Letter to the Honorable Robert A. McDonald, Secretary of Department of Veterans Affairs - On the Reconfiguration of Black HIlls Health Care System

Letter

The Honorable Robert McDonald

Secretary of Veterans Affairs

Department of Veterans Affairs

810 Vermont Avenue, NW

Washington, D.C. 20420

Dear Secretary McDonald:

We write to request an additional extension to the comment period for the Department of Veterans Affairs' (VA) Draft Environmental Impact Study (EIS) concerning the proposed reconfiguration of the Black Hills Health Care System (BHHCS). While we appreciate the VA granting a 30-day extension after the VA BHHCS National Environmental Policy Act (NEPA) historic properties consultation for Hot Springs was rescheduled from December 1, 2015, to January 21, 2016, we believe that a 60-day comment period extension would better allow for thoughtful review and comment in response to this final consultation meeting.

Extending the comment period will also provide additional time to address the requirements of Section 106 of the National Historic Preservation Act (NHPA). Ideally, both the NHPA and NEPA processes would proceed in concert in order to provide detailed analysis and consideration of the draft EIS. However, we understand that the NHPA process is far behind its NEPA counterpart. The consultation process may be further delayed because Labat Environmental, Inc. has switched working with SWCA as the consultant leading the Section 106 consultation process and is instead proceeding with R. Christopher Goodwin and Associates, Inc.

Additionally, Section 106 requires that the VA provide the Advisory Council on Historic Preservation (ACHP) "a reasonable opportunity to comment." The ACHP is awaiting a response from the VA to a series of questions posed to the agency in a letter dated December 21, 2015. This letter was precipitated by requests from the South Dakota State Historic Preservation Office and the National Trust for Historic Preservation for a Section 213 report to be completed by the National Parks Service (NPS), which will provide detailed recommendations on avoiding, minimizing, and mitigating adverse effects to the historic integrity of the Hot Springs VA. If the ACHP agrees to request a Section 213 report from the NPS, they will need adequate time to prepare it.

An inclusive and accessible comment period for the draft EIS is essential for ensuring thoughtful participation by all consulting parties and stakeholders. Unfortunately, the VA's postponement of the Hot Springs NEPA historic properties consultation and delays in the NHPA process may limit constructive contributions. For these reasons, we respectfully request an additional 30-day comment period extension.

Thank you for your consideration. We look forward to your response.

Sincerely,