Mr. Nicol: 
    I have sent this letter on behalf of a group of citizens who live near Elwren, Indiana and who have taken interest in the   I-69:Evansville to Indianapolis Tier 1 Draft Environmental Impact Study  (DEIS) & Section 4(f) Evaluation of JULY 22, 2002 (EIS# FHSA-IN-EIS-02-01-D) and signed by J. Bryan Nicol and John R. Baxter.  We understand that you are one of the government officials with the authority to decide which of twelve I-69 alternatives will be selected for Tier 2 study. 
    We have provided this letter and associated detail information to ensure that you are aware of the serious public concern with the poor quality of data that this report is based on and with the public dissatisfaction in the studyís assessment of 'preferred routes' for Tier 2 evaluation.  While the Tier 1/Tier 2 definition appears to be a logical approach to handling the dilemma of 'exactly how detailed of data to consider' in down selecting  from twelve routes to one ñ the selection of a single route for further consideration is a very serious concern to the many thousands of citizens impacted by those routes and their local economies.  The public will not accept this selection if it is based on grossly inaccurate, incomplete and ill communicated information.  Nor will we be easily pacified by a lengthy study with pretty pictures or with  the promise of quality Tier 2 work. 
This DEIS is overly superficial in itís assessment of environmental impact,  it insufficiently defends the imaginary economic benefits that I-69 will result in, and it provides absolutely no basis for comparing the relative value of environmental impact (and cost) to any other considerations. 
This letter and data are being copied to a wide variety of citizens action and watchdog groups and public agencies with interest in various environmental, fiscal, and legal aspects of the DEIS study who will be solicited for assistance in ensuring that these issues (and many others that we could not fully address in the available timeframe for public comment) are responsibly addressed by INDOT in this process.
Any questions or responses related to this letter can be directed to:
Mr. Gary Milhoan, R.R. 3 Box 480, Solsberry, Indiana 47459

 Executive Summary:
    A group of interested citizens has spent considerable time understanding this report and assessing the quality of some of the data.  This executive summary will briefly state the major issues with no elaboration and the detail will be provided later in the document.
The DEIS study does not effectively address environmental impacts as the title of the study suggests and its conclusions are confused with other objectives. 
The study is flawed on a macroscopic level.  The summary pages S-21, S-22, and Table data on S-24 very clearly specify that Alternative 1 is the logical choice from an environmental impact perspective, yet the ìenvironmental impact' study doesnít recommend this route.
Environmental impact and cost are obviously given very little weighting in the recommendations at all since Alternative 1 is not among the ìpreferred routes'. 
The study is seriously superficial on a microscopic level,  as it vastly underestimates the actual  environmental impacts and is based on only the most rudimentary information despite the claim on page S-6 that ìextensive field visits' were made.  More detailed knowledge of the Karst character of the Alternative 3 route will certainly increase even the high cost estimates for all three routes of Alternative 3 substantially.
The study does not adequately address impact to the  federally protected Indiana Bat if Alternative 3 is chosen. The DEIS study lists only the most superficial data on their known hibernaculum and includes absolutely no assessment of the impact of the substantial loss of critical habitat (to breeding, feeding, and living within a reasonable range of their hibernating areas).  This has been communicated to INDOT by USFWS but seems to be categorically ignored in the DEIS.
    Karst feature topology impact is dramatically understated for Alternative 3.  Again, the study is based on only the most superficial data and it is apparent that no ìextensive field studies' were performed as the study claims.  This could result in huge cost increases to avoid environmental damage (similar to the Mitchell plain fiasco on Route 37 a few years ago).  Substantiation of a additional Karst features in a very small area of Alternative 3 (A&B) is included with this letter.  More than a dozen additional undocumented caves have been identified (by this citizenís group) within the 2 mile study band of Alternative 3 (A, B, and C) but have not yet been documented by the Indiana Geological Survey or explored for Indiana Bat hibernaculum by USFWS.
 Background Information on KARST:
    A group of citizens along Alternative 3 became aware of the DEIS study and spent time to understand the detail contained therein.  Several concerns arose quickly from an understanding of the study:
There was no apparent concerted effort by INDOT to contact landowners along the route, raising suspicion of the true intents of this study and the INDOT decision process.   In all discussions to date, we have found no landowner who was contacted by anyone for field studies of their properties. 
Alternative 1 is cheapest, least environmentally damaging and not included among the preferred routes.  No need to substantiate this obvious fact that the DEIS study completely supports.
The DEIS study does not define any weighting for factors considered in recommending preferred alternatives. 
Alternative 3 is listed among the preferred routes and unnecessarily  dissects a very fragile Karst area with a substantial population of the federally endangered Indiana Bat.  The Karst information in the DEIS study considerably underestimates the actual concentration of features within the 2 mile study area of Alternative 3.
This citizens group recognized (based on knowledge of the area) that the DEIS study is based on insufficient knowledge of the actual Karst festures along Alternative 3. 
Studying the map of Karst feature concentration (ATLAS, Alternative 3, Page 7 of the DEIS study) reveals that it is based only on the existing superficial data provided by the Indiana Geological Survey.  This same information (for Greene and Monroe counties) is provided as Apendix 1 of this letter. 
Far more Karst features exist in the proposed two mile corridor of Alternative 3 than the DEIS data would suggest.
The entire Karst region could have been avoided by keeping Alternative 3 slightly further West.
County plattes were assembled and overlayed with IGS cave data and the two mile corridor to ascertain whether the known Karst features were indeed overlooked by the DEIS study and it was quite apparent that the study underestimates the features within the chosen two mile corridor.  This group also determined that no landowners in this area have been contacted by anyone for any field studies (and we have surveyed many landowners within the 2 mile corridor). 
    To provide credible evidence of the inadequacy of this study in assessing true environmental impact, we established a small study group of properties spanning the two mile study band along Alternative 3 (A&B).  We plotted plattes, overlaid the Alternative 3 route, obtained from the Indiana Geological Survey  the same source data (appendix 1) that was provided to INDOT for this study, and plotted all  known caves on the maps.  Then we contacted landowners in this small band to ascertain whether there are indeed Karst features on their properties that are not included in the source data.  We couldnít correlate this data to the study exactly because the study doesnít include detailed data on karst.  Interestingly enough, these landowners were overwhelming happy to help us in this endeavor (as they are very concerned that Alternative 3 represents real and significant environmental damage to their properties).  To no great surprise, this small effort revealed a tremendous number of undocumented Karst features situated exactly within the two-mile band that the study preparers  have purportedly ìfield verified (extensively)' already.
    We contacted the  Indiana Geological Survey, who provided assistance to us in locating, classifying, characterizing, and documenting a number of these features.  There was not sufficient time to explore many properties (a couple dozen out of hundreds within the Karst area) but the documentation of some of the additional features is included as appendix 2.  Many other Karst features have been communicated as word of this effort spread ñ including two long undocumented caves that may completely traverse the Alternative 3C route and have powerful year round water flow.  Over a dozen additional property owners have stepped forward with information on undocumented caves within the proposed two mile study band of Alternative 3 ñ but time has not allowed detailed substantiation for this letter.  Many of these property owners also have substantial evidence on the use of their properties by Indiana Bats which depend upon this rare and fragile rural Karst region for their diminishing existence.
Appendix 3 is a report on the Significance of Karst Features in Western Greene and Eastern Monroe Counties as written by Mr. Sam Freshour ñ a local cave expert.
Background Information on the Indiana Bat:
    The Indiana Bat is a federally endangered and protected species which resides in the exact area that Alternative 3 would be dissecting and damaging.   While the DEIS study gives lip service to this issue (chapter 5.17 and the map of ATLAS, Alternative 3, pade 9), there is no actual study of even the direct impact of eliminating multiple hibernaculums of these rare creatures let alone the very definite impact of eliminating feeding grounds and dissecting and diminishing the exact home range habitat that they breed in. 
No doubt there will be attempts to hide behind the ìTier 1' nature of this study and conversation about how the real details are going to be dealt with in Tier 2.  That approach is not very convincing considering the well known existence of these bats in this area and the well documented need to protect their habitat and the fact that the stated objective of this study is to have sufficient detail to decide on one single alternative. 
A quick look at the map included in the DEIS study reveals that there are only 49 known hibernaculums in the study area of Alternative 3.  Yet 4 of these are directly within the two mile corridor of Alternative 3.  More significantly, as many as 21 out of 49 are within about 5 miles of Alternative 3.  Why did the DEIS study not address these facts or assess the impact of elimination of this rare and significant bat range to the rapidly declining total population of this federally protected species ?
    "The present total population of this endangered species is fewer than 360,000, with more than 85 percent hibernating at only nine locations, making them extremely vulnerable to destruction. "Harvey, M.J., J.S. Altenbach, and T.L. Best. 1999. Bats of the United States. Little Rock: Arkansas game and Fish Commission.
To elaborate a little further on the likelihood of severe damage to the Indiana Bat, one must consider the reality of what is readily available information.  The very abundant caves of western Monroe County are very well known and very well documented.   These caves were ìopened up' over years and years (4 decades at least) with different groups of cavers working to dig out new sections of caves.  Now that so many people have spent so much time ìopening up' these caves ñ now we can walk in and observe the Indiana Bat hibernaculums that have probably been there for a long time.  There are nearly as many caves in the area of Eastern Greene County that Alternative 3 would dissect but these caves are on private property and have not been made accessible to the public.  However, bats do not need the same size openings that people do.  There are roughly 21 known (current or historical) hibernaculums for the federally protected Indiana Bats in the immediate area that Alternative 3 would destroy.  There is little doubt that there are additional hibernaculums that are currently unknown that will be destroyed if Alternative 3 becomes reality.   One neighbor on the route has a small cave on his property that he has seen bats flying into and out of.  He does not want to make his cave known for liability purposes.  What a shame that he may be forced to exploit his property to save it from being exploited by INDOT.  Dozens of property owners in this area have indicated that they have trees and ìholes' that are used as summer homes for Indiana Bats.  While some of these may not be Indiana Bats ñ we will be providing additional ìground level' assistance to ensure that the USFWS and other bat experts have access to these locations to distinguish the density of actual Indiana Bat presence.  Weíll also be working to ensure that some actual assessment is performed to determine the impact (on the remaining Indiana Bats) of destroying  this much  rare habitat. 
   Hydrology is another area of great concern that will be closely watched also but the ìgrass roots' legwork for these may lag behind the November 7 comment period.  There are many people in the area who have well water and use spring water for livestock.  These folks are very concerned that their springs may run dry or become polluted from this unwanted, unnecessary thoroughfare.
This study is a farce ñ at the macro and the micro level.  The only reasonable conclusion that could be drawn from its data is that Alternative 1 is the best alternative from an Environmental Impact perspective.  And that is the perspective that an Environmental Impact study needs to remain focused on. 
Appendix 1

Indiana Geological Survey provided 
list of Caves in 
Greene and Monroe Counties Appendix 2

Documentation of Additional Karst Features within 2 mile Study Band of 
Alternative 3

Includes:
six summary 11x17 topographic maps
84 two-sided sheets of cave report forms  Appendix 3

Report on the 
Significance of Karst Features in Western Greene and Eastern Monroe Counties Appendix 4

Indiana Bat Literature