonattainment or maintenance areas will need to address air
      quality conformity issues.  For more information on air quality
      conformity please see our web site at
      http://www.epa.gov/otaq/transp/traqconf.htm.


Regarding Karst

      Also, during the DEIS stage of the Evansville to Indianapolis
      study of I-69, the EPA expressed great concern that the Karst of
      Monroe and Greene County had not been given significant enough
      study or consideration for the costs of mitigating this area.
      This was an area that I tried to explain to the study as well.
      What was it that INDOT did to satisfy this EPA concern between the
      DEIS and the FEIS that allowed the Tier 1 ROD? [FHWA/INDOT
      provided responses to EPA's Tier 1 FEIS comments regarding karst
      in FHWA's Tier 1 Record of Decision (ROD), dated March 24, 2004).
      See ROD Appendix B, pages 8, 9, 18, 19, 20, 21, and 22].
      In my opinion, your DEIS comments were absolutely correct and were
      not addressed.  Please see these documents:
   1. Your comments to the DEIS:
      http://www.commonsensei69.org/documents/EPALtr11-07-02.pdf
   2. My press release telling INDOT that their source data is
      inadequate: http://www.i69tour.org/fax-kruzan-karst01.html
   3. These claims were documented after the closing of the public
      comment period for the Tier 1 FEIS by a study completed by Munson,
      Frushour, Peterson and Munson:
      http://www.i69tour.org/feis/karst94.pdf
   4. (Munson's provided several documents:
      http://www.i69tour.org/feis.html)
   [Documents noted, thank you.]
      I asked US Dept. of Transportation Field Operations Engineer if
      this oversight could cause the reversal of the 3C routing of I-69,
      and he said no, the ROD had concluded this was the route.  He
      seemed to tell me that there was no going back on the decision of
      the ROD, until I asked if a law suit might be the only option for
      citizens.  At first he agreed and then after a several minute
      absence from the CAC meeting, he returned, broke into the meeting
      with a correction.  He corrected his earlier statement, saying
      that a revised ROD was possible.  I want to know, how do we
      proceed to have this Karst problem given proper consideration?
      [FHWA is the responsible federal agency for the Tiered NEPA
      documentation for this project.  I recommend you and other members
      continue to actively participate on the TIER 2 Citizens Advisory
      Committee (CAC), attend the public information meetings, ask for
      periodic updates from FHWA/INDOT on the karst information that is
      being developed for the Tier 2 EISs, meet with your CAC
      counterparts for other I-69 segments to exchange ideas and
      information, and contact FHWA if your concerns/issues are not
      being adequately addressed or you are not receiving the
      information you feel you need to understand the implications of
      the proposal on karst resources.  I also suggest the CAC consider
      reviewing and commenting on the Tier 2 DEIS/s during the formal
      comment period/s.]
      Regarding the actions of the Evansville consultants, Bernardin,
      Lochmueller and Associates,  who had better Karst data and who
      chose to use documents that were clearly labeled not sufficient
      for this level of study, does the EPA find any reason for concern
      with the handling of this issue? [See our  attached March 23,
      2004, letter to FHWA] Our INDOT commissioner first denied lack of
      knowledge of this data and then defended this lack of
      consideration as appropriated for Tier 1.  One should question
      better information was available in house, "Why did the
      consultants contract for a less accurate assessment of Karst in
      this region?"  [See FHWA's Tier 1 ROD Appendix B, pages 8, 9, 18,
      19, 20, 21, and 22.]
      Could you provide any documentation regarding the potential or
      likely health effects on our lives from Karst runoff issues for
      this infrastructure and please provide these references? [Please
      see the below listings:
                                                                        
     Karst Ground - Water Tracing Using Fluorescent Microspheres        
     as Surrogates for Microbial Pathogens Using a Micro 
     Integrated Flow Cytometer
     Karstic aquifers are widely recognized as being more
     vulnerable to contamination than other types of aquifers.
     URL:
     http://cfpub1.epa.gov/ncea/cfm/recordisplay.cfm?deid=56440
                                                                        

                                                                       
     Ground - Water Monitoring in Karst Terranes: Recommended
     Protocols and Implicit Assumptions
     Approximately 20 percent of the United States is underlain
     by various types of karst aquifers.
     URL: http://www.epa.gov/swerust1/cat/gwkarst.pdf
     http://water.usgs.gov/ogw/karst/ 
     Home Page, lots of information
                                                                   
     Citizen's Guide to Ground - Water Protection
     This guide is intended to help citizens take an active and
     positive role in protecting their community's
     ground-watersupplies.
     URL: http://www.epa.gov/safewater/protect/citguide.html   ]  

        Are there cost analysis tools and/or researched articles       
        regarding methods of mitigation for such dense Karst? [At      
        this time, I am not aware of any.  However, this doesn't       
        mean there aren't any.  The CAC might want to consider         
        asking FHWA/INDOT/Consultants to research and provide          
        this type of information to the CAC.] If so, please            
        provide those references too.                                  
     Thank you,                                                        
                                                                       
     John Smith                                                        
     BBC Rep, Corridor 18, Section 3,                                  
     3C,  SIU Section 4,                                               
     Tier 2 EIS, CAC