Transportation and Land Use  

I-73 DEIS fails to address Roanoke's Air Quality

Report compiled for Virginians for Appropriate Roads, a chapter of the Blue Ridge Environmental Defense League

This report is comprised of BREDL and VAR's comments on the Air Quality issue for the I-73 DEIS

submitted by:
Mark E. Barker
BREDL Virginia Vice-President
January 11, 2001



Smog/Ground-Level Ozone

Conformity Requirements

CO, NOx and Particulate Matter




Health Impacts


Class 1 Federal Areas

Acid Deposition

Tourism/Economic Impacts

TSM/No-Build Alternatives



Despite overwhelming evidence, VDOT fails to acknowledge in the Draft Environmental Impact Statement for I-73 that the Roanoke area (I-73 Study Area) has an air quality problem, especially ground-level ozone. Instead, VDOT chooses to hide behind a “timing” issue.

As VDOT hurriedly pushes through the NEPA process, the department’s I-73 timeline has the Commonwealth Transportation Board selecting an alternative either prior or close to the time when EPA will be allowed to finalize the 8-hour ozone nonattainment designations. In the DEIS (page 3.3-3), VDOT says, “If the Roanoke area is designated (ozone) nonattainment prior to the completion of the I-73 Location Study, then the issue will be addressed in the final EIS.” That is an issue that should have been addressed in the DEIS.

An alternative for I-73 should not be selected until EPA finalizes the designations for ozone nonattainment areas and conformity requirements are outlined. This issue is so important and the DEIS is so inadequate that either a new DEIS or a Supplemental DEIS is requested for Air Quality. A Supplemental DEIS should include the NOx, VOC, ozone, and particulate matter emissions for each alternative and potential primary, secondary, and cumulative environmental, health and economic impacts to the Roanoke region.

The DEIS is both inadequate and misleading on mesoscale and microscale air quality issues. National Ambient Air Quality Standards criteria pollutants such as NOx , CO, Ozone and particulate matter will increase with the construction of a new interstate in the Roanoke Valley. The health impacts from Hazardous Air Pollutants/Mobile Source Air Toxics such as benzene, formaldehyde, and 1,3-butadiene and other pollutants need to be fully addressed.

VDOT needs to address these issues to reflect the “new emphasis” of the Federal Highway Administration and to meet NEPA requirements. In an April 1992 FHWA Position Paper titled "Secondary andCumulative Impact Assessment in the Highway Project Development Process", the leadhighway agency acknowledges that past actions “have not addressed secondary and cumulative impacts.” In the paper the FHWA goes on to say,

“Regardless of this history, secondary and cumulative impacts will become important issues which will temper decisions made by FHWA and the State Highway Agencies (SHAS) on project scope, location, and mitigation. To fulfill the general NEPA mandate of environmentally sensitive decisionmaking the FHWA and the States must develop and use techniques to incorporate secondary and cumulative impact issues in the highway project development process. The techniques must ensure that social, economic and environmental impacts are analyzed in both the present and future context. The SHAs and FHWA must establish a way to make one public interest decision with the assurance that all relevant impact issues were studied. We cannot assume necessarily that impacts which are difficult to recognize and evaluate have no bearing on our decisions. Since we are making decisions that shape the future, we must consider the ramifications of those determinations beyond their immediate effects on the existing environment.”

Smog/Ground-Level Ozone

According to the Environmental Protection Agency, highway vehicles contribute approximately one third of the oxides of nitrogen (NOx) emissions released to the atmosphere in the United States annually. Nitrogen oxides and volatile organic compounds - hydrocarbons - combine in the presence of sunlight to form ground-level ozone, or smog, which irritates the eyes, damages the lungs, and aggravates respiratory problems.

Virginia 1996 emissions (tons)

Source CO NOx VOC
















- sources: Environmental Defense/EPA

On the I-73 project, VDOT and the Commonwealth of Virginia are trying to skirt around the requirements of the Clean Air Act and TEA 21. The DEIS has not properly studied the bad air quality of the Roanoke area, especially in relation to meeting the attainment requirements for ozone under the Clean Air Act. The DEIS (p. S-10) states, “The study is located in an area designated as attainment for carbon monoxide and ozone; therefore it is not subject to the conformity requirements of the Clean Air Act.”

VDOT then acknowledges (DEIS p. 3.3-3) that “Based on existing monitoring data, it appears that the City of Roanoke and a portion of the surrounding area exceed the new standard and will be designated nonattainment.”

VDOT also mentions (DEIS p. 3.3-3) , in reference to the EPA new 8-hour standard for ozone, “...the timely implementation of the new standard has been tied up by legal challenge.” VDOT further explains that “if the Roanoke area is designated nonattainment prior to the completion of the I-73 Location Study, then the issue will be addressed in the final EIS.” VDOT also says this designation may not happen until mid-2001. Although the courts had allowed EPA to continue with their designations, Congress attached a rider to the FY 2001 Appropriations Bill which directed EPA to hold off finalizing nonattainment areas until either the U.S. Supreme Court issues a decision or June 15, 2001 first. As VDOT rushes to have the Commonwealth Transportation Board issue an alternative decision by the Summer of 2001, one has to wonder if the “timely” tie-up on the 8-hour standard has been calculated into VDOT’s study process.

In a June 29, 2000 letter (Appendix 1) to EPA Region III Administrator Bradley M. Campbell, Virginia Secretary of Natural Resources John Paul Woodley, Jr. reluctantly submitted Virginia’s recommendations for designations of nonattainment ozone areas under the current EPA 8-hour standard. This standard is currently being challenged in the U.S. Supreme Court. The Roanoke area is included, under the current 8-hour standard, as a nonattainment area. The Roanoke nonattainment area consists of Botetourt County, Roanoke County, City of Roanoke, City of Salem, and Town of Vinton. All areas will be affected by a new terrain interstate, I-73 build options.

Secretary Woodley wrote, “When the TEA 21 bill was passed requiring EPA to make designations by July of 2000, no one anticipated the lengthy litigation over the new 8-hour standard.” “Making such designations now ... just adds to the confusion,” he commented. The EPA was encouraged to hold any action on the nonattainment areas by Secretary Woodley who said “holding all actions involving the 8-hour standard in abeyance until that ruling is made is the prudent thing to do.”

The lawsuit now before the U.S. Supreme Court is challenging procedural matters and is not challenging technical merits. The technical information is sound. In fact, the state of North Carolina has adopted identical 8 hour standards into their state plan. Pending the Court’s decision, EPA may not be able to finalize the Roanoke ozone nonattainment designation until the Spring or Summer of 2001. Once this EPA designation has been made, Virginia will have to address the Roanoke ozone nonattainment issue.

We respectfully request VDOT to postpone choosing an alternative for I-73 until EPA makes its final designations for ozone nonattainment areas. It’s the prudent thing to do. VDOT should not circumvent their legal requirements by rushing to make a decision. The Virginia Secretary of Natural Resources in his June 29, 2000 letter to EPA asked EPA to postpone its final designations for ozone nonattainment areas until after the Supreme Court ruling on the 8-hour standard. The Secretary didn't want to add "confusion" to the process. Adding "confusion" to the process is exactly what VDOT is doing by not waiting for the Supreme Court ruling and EPA final designations.

In the DEIS, there are only five sites listed for DEQ monitoring in the Roanoke Valley. Of these five sites, data is only listed for one or two sites for each Criteria Pollutant. The data that is presented represents the current levels. Except for the CO estimates (DEIS 4.3-1), there is no estimate of anticipated levels of air pollutants from the various I-73 alternatives. It is also noteworthy that the 8-hour ozone standard was left out of the air quality grid and out of the DEIS Air Quality sections (DEIS 3.3 and 4.3).

The current EPA 8-hour standard is 85 parts per billion (ppb). Pending final designation from the EPA, Roanoke has been recommended as an ozone nonattainment area based on this official data. During the Summer of 2000, despite a wetter, cooler summer, Roanoke still experienced two days when the 8 Hour peak exceeded the 85 ppb standard. (Appendices 2A & 2B).

Roanoke highest 8-hour ozone average (1997 - Oct. 31, 1999)

Year 8-Hr.Ozone
1997 84 ppb
1998 99 ppb
1999 89 ppb
3 year ave. 90 ppb

- source Virginia DEQ

In the DEIS VDOT states (DEIS 2.1, p. 56), "The new interstate in the study area would ultimately connect with other segments of I-73 alignments in West Virginia and North Carolina." Also in the DEIS (DEIS 1.1, p.40) VDOT says, "West Virginia has completed a Final Environmental Impact Statement (FEIS) to upgrade existing U.S. Route 52 as their I-73 project. Due to the extreme terrain and capital costs, West Virginia has elected not to build to Interstate standards. This condition is true for much of the interstate system in West Virginia where design exceptions occur to accommodate mountainous conditions."

VDOT needs to examine the cumulative impacts from the congestion that will happen at the Virginia-West Virginia border and points west. If huge volumes of traffic are funneled onto the two-lane system thorough West Virginia, this could actually compound the air pollution which will descend on the Roanoke Valley.

Encouraging more traffic into Roanoke is not the sensible thing to do. VDOT has discussed this issue with the Roanoke Valley-Alleghany Regional Commission (RVARC) (DEIS 3.3-3), but no additional information was provided in the DEIS. A RVARC Roanoke report on air quality states, “Another primary factor is the actual level of ozone in the Roanoke Valley region. The monitor that records ozone levels for this region has shown readings in excess of the new eight-hour standard for the past three years. According to the Department of Environmental Quality, much of this ozone can be attributed to local sources such as vehicle travel and industry.”

The report mentions that “when the EPA designations are final, . . localities in the designated regions will be required to analyze road-building projects to ensure that they conform with ozone reduction requirements, and facilities that are new sources of air emissions will have to obtain emission "offsets" so that overall emissions in the area do not increase.”

Conformity Requirements

The conformity requirements should have been openly presented and discussed in the DEIS.

We argue that the Roanoke area is, in essence, a de facto ozone nonattainment area. As we await the Supreme Court ruling or the June 15, 2001 EPA deadline established by Congress, the Roanoke area is in a virtual conformity lapse without a proper local Transportation Improvement Program or State Implementation Plan. Both the Roanoke Valley Area TIP and the SIP will need to be updated to reflect the newly designated Roanoke MSA ozone nonattainment area.

The I-73 project will either contribute to a new violation, if the current 8-hour ozone designations become finalized, or will likely cause a new violation of the current 1-hour ozone standard or new 8-hour ozone standard that is reached. The definition of “Cause or contribute to a new violation” from 40CFRPart93 - 93.101 states: “Cause or contribute to a new violation for a project means: (1) To cause or contribute to a new violation of a standard in the area substantially affected by the project or over a region which would otherwise not be in violation of the standard during the future period in question, if the project were not implemented; or (2) To contribute to a new violation in a manner that would increase the frequency or severity of a new violation of a standard in such area.”

An excerpt from “Linking Transportation and Air Quality Planning”, a Harvard University March 1999 report to EPA and FHWA. (Chapter 2, p. 14 & 17)(Publication Number: EPA420-R-99-011) says:

First and foremost, the conformity process is intended to ensure that a nonattainment (or maintenance) area will keep transportation-related emissions within the bounds needed to bring the state into compliance with (or maintain) the national ambient air quality standards – and thus to advance the public health goals of the Clean Air Act. Conformity requires forecasting regional and (for certain pollutants) localized emissions from transportation. These projections, in turn, are used to determine whether expected future pollution levels jeopardize the timely achievement of the federal standards.

Thus, (according to the Clean Air Act, as amended) a conforming transportation project, program, or plan is one that:
- does not cause or contribute to any new air quality violation,
- does not increase the frequency or severity of any existing air quality violation, and
- does not delay timely attainment of air quality standards or interim emission reduction milestones.

We applaud VDOT for initiating discussion with the Roanoke Valley-Alleghany Regional Commission on the conformity requirements. However, we are disappointed that VDOT failed to openly discuss these requirements in the I-73 DEIS.

Eventually, VDOT will be forced to address the conformity issue. According to a June 18, 1999 FHWA memorandum “Additional Supplemental Guidance for the Implementation of the Circuit Court Decision Affecting Transportation Conformity”, “...projects that had previously been found to conform and had completed the . . . (NEPA) process (grandfathered projects) may not be advanced (that is, such projects should not be approved) in nonattainment and maintenance areas which do not have a currently conforming plan and transportation improvement program (TIP). Thus, in such areas, you should not make any approvals or grants for further development of projects (i.e., completion of NEPA process, final design, right-of-way acquisition, or construction).”

Therefore, we believe that the FHWA should not complete the NEPA process until EPA is allowed to finalize its ozone nonattainment areas for the 8-hour standard, Virginia updates its SIP, and the Roanoke MPO updates its TIP to reflect conformity requirements for the I-73 project. We argue that conformity must be determined: 1) Prior to approval of new transportation plans/TIPs or plan/TIP amendments, and 2) Prior to Federal approval or funding of projects.

In a FHWA 1992 position paper the agency says, “Under the CEQ regulations, the FHWA must consider the possibility of secondary and cumulative impacts on all agency actions. . . Secondary and cumulative impact analyses should be based on the possibility of indirect effects combined with various site specific conditions which will shape the scope and intensity of the studies necessary to provide adequate information to the project decisionmakers.”

The FHWA adds by saying, “ situations where the potential for indirect impacts exists, the likely consequences beyond direct project impacts should be determined with the greatest amount of confidence possible. “

Therefore, under NEPA and the Clean Air Act as amended and the conformity rule VDOT needs to complete a regional emission analysis for ozone, NOx, VOC and particulate matter to assess the adverse environmental and public health impacts from all the proposed alternatives. This analysis and a mention of the possible conformity requirements should be made available to the public in a SDEIS. The decision-makers and the public should have this information available to make intelligent , informed decisions on the I-73 alternatives.

We further request that the EPA require the FHWA to submit a regional emission analysis for ozone, NOx, VOC and particulate matter to address conformity requirements for the entire FHWA I-73/74 project from Charleston, South Carolina to Sault Ste. Marie, Michigan. Special emphasis should be placed on nonattainment areas throughout this region of the United States. The cumulative impacts from the entire I-73/74 project needs to be addressed.

Vehicle emissions of CO, NOx, and Particulate Matter

VDOT also misleads the public in their claim that “The Build Alternative would generally enhance air quality by reducing contaminant levels in the region by diverting traffic from other study area roadways and by increasing the average travel speed” (DEIS page 4.3-3). In this assertion, VDOT appears to be addressing the Carbon Monoxide pollutant exclusively. VDOT’s claim that redirecting traffic from existing roads onto I-73 will enhance air quality is unsupported. Studies and air pollution mitigating plans show that increasing travel speeds above certain limits also increases certain contaminants.

Constructing a new terrain interstate highway will induce more traffic and additional congestion into the Roanoke area. It’s like flies, throw a dead carcass on the ground and eventually it will be covered with flies. Any of the proposed build options for I-73 in the vicinity of Roanoke will worsen Roanoke's air quality by funneling more vehicular emitted pollutants into the region. It is ridiculous to claim that building a new highway would generally improve air quality in the region.

On pages 51, 66, and 257 of the DEIS, VDOT lists the Daily Vehicle Miles Traveled (VMT) projections for 2020 for the I-73 study area. The build alternatives will increase the VMT by 28.51 percent - 57.92 percent, whereas under the no-build and TSM options the VMT will only increase by 15.16 percent. This tremendous increase in daily VMT for the build options will drastically increase toxic emissions for the I-73 Study area.


  Current No-Build/TSM Option 1 Option 2 Option 3 Option 4
VMT 4.42 5.09 6.56 5.68 5.84 6.98
Increase - 15.16 % 48.42 % 28.51 % 32.13 % 57.92 %

As for VDOT’s claims that air quality will improve because of the increased travel speed, a study titled “Analysis of the Effects of Eliminating the National Speed Limit on NOx Emissions” (E.H. Pechan and Associates) shows that increases in traffic speed above 48 mph are associated with increases in emissions of CO, NOx , and possibly particulate matter. This study uses the same model base that VDOT used for their CO emission calculations.

The EPA-commissioned study addresses the impacts of increased speeds on air pollution. (on the internet at: The analysis was performed using the MOBILE5a model source emission factor model. The Report said:

"Motor vehicle NOx emissions result from combustion processes and tend to increase with increasing speeds above 48 miles per hour (mph) (Pechan, 1992)."

"Both CO and NOx emissions result from combustion processes. At lower speeds, around 15 mph, motor vehicle emissions of CO and NOx decrease with increases in vehicle speed as a result of more efficient combustion. However, after 48 mph, increases in vehicular speeds are accompanied by increases in emissions of both CO and NOx (Pechan, 1992).” Using the same reasoning, particulate matter (PM) emissions may also increase, according to the report.

The above findings for CO emissions should have been utilized in the DEIS on page 4.3-3 in the third paragraph,which describes CO emissions.

More evidence that increased speeds decreases the air quality can be found in Texas. One of the steps that the Texas Natural Resource Conservation Commission (TNRCC) has approved to enhance air quality around Dallas/Fort Worth includes reducing the speed limit. On April 19, 2000, the TNRCC approved plans designed to bring the four-county Dallas/Fort Worth ozone nonattainment area into compliance with the federal ozone standard. Among several steps, the Commission approved the following measure: “Speed limit reductions in the nine counties, from 70 to 65 mph and 65 to 60 mph beginning in September 2001”.

According to a 1996 study by the Natural Resources Defense Council (NRDC), the Roanoke Valley ranks first in Virginia for the amount of annual PM10 (particulate airborne matter) concentrations, and ranked 25 out of 239 areas nationally for PM10. The NRDC study ranked Roanoke as 16th among the top 25 metropolitan statistical areas in the U.S. for deaths per 100,000 population attributable to poor air quality. Particulate matter analysis needs to be completed for all I-73 alternatives.

Incomplete data in the I-73 DEIS: There are inadequacies in the Criteria Pollutant analysis because of lack of data from the DEQ monitoring sites in the Roanoke area. Table 3.3-2 is full of “Not Monitored” as the recorded levels. The analysis site corridor chosen for the CO Microscale modeling appears to favor certain alternatives. The Western Build Corridor was lacking in test sites.


Motor vehicles emit several pollutants that are known or probable human carcinogens. Benzene is a known human carcinogen. According to the EPA, formaldehyde, acetaldehyde, 1,3-butadiene and diesel particulate matter are probable human carcinogens. Based on modeling, EPA estimates that mobile (car, truck, and bus) sources of air toxics account for as much as half of all cancers attributed to outdoor sources of air toxics. This modeling estimates the maximum number of cancers that could be expected from current levels of exposure to mobile source emissions.

The EPA says “Hazardous air pollutants can cause many ill health effects. Many of these substances are known or suspected to be human carcinogens. Some of these chemicals are known to have negative effects on people's respiratory, neurological, immune, or reproductive systems. Some chemicals pose particular hazards to people with preexisting illnesses, or those of a certain age or stage in life, such as children or the elderly.”

The EPA has compiled a list of Hazardous Air Pollutants which make up the Mobile Source Air Toxics. These toxics include Acetaldehyde, Diesel Exhaust, MTBE, Acrolein, Ethylbenzene, Naphthalene, Arsenic compounds, Formaldehyde, Nickel compounds, Benzene, n-Hexane, POM (Sum of 7 PAHs), 1,3-Butadiene, Lead compounds, Styrene, Chromium compounds, Manganese compounds Toluene, Dioxin/Furans, Mercury compounds, and Xylene.

The EPA is proposing fuel-based controls to reduce on-highway MSAT inventories. In proposed rule 40 CFR Parts 80 and 86 (August 4, 2000) the EPA states, “Between 1990 and 2020, these programs are expected to reduce on-highway emissions of benzene by 75 percent, formaldehyde by 87 percent, 1,3- butadiene by 75 percent, and acetaldehyde by 82 percent. In addition, we expect to see on-highway diesel PM emission reductions of 94 percent...Although we anticipate substantial reductions in emissions of key toxic pollutants by 2020, the serious health effects associated with many of these compounds lead us to evaluate whether additional controls are appropriate at this time.”

The DEIS does acknowledge that benzene, formaldehyde, and 1,3-butadiene exceed the EPA health benchmark in the project area according to the EPA Cumulative Exposure Project. Inducing more vehicle emissions into the Roanoke Valley by constructing a new interstate I-73 will not lessen the amounts of these toxins.

In 1999, the Roanoke Times did a computer analysis using federal data which showed that “ thousands of people in the Roanoke and New River valleys are at risk of getting cancer from breathing these chemicals.”

In an August 15, 1999 Roanoke Times article the paper said, “The analysis, based on the Environmental Protection Agency's computer modeling data of hazardous air pollutants, shows that 13 toxic chemicals in the air above Roanoke exceed the health benchmark for cancer.”

The report also said: The concentrations are highest in the northeast and southeast parts of Roanoke, Vinton and west Salem and west and southwest Roanoke County. These areas have heavy traffic, gas stations, body shops and other industries that contribute to air pollution. In the New River, concentrations were highest around Blacksburg.

Though these neighborhoods have the highest concentrations of the three toxins, every part of the Roanoke and the New River Valleys exceeded the cancer benchmark.

In some places, the concentration of chemicals was more than 10 times higher than the health benchmark.

In Roanoke, the air with the highest chemical concentrations was in the U.S. 460 eastern corridor, with three chemicals more than 10 times higher than the health benchmark. The leading chemical was 1,3-butadiene, which was more than 19 times higher than the health benchmark. In Roanoke County, nine areas had chemical concentrations that were more than 10 times higher than the health benchmark. The concentration for 1,3-butadiene was more than 60 times higher in one area.

Along U.S. 460 in the southern part of Blacksburg, concentrations of benzene were 31 times the health benchmark. 1,3- butadiene was more than 100 times higher. The risks are highest in urban areas and decline with distance from those areas.


The secondary impacts from ozone damage to crops, forests, and agricultural lands should be considered. As reported in the 1996 Southern Appalachian Assessment (online at:, “Ozone is potentially the most significant pollutant affecting forests in North America.” Key findings from the SAA indicate that 1)“current ozone exposures are causing visible symptoms on the foliage of sensitive species” in numerous locations throughout the Southern Appalachians and 2) “ozone exposures, when soil moisture is adequate, may be sufficient to cause growth losses to the most sensitive species in the Southern Appalachians.”...4) “between 1983 - 1990, conditions in the northern and southern portions of the Southern Appalachians were most conducive to growth reductions from ozone exposures.” The Virginia I-73 Study corridor falls within the northern portion of the SAA.

The SAA used the W126 statistic, a mathematical index, to calculate data from EPA’s Aerometric Information Retrieval System (AIRS) database and from the National Dry Deposition Network programs. Each hourly average ozone concentration is recorded, then all of the W126 values are added together during the growing season.

The I-73 Study corridor through Virginia falls within the highest estimated W126 index areas. In the SAA results using 1988 data, the W126 index for the I-73 study area estimates ozone levels to be greater than 66.5 parts per million hours. The ranges consisted of: no estimate, < 5.9 ppm hours, 5.9 - 23.7 ppm hours, 23.8 - 66.5 ppm hours, and > 66.5 ppm hours.

The 1988 data results after combining the W126 and number of hours with ozone concentrations greater than or equal to 0.10 ppm placed the I-73 Study corridor area in Level 2 for ozone exposure levels associated with forest tree response. Levels included Minimal, Level 1, Level 2 and Level 3, with Level 3 having the most severe impact on trees.

The VDOT air quality analysis failed to address the loss of trees and that loss's impact on air pollution, citizens' health, and local climate. These impacts need to be studied.

In a 1992 FHWA position paper the FHWA says, “An important consideration is an estimate of the potential for development in the area of a proposed project within a reasonable period of time. The estimate should recognize the potential both with and without the project . . . in areas of moderate to rapid development, the contributions of a highway improvement can be a measurable element of the aggregated change leading to long-term impacts.”

On page 124 of the DEIS, VDOT states that the project area consists of 310,951 acres of forestland. Then on page 298, Table 4.2-1, VDOT outlines the acreage impacts to the forests. The Roanoke area stands to lose a significant amount of tree canopy from each of the build alternatives. The table below reflects loss of forestland from the highway itself. It does not include the resulting sprawl.

Percentage of loss of forestland for each alternative



1A 2 2A 2B 2C 3 3A 3B 3C 4 No-Build
NA 1.41 1.39 1.09 1.03 1.02 1.04 0.66 0.72 0.69 0.65 1.10 0

On page 144 of the DEIS, VDOT lists timber prices as the only possible economic impact from loss of forestland. An economic analysis based on citizen’s health and air/water pollution-fighting capabilities of forestlands needs to be assessed.

In July 1999, the non-profit group American Forests completed an Urban Ecosystem Analysis for the Roanoke area. (online at: _cities_sprawl/urban_analysis/roanoke.html) This included Roanoke County and portions of Bedford, Botetourt, Craig, Franklin and Montgomery counties. Using GIS mapping, satellite images from 1973 - 1997, and local on-site visits, an analysis on loss of tree canopy and associated values of that loss was completed.

Major findings from the study:

- Average tree cover declined from 40% to 35% in the Roanoke area.

- Natural tree cover (areas with at least 50% tree cover) declined from 41% to 32% of the total area.

- Heavily developed areas (with less than 20% tree cover) increased from 53% to 64% of the total area.

- Tree loss resulted in a 17% increase in stormwater runoff (515 million cubic feet) at a cost of $419 million.

- Total stormwater retention capacity of the urban forest in 1997 was worth $2 billion.

- The lost trees each year would have removed 2.93 million pounds of air pollution at a value of $8.2 million.

In 1997, the existing tree canopy removed 14.5 million pounds of pollutants, valued at $40.5 million. In 1973, the canopy removed 17.4 million pounds of pollutants, valued at $48.7 million. The report states, “When urban trees are large and healthy, the ecological system that supports them is also healthy. Healthy trees require healthy soils, adequate water, and clean air.”

Recommendations from the American Forests study include:

- Consider the financial value of natural resources in the decision-making process

- Increase and conserve the tree canopy cover. Roanoke should strive to reach 40 percent cover

- conduct analyses every five years to track future trends in forest canopy and associated benefits

In addition, according to the EPA, Virginia’s farmers lost between $12 million and $20 million in 1997 from reduced crop yields due to ozone damage.


VDOT failed to address the geography/topography/meteorology factor. The Roanoke Valley, home to Roanoke City and surrounding suburbs, forms a bowl, which tends to trap air pollution. The topography of the Roanoke area and its relation with air quality needs to be addressed in the DEIS, especially with regards to temperature inversions and air stagnation.

According to the Southern Appalachian Mountains Initiative (SAMI), “the southeastern United States has more frequent episodes of air stagnation than most other areas of the country. During these periods, pollutants can remain over the mountains for several days at a time. The naturally high humidity of the area magnifies the haze generated by airborne particles.”

A 1999 National Oceanic and Atmospheric Administration report (online at: titled Air Stagnation Climatology for the United States (1948-1998) states, “It has been observed that major air pollution episodes are usually related to the presence of stagnating anticyclones. Such anticyclones may linger over an area for a protracted period (4 days or more). During this period, surface wind speeds can fall to very low values. The near surface circulation is therefore insufficient to disperse accumulated pollutants, thereby causing distressful and possible hazardous conditions for the inhabitants of the area.”

In an annual mean sense, air stagnation events are most prevalent in the southern states. The trend in air stagnation days shows the Roanoke area is one of the SE regions which shows a positive trend or increase in stagnation days. From 1989 - 1998 (May-Oct.), in the Roanoke area, there were 23 cases of air stagnation days.

* air stagnation case of 4 or more days occurred

Year May June July Aug Sept Oct
1998       * *  
1997   *     * *
1996       *    
1995   *   * *  
1994       *    
1993   * * *    
1992 *     * *  
1991 * *   *   *
1990   *   *    
1989           *

- source: (table compiled from NOAA maps/data)

A “bowl effect” in the Roanoke area will worsen the impacts of a new terrain I-73, a new source of air pollution. Specifically, the NOx , CO, and other HAPs emissions for the entire Roanoke area will increase. All of the Build options traverse the proposed Roanoke ozone nonattainment area.

Health Impacts

VDOT glossed over the health impacts for the alternatives. VDOT briefly mentions the EPA Cumulative Exposure Project (DEIS 3.3-4), but fails to address the issue. Direct impacts to residents with respiratory problems should be addressed. Many of the pollutants from automobile emissions can aggravate existing conditions. At the very least, a simple coordinated effort with Roanoke area health officials could pinpoint areas within the I-73 Study area where there are high occurrences of respiratory illnesses.

In an American Lung Association report titled “State of the Air 2000”, the Roanoke County area was given a grade of “F” for its poor air quality and impacts on residents. The grade was based on the frequency of exceedences in the EPA Air Quality Index. “This report, and the analysis that underlies it, confirms what most citizens already know: air pollution remains a major threat to Americans, contributing substantially to the nation’s ill health burden.”, the report stated.

AT-RISK Groups impacted by Air Quality

County Total
Under 14 Over 65 Pediatric
Henry 56,078 10,399 7,846 789 2,260 3,033 458
Roanoke 81,480 14,568 11,210 1,120 3,310 4,398 659

- source: American Lung Association

A recently released University of Southern California Study shows that air pollution from the burning of fossil fuels slows lung function growth as children grow up. An excerpt from the study group’s press release says:

Common air pollutants slow children's lung development over time, according to results from the University of Southern California-led Children's Health Study. The 10-year-long study is considered one of the nation's most comprehensive studies to date of the long-term effects of smog on children.

"This is the best evidence yet of a chronic effect of air pollution in children," says John Peters, M.D., D.Sc., USC professor of preventive medicine and one of the study authors. "Long -term exposure to air pollution has long-term effects on children’s lungs, and the effects are more pronounced in areas of higher air pollution."

“... the offenders were nitrogen dioxide, microscopic particles known as particulate matter, and acid vapors. All come directly or indirectly from the burning of fossil fuels (the exhaust from a car or truck, for example), as well as from emissions from industrial plants and other sources...Although polluted air has long been known to cause immediate uncomfortable symptoms such as eye irritation, coughing and chest tightness, long-term or chronic effects have been less clear. In the current research, though, scientists have begun to demonstrate effects over time.”

VDOT should also acknowledge the possibility that cancer rates could increase in the I-73 Study area alternatives.

In a Saturday, March 4, 2000 ENN story titled “Mean streets: heavy traffic, leukemia linked”, ENN’s Lucy Chubb reports on a study that was published in the February 2000 issue of the Air and Waste Management Association journal.

Children who live near heavily traveled roads and highways are at greater risk of developing cancer, including leukemia, according to a study conducted in Denver, Colorado.

"What we are seeing is that children who live near high-traffic streets have an increased risk for childhood cancer," said co-author Robert Pearson, an adjunct professor of urban planning at the University of Colorado.

The researchers conclude that children living near transportation corridors carrying 20,000 or more vehicles per day are about six times as likely to contract cancer, including leukemia. The children are exposed to emissions through breathing and exposure to soil containing emissions.

The idea that vehicle emissions are to blame has "biological plausibility," Pearson said.


VDOT failed to address the potential reductions in visibility in the Roanoke area because of increased air pollution from a new terrain interstate highway.

Class I federal areas

Any of the build alternatives would potentially impact the visibility of the James River Face Wilderness Class 1 area, a federally protected area. This Class I area is located approximately 25 miles from the nearest I-73 build option and approximately 48 miles from the furthest option. VOC , ozone, NOx, and particulate matter emissions for each alternative should be calculated and included in a Supplemental DEIS. This procedure was done for the Appalachian Corridor H ASDEIS. The area was in “attainment”. Agencies expressed special concerns for the air quality of the Shenandoah National Park, the other Class 1 area in Virginia.

The Clean Air Act Amendments of 1977 declared as a national goal “the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I areas where impairment results from manmade air pollution.” According to the 1996 Southern Appalachia Assessment, there are only seven Class 1 areas in the Southern Appalachians. This includes 5 Wilderness areas, Shenandoah National Park, and Great Smoky Mountains National Park. Of the five Class 1 Wildernesses listed in the SAA, the James River Face has the poorest visibility. For the combined years from 1987 - 1993, James River Face had a median camera-based standard visual range (SVR) of only 15 miles during the Summer season and 66 miles during the Winter season. That compares with 19 miles SVR in the Summer and 138 miles SVR in the Winter for the Shining Rock, NC Wilderness area, which had the best SVR that was listed in the SAA.

According to the Southern Appalachian Assessment Atmospheric Technical Report, organic particles, volatile organic compounds, elemental carbon and nitrous oxides from diesel-fueled mobile sources and gasoline vehicles contribute to visibility problems in the eastern United States. These pollutants lead to regional haze which could impair visibility a great distance from the source area.

Percentage contribution by diesel and gasoline-fueled mobile sources to pollutants which affect visibility in the eastern U.S. - source: SAA

Pollutants Diesel-fueled Gasoline-fueled
Organic Particles   34 %
VOC   31 %
Elemental Carbon 47 % 29 %
NOx 16 % 26 %

A regional emissions analysis for VOC, NOx, and ozone should also address impacts to the Shenandoah National Park, which has been rated as having the second worst air quality for National Parks.

Acid Deposition

The acidic deposition effects on streams, soils, and vegetation from increased NOx pollution from vehicular emissions needs to be addressed. Potential environmental and financial impacts from tree damage, especially the Elm Trees in the downtown Roanoke area, crop damage, buildings and other structural damage needs to be assessed.

In a 1995 EPA Report titled “Acid Deposition Standard Feasibility Study, Report to Congress”, the EPA found that the eastern portion of the U.S. is most at risk from continued acid deposition. The targeted areas were the lakes and streams of the Appalachian Mountains.

The Virginia Trout Stream Sensitivity Study, which was released in October 2000, conducted by Trout Unlimited and analyzed by University of Virginia scientists shows that many of Virginia’s streams continue to suffer from acid rain. It showed that the number of “chronically acid” streams increased and will continue to increase. The number of dead streams is expected to more than double in the next 40 years.

Tourism/Economic Impacts

VDOT failed to mention the negative economic impacts to the Roanoke Valley area in relation to poor air quality/visibility. Economic impacts based on diminished visibility at the area’s two main attractions, the Star on Mill Mountain and the Blue Ridge Parkway need to be addressed. Without clean, clear air, visitors will have no incentive to visit these treasures.

The additional marring of the regional landscape from a new terrain interstate highway build alternative could have negative economic impacts from decreased tourism.

Additional pollution could potentially have negative economic impacts on healthcare and personal car maintenance. Roanoke area residents could suffer economically if health problems increase and/or vehicle emission control programs have to be instigated to offset ground-level ozone.

A Cost-Benefit analysis should be completed to study the economic impacts from all angles, not just interchange gas station/restaurant employment.

TSM/No-Build Alternatives

A primary goal of the Clean Air Act as amended in 1990 is to encourage or otherwise promote reasonable Federal, State, and local governmental actions, consistent with the provisions of this Act, for pollution prevention. (Title 1, Part A, Section 101 (c) [42 U.S.C. 7401] ) The TSM and no-build alternatives would meet the Clean Air Act and TEA-21 goals of not increasing emissions in nonattainment areas.

The TSM alternative and the no-build alternatives are the only two options that would not introduce more emissions from a new interstate source into the greater Roanoke area. These 2 options would not have adverse environmental impacts. The TSM and no-build alternatives are the only sensible alternatives to avoid future health and financial hardships on area residents as they struggle to rein in attainment for the Roanoke area. To choose a build-alternative would certainly alter our quality of life for the worse.


From a 1992 FHWA position paper, the FHWA says, "The new emphasis on environmental issues must include techniques that produce the best possible public interest decisions on project features such as, location, design and mitigation. These decisions will represent a balance between environmental, socioeconomic, and engineering issues. Therefore, we must assure full consideration of environmental concerns from the early stages of planning and throughout project development."

VDOT knows that Roanoke has air quality issues that need to be addressed. The evidence is overwhelming. However, VDOT failed to address significant adverse impacts to the human environment in the I-73 DEIS. VDOT needs to acknowledge the primary, secondary and cumulative air impacts of all the proposed I-73 alternatives. Environmental, health and economic impacts related to the Roanoke area’s air quality need to be properly studied for all alternatives. Once a complete, legitimate evaluation has been done, a proper assessment of the preferred alternative and conforming, mitigating measures can be performed.

We respectfully request VDOT to:

1) complete a mesoscale analysis, as was done for the Corridor-H project in West Virginia, for the Criteria Pollutants of ozone, nitrogen oxides (NOx) and volatile organic compounds (VOC). Particulate matter should be studied as well. This analysis should address the impacts to the Roanoke MSA and the Class 1 protected areas James River Face Wilderness and Shenandoah National Park. This analysis should be completed for all I-73 alternatives.

2) submit a regional emissions analysis for ozone, NOx, VOC and particulate matter to address conformity requirements for the entire FHWA I-73/74 project from Charleston, South Carolina to Sault Ste. Marie, Michigan. Special emphasis should be placed on nonattainment areas throughout this region of the United States. The cumulative impacts from the entire I-73/74 project needs to be addressed by the FHWA.

3) acknowledge that VDOT’s modeling and claims that increased traffic speeds will decrease air pollution, thus enhancing air quality in the I-73 Study Area contradicts other research using the same EPA MOBILE 5A modeling base.

4) complete a cost-benefit analysis which studies I-73’s environmental impacts and costs.

5) postpone choosing an alternative for I-73 until EPA makes its final designations for ozone nonattainment areas. It’s the prudent thing to do. VDOT should not circumvent their legal requirements by rushing to make a decision. The Virginia Secretary of Natural Resources in his June 29, 2000 letter to EPA asked EPA to postpone its final designations for ozone nonattainment areas until after the Supreme Court ruling on the 8-hour standard. The Secretary didn't want to add "confusion" to the process. Adding "confusion" to the process is exactly what VDOT is doing by not waiting for the Supreme Court ruling and EPA final designations.

6) postpone choosing a preferred I-73 alternative until a Supplemental DEIS has been completed. This SDEIS should properly analyze the primary, secondary and cumulative air impacts of all the proposed I-73 alternatives including environmental, health and economic impacts. It needs to include analysis of the 8-hour ozone standard and how the I-73 alternatives will impact the Valley residents’ way of life. Conformity requirements need to be addressed. Analysis needs to address new violations of the current ozone standard.