Mr. Marvin Williams
District Transportation Engineers
Federal Highway Administration
227 N Bronough St., Suite 2015
Tallahassee, FL 32301-2015

Re: Suncoast Parkway 2 - PD&E Study
Financial Project No: 405270-1

Dear Mr. Williams:

I have reviewed the minutes of the February 25-26, 2004, ERRAG work session especially as it relates to alternative alignments and I have some serious concerns about the information given to the agencies and its presentation.

My concerns were amplified when I read the report to the Federal Highway Administration requesting that, among others, alignment A be removed from additional study.

The data clearly portrayed an environmentally feasible route that is unpopular locally, being removed from consideration because of residential relocations and the potential for litigation.

At the same time, the more environmentally detrimental alternative D is lauded as worthy of detailed study because it follows an existing disturbed edge "along the power lines." Yet, A also follows power lines with an existing "disturbed edge." Better yet, A follows power lines that are not embedded in public land.

A's route is also the most westerly which lessens the problems with controlled burns due to the prevailing westerly winds. It fragments habitat to the least degree of all the routes. It puts the road closer to the community that it is intended to serve and closer to the road it is intended to relieve. That is supposed to matter.

Alignment A moves the interchange at route 98 to the west of public land and that would facilitate the creation of wildlife crossings between Chassahowitzka WMA and the abutting WSF-Citrus Tract (Annutteliga Hammock).

While ROW acquisition of residential lots may be greater than the dollar value placed on public land for the same distance, the cost would be made up easily by the simpler and safer exchange at SR 44. Route D requires exit and egress to the parkway at the crotch of an existing "Y" intersection. Not good and expensive to fix. Route A's interchange with SR 44 is clean and uncomplicated.

The minutes list the fact that route D is the shortest route. It is shorter by 528 feet, not quite the length of my lot. Another of A's listed disadvantages is major infrastructure impacts. I don't see it being any different from Cheval Subdivision in Hernando. FTE didn't mind putting a road through the middle of their subdivision. Institutional relocations are zero along route A, but route D has two. Institutions are infrastructure as much as paved roads.

The minutes stated they were listing the major advantages and disadvantages of the various routes. Then they proceed to list only negatives for route A, four positives for route D with the negative being some possibility of conflict with a turpentine camp. Did they even realize that D's listed advantage of being west is out done by route A's location which is even further west?

Gary Maidhof, the ERRAG representative for Citrus County also stated in his memo, dated March 9, 2004, that, "A number of ERRAG members noted that the matrix while useful was not statistically supported, and they disagreed with the equal status, provided each category, believing some categories deserved greater weight." To therefore eliminate alignments based on the matrix is contrary and antithetical to the agencies' critique of it.

As I understand it, the reason we have 4(f) laws is because it is always easier to build through parkland than through subdivisions politically and economically, as the land is undeveloped and therefore much less expensive than land with homes on it. Therefore, to prevent road planners from taking advantage of land inhabited by animals that cannot complain or sue, the will of the people was specific. The law states that the Secretary "shall not approve any program or project" that requires the use of any public parkland "unless (1) there is no feasible and prudent alternative to the use of such land, and (2) such program includes all possible planning to minimize harm to such park…" 23 USC S138 (1964 ed., Supp V); 49 USC S1653 (f)(1964 ed., Supp V). And now they want to dismiss from further study a very feasible alignment because it is unpopular locally. The apparent bias is blinding. Is it any wonder ERRAG does not want any public scrutiny at their meetings?

I am very concerned about the bias of information and how it is presented. Every alignment presented has different reasons for being selected in the first place. If the state didn't mean to consider seven of the ten, why were they selected in the first place?

How was the information presented? Somehow the ERRAG went from listing route A as their preferred alignment at their last meeting to shelving it from further study. What is the real reason? Certainly not the data.

Mr. Williams, please do not allow FTE to remove the most environmentally friendly route from further study.

Sincerely,

Kathy Chetoka Homosassa Springs, FL

Cc: Carl Gibilardo, Suncoast Parkway 2 Project Manager
Gary Maidhof, ERRAG Representative for Citrus County