On behalf of the Chickahominy Indian Tribe, please see our comments:

• Adopting program assignment currently would endanger the consideration of historic preservation and Tribal impacts on transportation projects in the state.
• The Commonwealth should pause this program application until the ACHP regulations rulemaking is resolved.
• If Virginia moves forward with program assignment, they should pass a state law requiring equivalent historic preservation requirements for VDOT, to authorize VDOT to continue its current environmental and historic preservation review.
• If Virginia moves forward with program assignment, they should also pass state legislation to apply tribal consultaiton requirements to VDOT.
• Moving forward without state law protecting historic resources would tie Virginia's hands and create more controversies and public relations challenges for Virginia and VDOT. 

Regards,

Lenora Adkins

Director

Program Management and Compliance Office-PMCO

Chickahominy Indian Tribe

8200 Lott Cary Road

Providence Forge, VA 23140

C: (804) 661-0809

F: (804) 500-0874