Appendix B - Letter that No Archaeological Survey is Required

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U.S. Department
of Transportation
Federal Railroad
Administration
Dr. Kevin Cherry
State Historic Preservation Officer
North Carolina State Historic Preservation Office
109 E. Jones Street
Raleigh, NC 27601
Attn: Ms. Renee Gledhill -Earley, Environmental Review Coordinator
1200 New Jersey Avenue, SE
Washington, DC 20590
RE: Proposed Improvements to the CSX Railroad SE Line (the "Beltline") Railroad and
Crossings — STIP P-5740 (Part of the Piedmont -Atlantic Intermodal Rail System
Project)
From east of the CSX Davis Yard in Navassa, Brunswick County to S. 2nd Street in
Wilmington, New Hanover County, North Carolina
Initiation of Section 106 Consultation and Finding of No Adverse Effect
Dear Dr. Cherry:
The Federal Railroad Administration (FRA) is providing financial assistance, through the Fiscal
Year 2018 Consolidated Rail Infrastructure and Safety Improvements (CRISI) Program, for a
Project to be undertaken by the North Carolina Department of Transportation (NCDOT) Rail
Division. The proposed improvements to the CSX Railroad SE Line (the `Beltline") Railroad
and Crossings (Project) is located from east of the CSX Davis Yard in Navassa, Brunswick
County to S. 2nd Street in Wilmington, New Hanover County, North Carolina (see Attachment
1). The Project is part of the larger Piedmont -Atlantic Intermodal Rail System Project. FRA is
the lead federal agency for this federally -funded undertaking, pursuant to Section 106 of the
National Historic Preservation Act of 1966, as amended, and its implementing regulations (36
CFR Part 800) (Section 106). All Section 106 work was undertaken by individuals who meet or
exceed the Secretary of the Interior's Professional Qualifications Standards for Architectural
History or Archeology (36 CFR Part 61). FRA is initiating the Section 106 consultation process
for the undertaking and seeks your concurrence with our findings.
Project Description
For this Project, which is the undertaking for the purposes of Section 106, the NCDOT Rail
Division proposes improvements to approximately 13 miles of the CSX Railroad SE Line, which
will include rehabilitating ties and rails; adding a minimal super -elevation on the existing
alignment at "Fernside Junction", a wye in northeastern Wilmington; upgrading switch
operations and train signaling; closing and improving several existing at -grade crossings, to

Proposed Improvements to the CSX Railroad SE Line (the `Beltline") Railroad and Crossings
Page 2
include surface and signal improvements; installing necessary signage prior to altering any traffic
patterns; realigning a railroad alignment curve; constructing two new street segments; installing
or improving signal access maintenance roads; and rehabilitating the superstructures at two steel
truss bridges (each with a moveable bascule span) to involve cleaning, repainting, welding
and/or patching deteriorated members, and replacing mechanical gearing. In addition, there will
be electrical work, including a new supplemental signals interface cabinet inside the operator's
house at the CSX Hilton Bridge over the Northeast Cape Fear River. At the CSX Navassa Bridge
over the Cape Fear River, the signal control house may be replaced at a new location on the
shoreline. Also at the Navassa Bridge, existing conduits housing cables under the main river
channel, along with their cabinets on either side of the channel, will be removed and replaced.
A number of historic architectural activities are exempted for their effect on railroad rights -of -
way resources by applying the activities -based approach of the Program Comment to Exempt
Consideration of Effects to Rail Properties Within Rail Rights -of -Way issued by the Advisory
Council on Historic Preservation on August 17, 2018 (83 FR 42920, August 24, 2018, and
amended 84 FR 31075, June 28, 2019) (Program Comment). Under the Program Comment,
federal agencies do not need to assess effects on rail -related historic properties within existing
railroad right-of-way if the project activities are covered by one or more exempted activities in
Appendix A: Exempted Activities List.
To consider potential effects on historic architectural railroad and non -railroad historic
properties, Section 106 consultation is required on the following activities taking place at 11
project locations in the table below (also see Attachments 2 and 3):
Attachment 3
Activity for Historic Architectural Section 106
Location # (Map Page #
Consultation
B (p. 17)
Close at -grade crossing as well as close a portion of Martin
Street from S. 4th Street to S. 5th Street. Install end of road
markers, guardrail and landscaping. Define the edge of
pavement to minimize parking within railroad limits on the
southwest corner property of S. 5th Street and Martin Street.
G (p. 16)
Close at -grade crossing at S. 9th Street near Martin Street, and
install end of road markers, guardrail and landscaping.
V (p. 10)
Close at -grade crossing at Clay Street near Princess Place
Drive, and install end of road markers and guardrail, and
landscaping, work extending outside the railroad right-of-way.
Z (pp. 7, 8)
Slightly re -align King Street at a railroad crossing that includes
relocating a utility pole and install sidewalks, work extending
outside the railroad right-of-way.
B-B (pp. 7, 8)
Realign a 2,500-feet-long railroad curve, located west of King
Street and near the Love Grove community, to create a new
straight railroad alignment.
D-D (pp. 1, 2)
Possibly replace the signal control house at the CSX Navassa
Bridge with a new control house at a new location to the

Proposed Improvements to the CSX Railroad SE Line (the "Beltline") Railroad and Crossings
Page 3
Attachment 3
Activity for Historic Architectural Section 106
Location # (Map Page #
Consultation
southwest shoreline, likely a CSX standard 8' x 12' aluminum
bungalow. The former location of the signal control house, as
well as the adjacent small, modern materials storage shed,
would be replaced with an electrical bungalow and signal
bungalow, both proposed to be CSX standard 8' x 12'
aluminum bungalows.
D-D (pp. 5, 6)
Install a standard signal interface cabinet in the operator's
room upstairs; associated wires will be pulled and terminated.
G-G (pp. 16, 17)
Construct a new road to connect Kidder Street between S. 8th
and S. 9th Streets, on dedicated public right-of-way, to provide
access to compensate for closures.
I -I (pp. 4, 5)
Construct new signal access maintenance road within CSX
right-of-way, west of Hilton Rail Bridge
I -I (p. 7)
Construct new signal access maintenance road within CSX
right- f-wa, at Bess and McRae Streets
V-V (p. 10)
Construct new street connection between Henry and Clay
Streets on the south side of the CSX right-of-way
The Project will involve ground disturbance, both within and outside the CSX railroad right-of-
way. These include 21 existing at -grade crossings where, depending on the crossing location, the
Project improvements could include potential ground disturbing activities such as crossing
surface improvements, sidewalk upgrades, signal system upgrades, and crossing gate
installations (locations A, B, C, D, E, F, H, I, J, N, O, P, Q, R, S, U, W, X, Y, Z, and A -A). The
precise location of ground disturbance within these areas is currently unknown. The areas where
there may be new signs within public right-of-way areas, installed to account for altered traffic
patterns, are also currently unknown. Activities at location B-B involve constructing new track
work, G-G and V-V involve vehicular road connections, and I -I (both locations) would build
new signal access maintenance roads. Also, existing conduits housing cables under the main
channel will be removed, to be replaced by new high -density polyethylene conduits that will be
directional bored under the channel, at an estimated depth of 20 feet.
Areas of Potential Effects
As defined in 36 CFR Part 800.16(d), the Area of Potential Effects (APE) means "the geographic
area or areas within which an undertaking may directly or indirectly cause alteration in the
character of use of historic properties, if such properties exist. The area of potential effects is
influenced by the scale and nature of the undertaking and may be different for different kinds of
effects caused by the undertaking." In addition to areas with potential physical effects, the APE
also accounts for potential visual, noise and atmospheric effects on the built environment.
The archaeological APE is limited to discontiguous areas with potential ground disturbance,
which are described in the last paragraph of the Project Description (see Attachment 4). The

Proposed Improvements to the CSX Railroad SE Line (the `Beltline") Railroad and Crossings
Page 4
historic architectural APE was delineated around the entire approximately 13-mile corridor,
generally following the project area boundaries along the CSX Railroad SE Line (see
Attachment 3). At the crossing improvement areas, the historic architectural APE follows the
areas of potential ground disturbance outlined by the archaeological APE. The APE was not
expanded beyond the potential project areas because the Project will not visually, audibly, or
atmospherically change the character of the areas which are already located within or adjacent to
a railroad and will continue to be after the Project is completed.
Identification of Historic Properties
Archaeology
NCDOT's Archaeology Group reviewed the Office of State Archaeology's repository that
includes GIS databases, USGS topographic maps, historic maps (NCMaps website), USDA soil
survey maps, and aerial photographs, with information compiled in a No Archaeological Survey
Required Form completed on December 3, 2019 for this Project (see Attachment 5, No
Archaeological Survey Required Form). A study area was used that generally overlaps with
the historic architectural APE. The study focused on areas along the corridor where effects may
occur outside the railroad existing right-of-way, which was generally treated as being heavily
disturbed and therefore not reviewed unless previously recorded archaeological sites were noted
within the existing right-of-way. No such archaeological sites were identified within the study
area, leading to the creation of two discontiguous archaeological APEs within the study area
focusing on the project's potential footprint beyond the railroad's existing right-of-way. These
included Location B-B and a second location which no longer involves ground disturbance as
part of the Project. There were also no known sites recorded at or in the vicinity of the Navassa
Bridge, and previous nearby Projects, involving underwater archaeology in the bridge's vicinity,
found there to be low probability of submerged sites or involved an archaeological survey that
found no sites in the immediate area (see Attachment 5, November 13, 2020 email). In
addition, the estimated depth of the under -channel conduits is well below the estimated one foot
or so depth where underwater archaeological resources are anticipated at this river channel.
The archaeological study found that, based primarily on the nature of the proposed Project,
historical land use, and the results of previously reviewed/surveyed projects in the area, the
archaeological APE is unlikely to contain intact and significant archaeological resources. In
addition, the project will be located in railroad and public right-of-way areas that are likely
previously disturbed. Therefore, no further archaeological investigation (terrestrial or
underwater) is recommended for this Project. NCDOT's Archaeology Group followed up on
October 26, 2020 to indicate these findings remain the same, even with recent project changes
(see Attachment 5, October 26, 2020 email).
Historic Architecture
NCDOT consultant, Moffatt & Nichol reviewed North Carolina State Historic Preservation
Office's (SHPO's) HPOWeb to identify previously surveyed historic resources within the APE.
The Wilmington Historic District is located within the APE (see Attachment 3, Map pp. 16 and
17). The historic district was listed on the NRHP in 1974 with a boundary expansion and

Proposed Improvements to the CSX Railroad SE Line (the `Beltline") Railroad and Crossings
Page 5
additional information provided in 2003. It is listed under Criteria A and C with a period of
significance from 1900 to 1945.
Two resources, the Delgado -Spofford Mill Village Historic District (NH2344) and Oakdale
Cemetery (NH0160) are on the SHPO Study List and are located just outside the APE.
The Navassa and Hilton Bridges are part of the CSX Railroad SE Line, formerly the Seaboard
Air Line Railway/Atlantic Coast Line Railroad. The Navassa Bridge was originally constructed
in circa 1911, with alterations made in the mid- 1960s to the north approach span and late 1990s
to the south approach span. The bascule truss portals and sway frames were modified in the late
2000s. The signal control house, possibly original from the 1911 bridge construction, has been
modified and the adjacent small materials storage shed was likely constructed sometime after
2002. The platform on which they stand has been extended. The Hilton Bridge was constructed
in 1971. Neither the railroad alignment nor the bridges have been previously evaluated for the
NRHP. For the purposes of this Project, FRA is considering the Seaboard Air Line
Railway/Atlantic Coast Line Railroad to be eligible for the NRHP (36 CFR Part 800.4(b)(1),
with both bridges as contributing elements to the railroad alignment.
Therefore, there are two historic properties within the historic architectural APE: Wilmington
Historic District and the Seaboard Air Line Railway/Atlantic Coast Line Railroad.
Assessment of Effects
FRA has determined the Project has the potential to affect historic properties. However, after
applying the criteria for adverse effect (36 CFR Part 800.5(a)(1) and (2)), FRA found the Project
will have No Adverse Effect on historic properties.
Archaeology
There are no NRHP-listed or eligible archaeological historic properties located within the APE.
In addition, it is unlikely that there are any intact archaeological resources within the APE.
Therefore, the proposed improvements are not anticipated to affect significant archaeological
Historic Architecture
Wilmington Historic District: The at -grade crossing at Hooper and Martin Streets will be closed,
and end of road markers, guardrail and landscaping will be installed, in a part of the district
located within the railroad right-of-way (Location B) (see Attachment 6, Figure 1). The new
Kidder Street alignment (Location G-G) is located within the edge of the Wilmington Historic
District in a public right-of-way that is currently wooded and appears to have originally been
intended as the continuation of Kidder Street, which was never constructed (see Attachment 6,
Figures 2 and 3). Curb turnouts already exist to the east and west to accommodate this roadway.
No above -ground resources associated with the district exist within these two areas. Therefore,
the project would not directly affect any of the historic district's contributing elements, and
would not alter the historic property's integrity of location, design, materials, and workmanship.

Proposed Improvements to the CSX Railroad SE Line (the `Beltline") Railroad and Crossings
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The resulting Project would not add any new visual, atmospheric, or audible elements that are
significantly different from those that already exist in this developed, urban environment. The
historic property's setting, feeling, and association would remain the same. The Project would
not alter any of the characteristics of the Wilmington Historic District that would diminish its
integrity. Therefore, the Project will have no adverse effect on the Wilmington Historic District.
Seaboard Air Line Railway/Atlantic Coast Line Railroad: The Project may replace the signal
control house of the railroad's Navassa Bridge with a new control house at a new location on the
southwest shoreline (first Location D-D) (see Attachment 6, Figure 4). The current location of
the signal control house, as well as the adjacent small materials storage shed, would be replaced
with an electrical bungalow and signal bungalow. However, this work would not change the
overall appearance and character of the bridge or the significantly larger railroad historic district.
The same is true of the bridge's new conduit cabinets, as well as the Hilton Bridge's new
supplemental signal control cabinet, which would be installed within the operator's room
(second Location D-D). The railroad's overall appearance and character would not change with
the work proposed at the closed crossings, the slight realignment of King Street at a railroad
crossing (Location Z), the realignment of a current railroad curve (Location B-B), and the
addition of new roads within the railroad right-of-way (both Locations I -I) (see Attachment 6,
Figure 5). Therefore, the Project would not diminish the design, material, and workmanship of
the historic property.
While the realigned railroad curve (Location B-B) changes the location of the railroad in this
area, the railroad would otherwise retain its historic alignment. The Project would not change the
historic property's setting, including Wilmington's historically urban setting. This project
activity would not change the historic property's feeling and association as a railroad alignment.
Rather, the Project would help maintain the use of the right-of-way as an active railroad
transportation corridor. The Project would not alter any of the characteristics of the Seaboard Air
Line Railway/Atlantic Coast Line Railroad that would diminish its integrity. Therefore, the
Project would have no adverse effect on the Seaboard Air Line Railway/Atlantic Coast Line
Railroad.
Consulting Party Outreach
In accordance with 36 CFR Part 800.2(c), FRA identified parties that may be interested in
reviewing and commenting on the proposed Project and FRA's determination of effect. The City
of Wilmington, Historic Wilmington Foundation, and Town of Navassa are copied on this letter
to serve as their invitation to participate as Section 106 consulting parties. FRA is also inviting
the Catawba Indian Nation, a federally recognized Indian tribe.
Should any of the parties express concerns about the Project's potential effects to historic
properties, FRA will continue to consult with the parties and the North Carolina State Historic
Preservation Officer to resolve those issues prior to project implementation.

Proposed Improvements to the CSX Railroad SE Line (the `Beltline") Railroad and Crossings
Page 7
Request for Section 106 Concurrence
FRA seeks your concurrence with this finding of No Adverse Effect pursuant to 36 CFR Part
800.5(b) and (c)(1). FRA is providing documentation of this finding, as set forth in 36 CFR Part
800.11(e). Should you disagree, please notify us within 30 days via e-mail to ensure timely
receipt of your communications. FRA staff are currently working remotely and are not able to
access mailed correspondence. Please respond to Michael Johnsen, Supervisory Environmental
Protection Specialist, [phone] or [e-mail] and contact him if you have
questions or wish to discuss this Project.
Sincerely,
19W ""' �
Katherine Zeringue
Federal Preservation Officer
Environmental and Project Engineering Division
Office of Railroad Policy and Development
Enclosures:
cc:
Attachment 1 — Vicinity Map
Attachment 2 — NCDOT Project Plans
Attachment 3 — Historic Architectural Area of Potential Effects Map
Attachment 4 — Archaeological Area of Potential Effects Map
Attachment 5 — NCDOT No Archaeological Survey Required Form and emails
Attachment 6 — Photographs of Historic Properties within Project Areas
Randall Brown, FRA Project Manager
Michael Johnsen, FRA Supervisory Environmental Specialist
Christeen Taniguchi, FRA Environmental Protection Specialist
Ron Lucas, NCDOT Rail Project Development Manager
Undrea Major, NCDOT Senior Rail Project Development Engineer Consultant
Marc Hamel, Moffatt & Nichol Project Manager
Jeff Walton, City of Wilmington Associate Planner (staff liaison for the Historic
Preservation Commission)
Beth Rutledge, Historic Wilmington Foundation Executive Director
Barnes Sutton, Town of Navassa Planning and Development Director