C100 Comments on Draft 106 Va Ave Tunnel

Monte Edwards

The purpose of the Section 106 process is to assess adverse impacts on historic properties and if those adverse effects cannot be avoided, to agree on how to mitigate the adverse effects. The MOA is supposed to be the agreement of the parties about how to accomplish that mitigation. But, as demonstrated in these comments, the adverse effects can be identified, but studies are required to quantify the adverse effects so that they can be avoided or appropriate mitigation can be designed. Until the studies requested above have been accomplished, mitigation cannot be addressed in a MOA.